Table of Contents Light Regional Council Tuesday, 8 September 2020

TABLE OF CONTENTS for the Special Meeting of LIGHT REGIONAL COUNCIL

TUESDAY, 8 SEPTEMBER 2020

Reports for Decision:

5.1.1 Genetically Modified Crops Moratorium ...... 1 VISION Respecting the Past, Creating our Future.

CORE PRINCIPLES Light Regional Council is guided by a focus on ‘Core Principles’ of Growth; Reform; Innovation and Discipline.

AGENDA PAPERS

for the Special Meeting of

LIGHT REGIONAL COUNCIL

in the COUNCIL CHAMBER 93 Main Street, Kapunda

TUESDAY, 8 SEPTEMBER 2020 at 5:00pm

Principal Office: 93 Main Street Branch Office: 12 Hanson Street Kapunda 5373 Freeling 5372 Telephone: 8525 3200 Facsimile: 8566 3262 NOTICE OF MEETING

Mayor and Councillors,

Notice is hereby given pursuant to the provisions of Section 83 (2) of the Local Government Act, 1999, that Special Meeting of Council will be held in the Council Chamber, 93 Main Street, Kapunda on Tuesday, 8 September 2020 at 5.00pm

A copy of the Agenda for the above meeting is supplied as prescribed by Section 83 (3) of the said Act.

...... Per Brian Carr CHIEF EXECUTIVE OFFICER AGENDA

SPECIAL MEETING OF COUNCIL HELD ON TUESDAY, 8 SEPTEMBER 2020, IN THE COUNCIL CHAMBER, 93 MAIN STREET, KAPUNDA, COMMENCING AT 5.00PM

1. PRESENT 2. OPENING 3. APOLOGIES 4. DEPUTATIONS & PRESENTATIONS 5. REPORTS FOR DECISION 5.1 CHIEF EXECUTIVE OFFICER 5.2 GENERAL MANAGERS, BUSINESS & FINANCE, & GOVERNANCE 5.3 GENERAL MANAGER, STRATEGY & DEVELOPMENT 5.4 GENERAL MANAGER, INFRASTRUCTURE & ENVIRONMENT 5.5. GENERAL MANAGER, ECONOMIC DEVELOPMENT 6. PROCEDURAL MATTERS 6.1 QUESTIONS WITHOUT NOTICE 6.2 QUESTIONS ON NOTICE 6.3 NOTICE OF MOTION 6.4 MOTIONS WITHOUT NOTICE 7. CONFIDENTIAL ITEMS 8. MEETINGS The next ordinary meeting of Light Regional Council will be held on Tuesday, 22 September 2020, commencing at 5:00pm in the Council Chamber, 93 Main Street, Kapunda.

9. CLOSURE Council Agenda Special Meeting of Council – Tuesday, 8 September 2020 2020/1

4. DEPUTATIONS & PRESENTATIONS

5. REPORTS FOR DECISION

5.1 GENERAL MANAGER, STRATEGY & DEVELOPMENT

5.1.1 Genetically Modified Crops Moratorium

Folder ID: 74058

Appendix: 5.1A Summary of Submissions Table

5.1B Survey Summary – 7 September 2020

5.1C Written Submissions

Author: Craig Doyle – General Manager, Strategy & Development

Report Presenter: Craig Doyle – General Manager, Strategy & Development

Executive Summary

Council has conducted consultation pursuant to Section 5A of the Genetically Modified Crops Management Act 2004 to assist in determining whether it is to proceed with an application to the Minister for Primary Industries and Regional Development (the Minister) to remain a Genetically Modified Crop Free (GM-free) council area.

This report provides Council with the outcomes of the community consultation that was conducted between 12 August 2020 and 2 September 2020 to assist Council with determining whether it will make an application to the Minister to remain a GM-free council area

Council received 165 responses to its survey (160 on-line, 5 in hardcopy). The results are presented in Appendix 5.1B.

It is noted that the response from the Barossa Grape and Wine Association indicates that there is a market risk to the Barossa and Australian wine industries reputation if GM crops are allowed.

However, the situation for grain farmers is also compelling, in that removing GM-free status would provide a greater choice in management options, to increase potential production yields and economic return. Further, the desire expressed by several farmers to simply having the choice to use these technologies if they see the need to is also acknowledged.

Given the diversity of the Council area this is a complex process.

The recommendation will either be tabled at the meeting or distributed beforehand.

As noted, any application must be made to the Minister by 30 September 2020. The final decision on the Moratorium remains with the Minister.

Council Agenda Special Meeting of Council – Tuesday, 8 September 2020 2020/2

Budget Impact Estimated Cost: $Undetermined Future ongoing operating costs: $Nil Is this budgeted? No

Recommendation

To be provided separately and will either be tabled at the meeting or distributed beforehand.

Reasons for the decision

To enable Council to consider consultation feedback to inform whether it will apply to the Minister for Primary Industries and Regional Development (the Minister) to remain a non-GM crop area under the Genetically Modified Crops Management Act 2004.

Council Agenda Special Meeting of Council – Tuesday, 8 September 2020 2020/3

Detailed Report

Purpose

This report provides Council with the outcomes of the community consultation that was conducted between 12 August 2020 and 2 September 2020 pursuant to Genetically Modified Crops Management Act 2004 to assist Council with determining whether it will make an application to the Minister for Primary Industries and Regional Development (the Minister) to remain a Genetically Modified Crop Free (GM-free) council area.

Background

At the Council meeting on 28 July 2020, Council resolved as follows:

Item 14.3.1 - Genetically Modified Crops – Notice of Motion by Cr Simon Zeller Moved Cr Zeller Seconded Cr Reichstein That Council: 1. Notes the correspondence received. 2. Pursuant to Section 5A(2) of the Genetically Modified Crops Management Act 2004, will seek the views of its community, including but not limited to persons engaged in primary production activities and food processing or manufacturing activities, regarding whether or not such an application should be made. 3. Will conduct public consultation to be guided by Council’s public consultation policy. 4. Provide a report about the findings of the public consultation to the earliest possible Council meeting for further consideration. CARRIED

Separately, an application must be made to the Minister by 30 September 2020. The final decision on the Moratorium remains with the Minister.

