Summary of issues raised in submissions received from prescribed experts, agencies and authorities14 on the consultation RARMP for DIR 095
The Regulator received several submissions from prescribed experts, agencies and authorities on the consultation RARMP. All issues raised in submissions relating to risks to the health and safety of people and the environment were considered in the context of the currently available scientific evidence that was used in finalising the RARMP that formed the basis of the Regulator’s decision to issue the licence. A number of submissions received raised issues relating to risks to the health and safety of people and the environment as summarised below.
|Summary of issues raised||Comments|
|Considers that there is potential for the genetic modifications to increase sugarcane’s weediness, through the intended effects of genetic modifications to enhance nitrogen use efficiency, enhance drought tolerance, to alter plant growth, to improve sucrose accumulation and to improve cellulosic ethanol production, and also through unintended effects in all lines.|
States that no scientific data is provided to support the argument that changes to plant growth would not give rise to some selective advantages over non-GM sugarcane in the non-agricultural environment.
States that consideration should be given to effects of WUE genes on both drought tolerance and water use efficiency, which could play an important role in the establishment of GM sugarcane from vegetative propagation. Drought tolerance plus water use efficiency may result in weediness.
|The spread and persistence of sugarcane in the environment is limited by a complex range of factors including its low fertility and seed viability, nutrient requirements and susceptibility to pests and diseases. In the RARMP, the potential for the genetic modifications to increase the weediness of the GM sugarcane through intended and unintended effects is discussed (Event 2), and further discussion has now been introduced to the RARMP to provide additional general consideration of how weediness may be altered by the introduced traits.|
In the absence of phenotypic characterisation of the GM lines, the RARMP gives consideration to a wide range of reported effects of expression of the introduced genes in GM plants. It is noted that such phenotypes may not necessarily occur in the GM sugarcane, and that the discussion includes a much broader range of phenotypes than may actually occur.
It is concluded that direct and unintended effects may incrementally increase weediness of the GM sugarcane. However, it is unlikely that the introduced genes or RNAi constructs would be able to alter all of the characteristics which limit the spread and persistence of sugarcane. In any case, measures have been imposed to restrict any potential spread and persistence of the GM sugarcane.
|Considers that the risk of gene transfer from GM sugarcane to non-GM sugarcane and other Saccharum species (especially S. spontaneum) exists.
Recommends that at field sites, flowering should be monitored and inflorescences removed and destroyed if they are not required for further experimentation.
|In Event 4, gene transfer from the GM sugarcane to other sugarcane and subsequent establishment of new plants is considered unlikely due to:|
In Event 5, the sexual compatibility of sugarcane with other species and the potential for crossing to occur is discussed. Other Saccharum species are not known to occur near any of the sites except BSES Meringa, where a clone garden containing several specimens is located, and S. spontaneum occurs in naturalised populations several kilometres away. Control measures have been imposed to restrict pollen dispersal from GM sugarcane at BSES Meringa.
|States that the related genera Vacoparis and Sarga are found in sugarcane growing regions, and it is not known if sugarcane can hybridise to these native species though they are thought to be sexually compatible with sugarcane at very low levels (Bonnett et al 2008).||In Bonnett et al (2008) discussion of Vacoparis and Sarga is limited to noting that there are no reports on the ability of these genera to hybridise with sugarcane. However, as these species are closely related to Sorghum, their sexual compatibility with sugarcane may be similar. As discussed in the RARMP, hybridisation between sugarcane and Sorghum bicolor has been established to occur at very low frequency under artificial conditions and give rise to hybrids lacking vigour.|
|States that some sites are close to natural waterways, and occur in regions prone to flooding. 50 m separation from natural waterways is not satisfactory given the course of natural waterways, the length of the trial and the potential for flooding.
Recommends a fence to trap floating plant material if relocating to a non-flooding zone is not practicable.
|Further information on the likelihood of flooding at the proposed trial sites has been added to the RARMP.|
The trial sites were chosen, amongst other reasons, because “the risk of flooding is very minimal”. The applicant has provided further information clarifying that BSES Meringa, Burdekin and Southern have no history of flooding, and BSES Woodford is in an elevated part of a flood-prone area and has experienced no significant flooding in the past 10 years. Flooding is rare at BSES Central, which is 5 km from the nearest major waterway, with the station being unaffected by significant floods in the area in 2008. The applicant also states that sugarcane plants are generally not uprooted by floodwaters, unless significant water flow occurs.
Dispersal of GM sugarcane leading to its spread and persistence in the environment was therefore not considered an identified risk and control measures to restrict movement of pieces of GM material during flooding were not imposed.
|Considers that the release being conducted alongside ongoing work on non-GM sugarcane poses some level of risk of inadvertent mixing of GM and non-GM materials. Suggested controls included:
||The proximity of the release to conventional sugarcane gave rise to consideration in the RARMP of the potential for GM sugarcane to pollinate non-GM sugarcane (Event 4), and also for inadvertent mixing of GM and non-GM sugarcane leading to dispersal of GM material (Event 3).|
In relation to the potential for accidental mixing of GM and non-GM sugarcane, the imposed licence conditions include controls to reduce the risk of this occurring, including:
The licence describes a crossing facility as being made up of several discrete areas of various parts of the BSES Meringa and Bundaberg stations (eg one area of a photoperiod facility, one area of a crossing shed, one area of a glasshouse). Non-GM material within areas designated for use with GM plants must be treated as if it were GM. In other parts of facilities within which GM plants are kept, non-GM material is not required to be destroyed since the licence requires separation measures as described above, and measures to restrict gene flow.
|Considers that contingency plans should cover the possibility of cyclone damage, and should include treating any sugarcane material which falls within the 6 m isolation zone as if it were GM.||The licence requires that sugarcane or related species found within the isolation zone be destroyed.|
BSES is required by the licence to submit a contingency plan detailing measures to be undertaken in the event of inadvertent presence of the GM sugarcane lines outside the permitted areas.
|Considers that the broad range of proposed geographic sites may increase the risk of spread and persistence in the environment.||The geographic distribution of the release sites is for the purpose of the lines being assessed under a range of environmental conditions. Importantly, the proposed areas of release are BSES experiment stations, at which managers have long-term experience in undertaking complex field trials and breeding work.|
14GTTAC, State and Territory Governments, Australian Government agencies and the Minister for the Environment, Heritage & the Arts.