History

• 26 May 2020 – Item 11.4 – Genetically Modified Crops in South Australia

• 28 July 2020 – Item 13.3.1 - Genetically Modified Crops Moratorium

Discussion/Analysis

As per the Council’s Consultation Policy, community consultation included:

• Advertisements placed in the editions of ‘The Leader’ and ‘The Bunyip’ on 12 August 2020;

• 52 letters to businesses understood to be involved in primary production activities and food processing or manufacturing activities;

• Distribution of a link to Council’s website on this matter to 1460 email addresses obtained from the Australian Business Register.

Council Agenda Special Meeting of Council – Tuesday, 8 September 2020 2020/4

In each instance, the public were invited to complete an on-line survey with respect to the Genetically Modified Crops Moratorium.

An option to complete a hard copy of the survey was also made available at Council’s Kapunda Office and at the Freeling Library.

Council’s survey was based upon one used by other councils to provide general consistency in the consultation undertaken with our community and interested parties with respect to this matter.

The survey enabled any interested persons and organisation to identify their interest and position about the Light Regional Council area being kept GM-free.

Individuals and organisations also made written submissions to Council, including:

• Mr. Graham Brookman, The Food Forest – 4 August 2020 and 13 August 2020

• Grain Producers SA – 13 August 2020

• Ms. Janis Stewart – 14 August 2020

• Mr. Malcolm Bubner – 16 August 2020

• Barossa Grape and Wine Association – 18 August 2020

• Ms. Monika Quattrocchi, Monika’s Organics – 20 August 2020

• Ms. Julie Newman – 22 August 2020

• Mr. Jim Carreker, The Louise Barossa Valley – 24 August 2020

• Viterra – 1 September 2020

These are listed in the Summary of Submissions Table (Appendix 5.1A) and attached.

All previous submissions have also been collated as part of the consultation and are included in both the Summary of Submissions Table and submissions in Appendix 5.1B.

Neighbouring Councils

The Adelaide Plains Council resolved not to make an application to the Minister for Adelaide Plains to be declared a GM-free area and did not provide comment as part of our consultation process.

The Barossa Council has authorised staff to apply to the Minister to remain a GM-free council area, with the trade and marketing impacts in its application to be based around the industry responses that it received.

The Town of Gawler has not settled its position and may yet petition the Minister to designate the Town of Gawler as a GM-free area.

Council Agenda Special Meeting of Council – Tuesday, 8 September 2020 2020/5

The Mid Murray Council is also considering this matter at a meeting on 8 September 2020. From a review of the related agenda report, the Mid Murray community responses show 48% supporting GM crops, 40% not supporting GM crops and 12% undecided. Also, for Mid Murray Council, 60% of its primary producer’s support GM crops, 30% do not and 10% are undecided.

In terms of other council areas featuring wine regions:

• The City of Onkaparinga is considering making an application to the Minister;

• Alexandrina Council (and the District Council of Yankalilla) are both considering making an application;

• Wattle Range Council (Coonawarra) is also considering this matter at a meeting on 8 September 2020 and the agenda recommendation is that council does not make an application to remain GM-free.

• Clare and Gilbert Valleys Council chose not to proceed with consultation and will not be making an application.

Survey

Council received 165 responses to its survey (160 on-line, 5 in hardcopy). The results are presented in Appendix 5.1B

Below is a summary of key components of the survey:

• Of the respondents 49.7% are community members, 49.7% are business owners or primary producers and 0.6% association or incorporated organisations;

• For community member respondents, the vast majority (72%) are residents of the area;

• For ‘Business Owner or Primary Producer’, 50% identified as being involved in ‘grain farming’;

• Some 56.5% of respondents indicated that they ‘always’ choose products based on them being labelled as GM-free;

• With respect as to whether there would be a positive or negative trade and marketing impact of allowing GM Crops, 27.71% indicated this is ‘Very likely’ and 10.84% ‘Likely’. Otherwise, 12.05% indicated ‘Unlikely’ and 19.28% ‘Not at all likely’. 1.2% were unsure and 8.43% were ‘neutral’; and

• When asked as to whether Council should make application to the Minister, the overall support was 57.9% (Strongly support and Support) compared to 37.83% for ‘Do not support’ and ‘Strongly do not support’, with the balance ‘Neutral’ or ‘Unsure’.

Council Agenda Special Meeting of Council – Tuesday, 8 September 2020 2020/6

General comments

In the survey response, example comments included:

• Grain farmers in support of removing GM-free status generally noted that GM farming would provide a greater choice in management options, to increase production yields and economic return. It was mentioned that such options could assist with crop survival in changing climate conditions. Several farmers mentioned the importance of simply having the choice to use these technologies if they see the need to.

• Grain farmers opposed to removing GM-free status observed there could be little financial benefit farmers and more to the GM seed supplier/s. It was noted that there could be negative impacts on crop rotations and more overseas market opportunities for GM-free.

• Community members opposed to removing GM-free status raised concerns such as unknown health, environmental and economic (and contamination) risks from GM technologies, and the need for more research. The risk to South Australia’s ‘clean and green’ brand was also mentioned. Risks to bee populations arising from the use of GM technologies were also raised.

Submissions

Of the written submissions received with respect to this matter since May 2020, eleven are in favour of retaining GM-free status and seven are in support of allowing GM crops.

Retain GM-free status Remove GM-free status

Mark Parnell MLC Crop Science Society of South Australia

Ms. Donella Peters - Keep SA GM-free (+ Review Grain Producers SA by Dr. John Paull)

Ms. Cynthia Helbig Mr. Jamie Wilson

NASAA Organic Mr. Chris Butler

Mr. Graham Brookman, The Food Forest Ms. Janis Stewart

Ms. Natasha Schubert Mr. Malcolm Bubner

Ms. Annette Burmeister Viterra

Barossa Grape and Wine Association

Ms. Monika Quattrocchi - Monika’s Organics

Ms. Julie Newman

Mr. Jim Carreker (The Louise, Barossa Valley)

Council Agenda Special Meeting of Council – Tuesday, 8 September 2020 2020/7

Trade and Marketing Impact

As stated in previous reports, the Minister will only consider evidence related to the trade and marketing impact of GM crops. Further background was provided in the report considered by Council with respect to this matter on 28 July 2020.

The written submissions sought to address these impacts in various levels of detail including, Grain Producers SA (GPSA) and the Barossa Grape and Wine Association (BGWA).

GPSA argue that there is no sound trade and marketing basis on which to apply for designation, and that growers should be provided a choice to grow crops that best fit their farming systems. GPSA has recommended that Council not pursue designation, and that any application would have to include information that meets the high threshold criteria set by the Mercardo Report and Anderson Review respectively (which are referenced in the Summary of Submissions Table).

The BGWA supports the retention of the GM-free status for the three councils (Barossa, Light and Mid Murray) that incorporate the Barossa Zone Geographical Indexation (GI), highlighting the potential negative impact on the reputation and leading brand position of the Barossa.

It is noted that the BGWA proposal of applying to preserve the Barossa Zone Geographical Indexation only as a GM-free area is probably unable to be implemented, as per Local Government Association advice in its Explanatory Paper (referred to in the July 2020 report) that any Council application may only relate to the entire area of the Council (and not specific parts).

Conclusion

It is noted that the response from the Barossa Grape and Wine Association indicates that there is a market risk to the Barossa and Australian wine industries reputation if GM crops are allowed.

However, the situation for grain farmers is also compelling, in that removing GM-free status would provide a greater choice in management options, to increase production yields and economic return. Further, the desire expressed by several farmers to simply having the choice to use these technologies if they see the need to is acknowledged.

Given the diversity of the Council area this is a complex process.

The recommendation will either be tabled at the meeting or distributed beforehand.

As noted, any application must be made to the Minister by 30 September 2020. The final decision on the Moratorium remains with the Minister. Council Agenda Special Meeting of Council – Tuesday, 8 September 2020 2020/8

References

Legislation

Genetically Modified Crops Management Act 2004

Genetically Modified Crops Management (Designated Area) Amendment Act 2020

Council Policies

Public Consultation Policy

Strategic Plan

3.1 – Support local agricultural and tourism industries as well as manufacturing and small business

6. PROCEDURAL MATTERS 6.1 QUESTIONS WITHOUT NOTICE Rules per Regulations - • Questions and replies are not entered in the minute book unless expressly required by resolution. • No debate shall be allowed on any question or the reply to any question. • If required by the Mayor, such questions shall be put in writing. • The Mayor may direct that a reply be given at the next meeting.

6.2 QUESTIONS ON NOTICE NIL

6.3 NOTICE OF MOTION 6.4 MOTIONS WITHOUT NOTICE Rules per Regulations • A member may bring forward a motion without notice and if required by the Mayor, put it in writing. • Before addressing the meeting, the member shall state the purpose of the motion. • A member cannot move more than one motion without notice on the same subject at any meeting.

7. CONFIDENTIAL ITEMS

8. NEXT MEETING

9. CLOSURE

Genetically Modified Crops – Summary of Submissions Table # Date Respondent For/ Comments Against 1. 13 May 2020 Crop Science For • Supports the cultivation of GMC in South Australia. (via Mr. Peter Society of • Grocke) South Notes that: Australia, per • The moratorium on GMC has hampered progress of agricultural science in SA and has hindered 23 July 2020 Craig Davis the broader agricultural community. (direct to (President) Council) • The benefits to the SA economy, environment & farmers have proven to be substantial. • Currently consumers, feed lotters and processors can legally import (into SA) and manufacture from 25 July 2020 GM products and these products are widely available on supermarket shelves. Provision of: • After over 30 years of global and Australian GM food and fibre production, the global science has ‘Analysis of proven GM technology is safe. price premiums • GM crops have successfully co-existed with conventional farming systems and identity preserved under the South crops. Australian GM moratorium • The moratorium has placed SA farmers nearly 20 years behind interstate counterparts. (March 2018) – prepared by • The moratorium (and its extension) have seen GM research and studies diminish in SA – which Mercado may also disadvantage consumers and the public at large. • The safety of GMC has been rigorously tested and proven. InfoXpert # 435532 • Certain GMC have the potential to improve health outcomes for consumers. • The use of GMC can assist with managing risks from climate change. • The use of GMC can assist with creating a sustainable future with reduced pesticide application. • The acceptance of GM technology will also ensure farmers have all the available tools to produce food and fibre crops sustainably and competitively through improved yields, reduced farm chemical use, improved fertiliser and greater water use efficiencies. • Research programs will enable GM technologies to be brought to the market.

APPENDIX SPECIAL COUNCIL 5.1A-8SEPTEMBER2020 PAGE 1 AGENDA ITEM SPECIAL COUNCIL 5.1.1 Genetically Modified Crops – Summary of Submissions Table # Date Respondent For/ Comments Against • To date, stringent regulations have led to large multi-nationals as being the main companies that can afford to commercialise and deliver this technology. • Farmers can continue to make personal and business decisions to use or not to use technology or practices, and GM will be no different. • There are protocols for propagation and segregation enabling GMC to be safely and confidently grown together within SA and even on the same farm. • It has been proven that contamination of non-GMC can be avoided by following the guidelines and consumers can buy with confidence. • Market premiums for a non-GMC product may be based on the product itself rather than the region it originates from. 25 July 2020 (refer to attached document) The Mercado Report (March 2018) (provided 25 July 2020) adds: ..This report is the most exhaustive analysis produced to date of the premiums and discounts achieved by farmers in South Australia, covering commodities which contribute approximately 63% of the state’s agricultural economy. The results demonstrate overwhelmingly that the majority of farmers in South Australia do not receive a premium as a result of the (GM) moratorium. The only agricultural commodity with a premium over a comparable market is pork, albeit a very slim premium, and likely based on supply and demand factors as opposed to the moratorium and subsequent marketing opportunities. It is our opinion, supported by economic analysis, that the moratorium in South Australia has not led to enhanced premiums over comparable markets to farmers producing the following commodities: • wheat • barley • canola • wine grapes • wool

APPENDIX SPECIAL COUNCIL 5.1A-8SEPTEMBER2020 PAGE 2 AGENDA ITEM SPECIAL COUNCIL 5.1.1 Genetically Modified Crops – Summary of Submissions Table # Date Respondent For/ Comments Against • cattle • sheep and lamb. There is a slight premium for pork prices in South Australia, however it is not possible to determine whether this is due to the moratorium. Despite GM canola being the only GM crop currently grown in Australia that is likely to be adopted by SA farmers; the additional agricultural commodities were included in this analysis to test the presumption that the GM moratorium provides a premium to other South Australian agricultural commodities. Our analysis demonstrates that the GM moratorium removes the option of utilising innovative agronomic tools, licenced by the Gene Technology Regulator (GTR) as safe, with little in the way of trade and marketing benefit to the majority of agricultural producers in South Australia. • We have found no evidence to suggest that the repeal of the moratorium, and the introduction of GM canola, would lead to any reduction in comparable prices to South Australian farmers. 2. 29 May 2020 The Barossa N/A The position of Light Regional Council sought, as noted. Council

3. 3 June 2020 Primary N/A • Notes that: Industries and • Resources SA The Genetically Modified Crops Management Act 2004 (the Act) provides the power to prohibit (PIRSA) cultivation of genetically modified (GM) food crops and aligns with the national scheme for regulating gene technology which only allows State Governments to regulate GM food crops where there are risks to markets and trade. • Any risks to human health or the environment are managed by the national scheme, which is administered by the Commonwealth Government regulator, the Office of the Gene Technology Regulator. • The Act is therefore limited in its scope and any concerns relating to health or the environment cannot be used as grounds to apply to be a non-GM designated area under the Act. • A GM moratorium under the Act only applies to the cultivation of GM food crops. It does not apply to the sale of processed foods made from GM food crops such as canola oil.

APPENDIX SPECIAL COUNCIL 5.1A-8SEPTEMBER2020 PAGE 3 AGENDA ITEM SPECIAL COUNCIL 5.1.1 Genetically Modified Crops – Summary of Submissions Table # Date Respondent For/ Comments Against • Recent amendments lift the GM moratorium across SA except for Kangaroo Island. There is a time limited opportunity for local councils to apply to the Minister for Primary Industries and Regional Development to be declared an area where no GM food crops may be cultivated. • The decision to lift the GM Moratorium on mainland South Australia follows extensive public consultation and recommendations from an independent review that evaluated the market and trade benefits, or lack thereof, of the GM moratorium to the South Australian economy and agricultural industries. • While local councils can apply to be a non-GM crop cultivation designated area there is no requirement for councils to make such an application. • Section 5A of the Act governs the processes relating to designating council areas and the Minister may make a declaration through a notice in the Government Gazette after he has consulted with the GM Crops Advisory Committee established under the Act. • If Council wishes to make an application it must firstly consult with its community, including persons engaged in primary production activities and food processing or manufacturing activities. • Applications and Ministerial declarations can only occur before Sunday 15 November 2020. • Applications should: • be framed within the scope of the Act i.e. relate to marketing and trade only; • demonstrate the consultation requirements of the Act have been fulfilled; • include advice on all views expressed during consultation (in favour or against declaration) and any evidence provided by the community and/or industry relating to the application; • be submitted by 30 September 2020 to provide the Minister with enough time to fulfil his responsibilities under section 5A of the Act. 4. 10 June 2020 Mark Parnell Against • Writes to advise regarding the changes to the Genetically Modified Crops Management Act 2004 and MLC notes that these changes lift the long-standing moratorium on the cultivation of genetically modified (GM) crops on mainland South Australia. • Notes that the changes provide SA councils with a short window of opportunity to apply to remain a non-GM crop area council area.

APPENDIX SPECIAL COUNCIL 5.1A-8SEPTEMBER2020 PAGE 4 AGENDA ITEM SPECIAL COUNCIL 5.1.1 Genetically Modified Crops – Summary of Submissions Table # Date Respondent For/ Comments Against • Strongly encourages Council to urgently resolve to undertake a consultation process with the community regarding their views on this question. • Notes that the final decision on whether a local council area can remain non-GM crop area will be made by the Minister for Primary Industries. • Notes that under the Act, the Minister will only be considering views and evidence relating to impacts on marketing and trade of allowing GM-crops to be grown in the Council area or remaining non-GM crop area. • Notes that many food businesses want SA to remain non-GM crop area to provide a marketing advantage and point of difference with their competitors. • Encourages Council to assist by proactively investigating existing and potential marketing and trade advantages that could be gained for food-related businesses in its Council area by remaining non-GM crop area. • Notes advice that the Minister will also be looking at implications of a decision to declare a council area non-GM crop area for areas beyond council boundaries. • Suggest that Council may wish to consider a regional approach to this matter, in conjunction with neighbouring councils. • Notes that the Anderson Report which will be referred to by the Minister has been disputed by reputable academics. One such critique is by Dr John Paull from the University of Tasmania entitled A Review of the Independent Review of the South Australian GM Food Crop Moratorium and Fourteen Alternative Findings (provided separately at #7). • Encourages Council to act quickly given applications will be due to the Minister by 30 September 2020. • Notes that this issue is important for all council areas, regardless of whether canola is currently grown. • Notes that this is Council’s only chance to apply to remain non-GM crop area and all future decisions about growing GM crops will be made at a national level with no regard to local economic circumstances.

APPENDIX SPECIAL COUNCIL 5.1A-8SEPTEMBER2020 PAGE 5 AGENDA ITEM SPECIAL COUNCIL 5.1.1 Genetically Modified Crops – Summary of Submissions Table # Date Respondent For/ Comments Against 5. 18 June 2020 Grain For • Notes the changes to the Act. Producers SA • And (GPSA) Advises that Grain Producers SA (GPSA) is the peak industry body for South Australian grain growers, representing the grain industry to government, the community and industry, including grain. 13 August 2020 • GPSA develops and implements policies and projects that promote the economic and environmental sustainability of South Australian grain growing businesses. InfoXpert # 437569 • GPSA has run a longstanding campaign to give growers freedom of choice in their cropping decisions. • The South Australian grain industry is large and diverse, with an estimated primary production value of $2.5 billion. Grain is both a major contributor to the economy and a significant export earner for the state. • There are more than 4,500 grain farm businesses that span the cropping belt in South Australia. • GPSA believes that growers should have the freedom of choice to grow the cereal, legume and oilseed varieties that best fit their farming system, including genetically modified varieties. • Removing the GM food crop moratorium from mainland SA will enable producers to have the same freedom of choice as growers from other mainland states. • The Australian grains industry successfully and safely manages a complex value chain, and self regulates through best‐practice farming systems and processes that effectively manage numerous segregations tailored for various markets. As such, growers’ choice to remain GM‐free on their farm will be retained should the moratorium be lifted. • SA’s predominant grain handler, Viterra, has advised GPSA that “Viterra’s position has always been that we can support the choice to grow GM crops by providing handling and quality management expertise and processes to meet the market requirements of handling and segregating both GM and non‐GM commodities.” • GPSA’s position is about enabling choice for all producers. Enabling grower choice will allow the use of approved GM crop varieties consistent with the remainder of mainland Australian states and provide a commercial incentive to fund research in GM technology in South Australia. • In line with the Act’s trade and marketing scope, GPSA commissioned an independent economic analysis of price premiums under the moratorium in 2017. This analysis concluded that growers did not

APPENDIX SPECIAL COUNCIL 5.1A-8SEPTEMBER2020 PAGE 6 AGENDA ITEM SPECIAL COUNCIL 5.1.1 Genetically Modified Crops – Summary of Submissions Table # Date Respondent For/ Comments Against receive a marketing advantage as a result of SA’s GM‐free status, and that the only effect of moratorium was to deny the use of safe and effective GM tools. • Fact Sheet provided in summary of the above. • Notes that any local government looking to make an application for designation as a GM cultivation‐ free area will have to meet the high threshold set by the findings of these two separate independent economic assessments (GPSA’s and the Anderson Report). • As the peak industry body, GPSA welcomes consultation by Light Regional Council, noting this as an explicit requirement under s5A(2) of the Act before any application is made. 13 August 2020 (refer to attached document) • Welcomes Council’s consultation and notes that Council is not obliged to make an application for designation pursuant to the Act. • Provides a submission in relation to the Act, including background on GM crops, the Regulatory Framework, Trade and Marketing Impacts (referencing the ‘Mercado Study’ and ‘Anderson Review’) and Industry Co-existence. • GPSA advises: “The evidence produced through two separate economic assessments and nearly two decades of successful coexistence between GM, non-GM and organic crops interstate demonstrates that there are no trade and marketing benefits as a result of SA’s GM-free status, and that the removal of restrictions relating to GM crops will not have any adverse trade or marketing impacts in your local government area” 6. 22 June 2020 Keep SA GM- Against Notes that: free (via • Donella Losing South Australia's state-wide GM-free status and reputation for high quality GM-free food Peters) products will disrupt market and trade opportunities for producers and processors all over the state, including this council area. InfoXpert # • Refers to the example of Kangaroo Island remaining GMC free and the benefits of this in terms of 431630 revenue – referencing also the example of Japanese Consumer Cooperatives (‘Palsystem Consumers’

APPENDIX SPECIAL COUNCIL 5.1A-8SEPTEMBER2020 PAGE 7 AGENDA ITEM SPECIAL COUNCIL 5.1.1 Genetically Modified Crops – Summary of Submissions Table # Date Respondent For/ Comments Against Co-operative Union of Japan’ and ‘Japanese Consumer Co-operative, Coop Shizenha’) which procure only non-GM crop area products and the loss of these markets would amount to millions in lost revenue. • Comments that the State Government’s Review (Anderson Review) had a “short term and narrow Terms of Reference. The report was based on shaky assumptions, excluded relevant information, and ignored inconvenient data.” • Notes that Australian non-GM canola has earned premiums in Europe since 2006 and that “GM canola discounts continue to be significant”: • Notes that Council can remain a GM-free Zone and to embrace this process. • Notes that “GM pollen is easily carried on the wind and by bees and will not stop at artificial borders. The more councils that are declared a GM-free Crop Zone, the better the protection for all non-GM and organic producers”. • Asks Council to • consider retaining the Council area as a GM-free zone; • consult all members of our community, “including persons engaged in primary production activities and food processing or manufacturing activities”; • gather evidence of the present and future benefits and costs of remaining GM-free vs the potential benefits and costs of allowing GM crops to be grown in the area (canola and safflower now, but possibly GM wheat, ryegrass, lucerne etc. in the future; • apply to the Minister for Primary Industries and Resources for Council to remain a GM-free Crop Zone • refute the Anderson report findings on which the government's GM policy is based, in the application, and make the case for the council to remain a GM-free Crop Zone: • give an overview of positive feedback, submissions and evidence that led to council's decision to advocate for a GM-free Crop Zone; • show a marketing advantage for primary producers, food producers and manufacturers from remaining a GM-free Crop Zone;

APPENDIX SPECIAL COUNCIL 5.1A-8SEPTEMBER2020 PAGE 8 AGENDA ITEM SPECIAL COUNCIL 5.1.1 Genetically Modified Crops – Summary of Submissions Table # Date Respondent For/ Comments Against • provide evidence of positive marketing or trade impacts on local businesses from remaining a GM-free Crop Zone. • Advises that there are many compelling health and environmental reasons to avoid GM crops, but the only reason the Minister will designate an area as a GM-free Crop Zone is to preserve the identity of crops (GM and non-GM) for marketing purposes. Attaches a copy of the report from Dr. John Paull (included separately at #7). 7. 22 June 2020 Dr John Paull Against Submission Title: (via ‘Keep SA A Review of the Independent Review of the South Australian GM Food Crop Moratorium and Fourteen GM-free) Alternative Findings’

25 June 2020 This submission to the GM Moratorium Report Consultation provides 14 Findings in contrast to the State (via Cr. Zeller) Government’s own commissioned Review, summarised as follows:

1. The Independent Review contains errors and is not independent as it was written by an advocate of 10 July 2020 (via Mr. Graham GMOs and GM-crops. Brookman) 2. The majority (78%) of submissions support retaining the existing SA GM Moratorium and the “Independent Review falsely reports the contrary.” 3. Australian supermarkets do not stock GM-foods because they are aware that Australian consumers have rejected such ‘Frankenfoods’. 4. SA enjoys a clean and green and smart image which is important for tourism, trade, investment, education and migration and is supported by the GM Moratorium, the loss of which would undermine that image and its economic benefits. 5. Around the world, there is strong consumer sentiment against GMO food and economic price penalties for growing GM Crops. 6. There is a price penalty for growing GM crops (average price penalty for GM canola in WA is 7.2%). 7. GM agriculture is concentrated in just three countries, USA, Brazil and Argentina. Australia is a very minor player in the world of GM agriculture. 8. Segregation of GM and non-GM canola has failed in WA. Non-GM has been redefined as ‘GM- contaminated to an extent not exceeding 0.9%’ as a result.

APPENDIX SPECIAL COUNCIL 5.1A-8SEPTEMBER2020 PAGE 9 AGENDA ITEM SPECIAL COUNCIL 5.1.1 Genetically Modified Crops – Summary of Submissions Table # Date Respondent For/ Comments Against 9. GM RR canola is glyphosate dependent. Glyphosate is carcinogenic, leading to more health costs for SA. Contaminated products (beer and wine) can have negative economic consequences and damage exports. Glyphosate lawsuits can be an economic drain on the SA economy. 10. Around the world, there is strong consumer sentiment for organic food (and against GM food) and economic rewards for providing this. 11. Australia is the world leader in organic agriculture and accounts for 51% of the world’s certified organic hectares. GMOs put organics at existential and economic risk. 12. Organic agriculture in Australia is growing at 22% per annum. Allowing GMOs puts organics at risk. 13. South Australia leads the country in organic agriculture (based on certified organic hectares). Allowing GMOs in SA places a price premium for organic produce at risk. There is no social licence for GMOs. The SA GM Moratorium warrants being maintained for its social, environmental, health, education, trade and economic benefits. 8. 2 July 2020 Ms. Cynthia Against • Asks that Council does everything it can to ensure that LRC remains a GM-free Crop Zone, as “losing Helbig our region’s GM-free status, and reputation for high-quality GM-free foods and beverages, will disrupt markets and deny us trade benefits” InfoXpert # • 433046 Requests that Council “embrace and promote the GM-free Crop Zone review process” and asks that Council resolves to consider this matter, consult with the community and apply to the Minister for Primary Industries and Resources to remain a GM-free Crop Zone. • Notes that GM-free is an important part of SA’s enviable reputation for high-quality fresh produce.

APPENDIX SPECIAL COUNCIL 5.1A-8SEPTEMBER2020 PAGE 10 AGENDA ITEM SPECIAL COUNCIL 5.1.1 Genetically Modified Crops – Summary of Submissions Table # Date Respondent For/ Comments Against • Notes that all SA councils standing together will provide a stronger voice to ensure the SA landscape remains non-GM crop area, while securing future benefits for many SA communities. • Asks Council to resolve to: • consider retaining the Council area as a GMC free zone; • consult all members of your community, “including persons engaged in primary production activities and food processing or manufacturing activities”; • gather evidence of the present and future benefits and costs of remaining GMC free vs the potential benefits and costs of allowing GM crops to be grown; • show a marketing advantage for primary producers, food producers, manufacturers and the community from remaining GMC-free; • provide evidence of positive marketing or trade benefits for local businesses from remaining a GMC free zone. • Notes GMC free (moratorium) benefits, including: • substantial price premiums and preferential market access; • lower production costs, without segregation and identity preservation being needed; • no recalls or market disruptions from GM contamination, as US wheat and Lucerne caused; • domestic and export market reputations for high quality non-GM products. • Notes that in contrast, adopting GM crops like canola would have marginal, unquantified, and speculative benefits. • Refers to the example of Kangaroo Island remaining GMC free and the benefits of this – referencing also the example of Japanese Consumer Cooperatives (‘Palsystem Consumers’ Co-operative Union of Japan’ and ‘Japanese Consumer Co-operative, Coop Shizenha’) which supply only non-GM crop area products. • Comments that the State Government’s Review (Anderson Review) had a “short term and narrow Terms of Reference, so the report made shaky assumptions, excluded relevant information, and ignored unfavourable data.”

APPENDIX SPECIAL COUNCIL 5.1A-8SEPTEMBER2020 PAGE 11 AGENDA ITEM SPECIAL COUNCIL 5.1.1 Genetically Modified Crops – Summary of Submissions Table # Date Respondent For/ Comments Against • Notes reports that Australian non-GM canola has earned premiums in Europe since 2006; • Comments that in the week ending June 5, 2020, GM canola was discounted $95/tonne in WA (compared with non-GM varieties), $39/tonne in Port Melbourne, and up to $39/tonne in rural NSW. • Notes that consumers don’t want GM foods and Coles and Woolworths branded products don’t use GM ingredients accordingly. • Notes non-GM crop area labelled products are now amongst the fastest growing markets. • Notes that lifting the ban could negatively impact on wheat markets and trade. 10. 10 July 2020 Mr. Graham Against • Mr. Brookman has provided number of attachments to his submission as follows: Brookman – • 4 August 2020 The Food Attachment # 1 – ‘Some Premiums for Non-GM Crop’ (Memo to Mayor Forest • Attachment # 2 – ‘2020 Gross Farm Margin and Enterprise Planning Guide’ (PIRSA) which can be and CEO) accessed here

InfoXpert # • Attachment #3 – ‘Relative yield and profit of Australian hybrid compared with open-pollinated canola 436685 is largely determined by growing-season rainfall’ – CSIRO Publishing – provided to Elected Members under separate cover. Unable to be included in the Agenda as it is subject to copyright, but can be purchased here 13 August 2020 • Attachment #4 – ‘Summary of market from Tasmanian GM review 2019’ Re: Rabobank • Attachment #5 – ‘Identification and Assessment of Added-Value Export Market Opportunities for Non-GMO Labelled Food Products from South Australia’ – University of Adelaide, Centre for Global Food and Resources, prepared for PIRSA, which can be accessed here • Attachment #6 – ‘A Review of the Independent Review of the South Australian GM Food Crop Moratorium and Fourteen Alternative Findings’ – Dr. John Paull – provided in this Agenda at Appendix 13.3F • Attachment #7 – ‘The cost of GM contamination’ • Attachment #8 – ‘Genetically modified crop unknowingly planted by SA farmer in state with strict ban’ (ABC News - also accessible here)

APPENDIX SPECIAL COUNCIL 5.1A-8SEPTEMBER2020 PAGE 12 AGENDA ITEM SPECIAL COUNCIL 5.1.1 Genetically Modified Crops – Summary of Submissions Table # Date Respondent For/ Comments Against • Attachment #9 (& #10) – Memo to Light Council – Mr. G. Brookman • Notes that his property shares a boundary with Light Regional Council. • Mr. Brookman has a real interest in Council's response to its opportunity to apply to the Minister to become a GMC-free area. • Notes that the issues warrant public discussion in the interests of the prosperity of the Council area. • Provides evidence that Council will be advantaged in trade and marketing by applying for and being granted the right to become a GMC free area. • Cites: • Data in PIRSA’s 2020 Gross Margins and Enterprise Planning Guide that GM Canola is significantly less profitable (gross margins over 5 years of data) than naturally bred cultivars, right across SA. • Data presented in the Anderson Report commissioned by the State Government showing the higher profitability of GM canola was questioned in a paper from the Journal of Pasture Science 2016 (specifically about SA cropping areas) which showed that open pollinated canola was more profitable in lower rainfall areas. • Data within the Anderson Report confirmed that farmers growing non-GM canola were receiving a substantial premium for non-GM canola on Kangaroo Island. • Market reports for the sale of canola from Australian ports show that non-GM canola provides constant premia over GM canola sometimes rising to almost $100 per tonne. • Notes that food businesses wanting to produce non-GM products will find ingredients more difficult to obtain or more expensive if GM is adopted more widely; on the other hand, they will have more market access if they remain non-GM. • Refers to date from world markets confirming that the market for non-GM Crops is growing rapidly (>17%). • Refers to surveys of populations worldwide show that most people do not want to consume GM food or beverages – citing CSIRO showed only 7% of shoppers 'were unconcerned' about eating GM food. • Notes that:

APPENDIX SPECIAL COUNCIL 5.1A-8SEPTEMBER2020 PAGE 13 AGENDA ITEM SPECIAL COUNCIL 5.1.1 Genetically Modified Crops – Summary of Submissions Table # Date Respondent For/ Comments Against • Key users of grain in Australia will not use GM grain in their value adding processes. • The segregation of GM crops from non-GM crops has been shown to fail regularly overseas and in Australia. The Independent Parliamentary review of the release of GM crop cultivars into the environment pointed out more than 20 failures and obstacles in the regulation of GM crops. • The multi-million-dollar non-GM/Organic SA beef export market could be compromised by GM 'contamination' (not to mention other meat, milk and grain crops) as livestock eating GM feed are disqualified from certified non-GM status domestically and in some export markets. • More GM cultivars including cereals are planned for release into the environment, potentially threatening the status of South Australia's beer, pasta, biscuits, flour and stockfeed. • The term 'GM Crops' is broad and could lead to losses of potential markets and premia for many crop types (including horticultural crops). • The loss of SA's overall clean, green image and the difficulty of assuring patrons of shops, restaurants and wineries that food is free of GM ingredients will likely cause higher costs and a lack of confidence from potential tourists. • Most consumers of wine are unaware of the wine industry's self-imposed ban on GM inputs and need to be advised that wine comes from non-GM areas as well as excluding GM yeasts, which can be viewed as a market advantage to a branded non-GM region. • Buyers of SA products may well demand independent certification of non-GM status if the bulk of the State is GM, placing additional costs on the producer. • Organic farmers with neighbours growing GM may lose certification of all or part of their crops due to the proximity of GM crops. • There is no legislation to handle problems caused by the commercial incompatibility of GM and non-GM crops. • Genetic modification is an inexact science and there can be unintended outcomes and consequences. • Government research investment has been redirected from natural plant breeding programs in the pursuit of engineered plants that are resistant to pests , diseases or herbicides through GM;

APPENDIX SPECIAL COUNCIL 5.1A-8SEPTEMBER2020 PAGE 14 AGENDA ITEM SPECIAL COUNCIL 5.1.1 Genetically Modified Crops – Summary of Submissions Table # Date Respondent For/ Comments Against however weeds, pathogens and insects can adapt to the ‘blocking’ mechanisms used (example of ‘Roundup’ resistance). • Farmers are required to pay high prices for the seed of GM cultivars that have specific resistances or other qualities, but the base cultivar that was chosen and modified is often maladapted to the specific environmental conditions in which a farmer is growing the crop. • Farmers are also required to sign and pay for 'technology agreements' through which they are locked into using certain herbicides from which the seed supplier is directly profiting. These costs eat into the gross margins (profitability) of GM crops. The keeping or sale of seed for planting is forbidden and aggressively enforced. Farmers are taken to court for breaches, both systematic and accidental. • Some GM seed companies (e.g. NuSeed) currently pay farmers a bounty on each tonne of grain produced to artificially make up for the lower profitability of crops grown using their seed. Such 'promo' bounties can be withdrawn at any time. • The above points do not consider the proven negative impacts of GM crops on: • human and animal health; • effects on the environment including soil biology and water resources (including potable water). • Points out that a good website for basic research into the advantages of being a non-GM area is https://non-gmoreport.com • Mr. Brookman: • has provided attachments and is happy to provide further resources demonstrating the potential future losses that would be caused by Council remaining in the GM zone; • mentions his membership of a group that is concerned about the GM situation that comprises a range of professionals including several experts in the field of genetics; • notes that the Minister has commented that it would be logical for adjacent councils to communicate about this matter and his understanding that Gawler, Barossa, Playford, Adelaide Hills and Onkaparinga Councils will be consulting with their communities and his hope that LRC will do the same;

APPENDIX SPECIAL COUNCIL 5.1A-8SEPTEMBER2020 PAGE 15 AGENDA ITEM SPECIAL COUNCIL 5.1.1 Genetically Modified Crops – Summary of Submissions Table # Date Respondent For/ Comments Against • offers to provide additional information as required and to address Council if desired. Memo to Mayor and CEO – 4 August 2020 refer to attached document (n.b. only additional content noted below) • Notes the process for Councils to apply to the Minister (and his consideration) as well as noting that a council would need a 'cogent basis' for not consulting with its community on the GM issue. • Notes that SA farmers could have lost $17M if they had all grown GM canola last year – due to GM varieties' poorer yields and the penalty applied to GM varieties by the grain market. • Refers to daily prices on grain markets showing certified Non-GM canola is commanding a premium of 12-19% over GM canola. • Notes that GM seed comes with agreements to use specific herbicides and charges for technology and stewardship agreements and a royalty on grain produced; all affecting a farmer’s income. • Notes that Kangaroo Island farmers are already receiving even higher contracted premiums for their Non-GM canola ($100 per tonne i.e. 19%) and for other grains and honey grown in a Non-GM environment. • Advises that the University of Adelaide report (Attachment #5) “gives a realistic picture of future world market opportunities in which SA can play a part as one of the world's largest Non-GM land areas, including over 10 million hectares of certified organic land with farms in all regions of the State.” • Advises the following with respect to ‘Organic production nodes’ in South Australia • The $900M meat industry in SA is underpinned by the massive beef and sheep stations in the outback whose products are naturally GM free; • SA has a $7.6B tourist industry largely based on fine food and wine. 49% of tourists in SA associate the State with food and wine. Culinary tourists outlay significant expenditure on food and wine experiences; • The Eco-tourism (and ‘organic tourism’) market is growing rapidly and relates strongly to natural food experiences. Councils having a commitment to non-GM food will not be lost on tourists; • Large areas of non-GM land will reduce potential GM cultivar contamination (through transport, wind, and insect pollination, transfer via mulch and animal feed);

APPENDIX SPECIAL COUNCIL 5.1A-8SEPTEMBER2020 PAGE 16 AGENDA ITEM SPECIAL COUNCIL 5.1.1 Genetically Modified Crops – Summary of Submissions Table # Date Respondent For/ Comments Against • GM contamination is a risk to the wine industry, which has specifically banned GM vine varieties and yeasts to avoid market damage; • Most consumers enjoying a dining experience would appreciate an assurance food and wine is badged Non-GM; • Property values in non-GM areas “will comparatively rise in comparison with GM areas” (Tasmania example); • Local food producers/ businesses can benefit from association with a non-GM area and visiting a GM-free region can be a tourist attraction; • Events (including Farmers Markets and others) bring visitors and should be protected from GM intrusion; • Allowing GM would likely cause higher costs and a lack of confidence in potential tourists; • Organic growers may lose certification due to the proximity of GM crops. • Some export markets now require proof of non-GM – an extra cost for producers; • Weeds, pathogens and insects can adapt to genetic modifications that are applied; • Food businesses will find non-GM products harder to source if GM is adopted more widely • Key producers will not use GM grain in their value adding processes e.g. San Remo, brewing companies etc • There are international examples of ‘non-GM’ areas (Spain, California, Belgium etc.) indicating it is achievable • Notes that there are “serious question marks” over the Anderson and Mercado reports “which are regarded by most as political documents commissioned by the Government specifically to sell GM to the public and vanquish the calls for caution from medical scientists, grain market professionals, graziers, winemakers, food processors and environmental scientists.” • Notes that the conclusions reached “are demonstrably wrong using the daily Canola price information available publicly and the PIRSA Farm Gross Margins publication”.

APPENDIX SPECIAL COUNCIL 5.1A-8SEPTEMBER2020 PAGE 17 AGENDA ITEM SPECIAL COUNCIL 5.1.1 Genetically Modified Crops – Summary of Submissions Table # Date Respondent For/ Comments Against • Advises that Kangaroo Island was granted non-GM status based on advantages to trade and marketing (and attaches the ‘Kangaroo Island Pure Grain’ letter showing how its request was presented). • Concludes by advising Given that becoming designated as Non-GM Crop area is a once-only opportunity and that there are clearly large trade and market risks for the councils embracing GM (and no quantifiable gains), it seems prudent for your council to apply for Non GM status by the end of September The concept of regions becoming Non-GM, with adjacent councils collaborating to form viable zones, will be considered by the government 13 August 2020 (refer to attached document) • Notes that Rabobank had released a report confirming that non-GM Canola remains a preferred import into Europe. 11. 22 July 2020 Jamie Wilson For • Notes the changes to the GMCM Act. • Advises that he is an experienced agronomist working in the LRC area and has studied plant science. • Advises that GM crops are administered federally by the Office of Gene Technology Regulator (OGTR) and Food Standards Australia and New Zealand (FSANZ). Further, prior to commercial release all GM crops must undertake onerous safety testing by both federal bodies. To date since GM crops have been produced in Australia there has been no adverse effects in 25 years in Australia and 30 years globally. • Notes that there will be strong opposition from the organic industry, but it could be argued that the introduction of GM crops would increase the value of the organic produce if the market is prepared to pay and would allow a marketing difference for that niche portion of the market, increasing the value of this sector. • Notes that these sectors have continued to be viable in every other state where GM crops are grown and have successfully co-existed. As both industries use different supply chains for their markets the management of identity preservation is easily managed. • The delay in allowing GM technology in South Australia has seen a reduction in agricultural research in SA and a transfer of scientists to the eastern states at immeasurable cost. An independent report

APPENDIX SPECIAL COUNCIL 5.1A-8SEPTEMBER2020 PAGE 18 AGENDA ITEM SPECIAL COUNCIL 5.1.1 Genetically Modified Crops – Summary of Submissions Table # Date Respondent For/ Comments Against has shown that the lack of GM technology for SA has cost the industry approximately $33M (refer here). • GM technology is rapidly changing and there are a range of GM uses currently undergoing infield testing for performance and regulatory approval (e.g. drought and frost, salinity tolerance, bio- fortification). • GM plant-based vaccines are also being tested, including increased Omega oils in safflower and canola, algae for biofuel and plastics, tree crops such as eucalyptus and poplar trees. Currently under development and commercialisation are GM yeasts for wine and beer production, GM pastures for livestock production and GM wheat with improved water use efficiency. • Commercially GM traits include: • Abiotic Stress Tolerance • Altered Growth/Yield • Disease Resistance • Herbicide Tolerance • Insect Resistance • Modified Product Quality • Pollination Control System • GM crops have been globally increasing in area since their introduction. Being introduced in 1996 and 1.7 million hectares to 2018 global production reaching 191.7 million hectares. This indicates several key points: 1) Economic return – if there was not an economic return farmers wouldn’t be growing; 2) Market Acceptance – if markets didn’t accept GM crops there would be no market available for the produce. • Many countries including Australia’s trading partners have GM crops registered and have GM crop production. The European Union and China both accept GM crops and China has a range of crops in production. Many other Asian countries also produce and accept GM crops and are a very important

APPENDIX SPECIAL COUNCIL 5.1A-8SEPTEMBER2020 PAGE 19 AGENDA ITEM SPECIAL COUNCIL 5.1.1 Genetically Modified Crops – Summary of Submissions Table # Date Respondent For/ Comments Against part of food security for developing countries shown at https://www.isaaa.org/resources/publications/pocketk/16/ • The consultation process undertaken in South Australia showed a majority support to produce GM crops in South Australia. • Mr Wilson fully supports the introduction of GM crops in South Australia and requests that Council supports the propagation of GM crops in its region. 12. 23 July 2020 Ms. Natasha Against • Asks that Council does everything it can to ensure that LRC remains a GM-free Crop Zone, as “losing Schubert our region’s GM-free status, and reputation for high-quality GM-free foods and beverages, will disrupt markets and deny us trade benefits” InfoXpert # • 435348 Requests that Council “embrace and promote the GM-free Crop Zone review process” and asks that Council resolves to consider this matter, consult with the community and apply to the Minister for Primary Industries and Resources to remain a GM-free Crop Zone. • Notes that GM-free is an important part of SA’s enviable reputation for high-quality fresh produce.

• Notes that a wide range of industries rely upon SA’s clean, green image to market products at a premium, with the loss of the GM crop moratorium risking that image and the benefits it provides • Notes that consumers are not comfortable with foods and beverages with GM ingredients. • Notes the opportunity to remain GM-free like Kangaroo Island, preserving its market premiums. 13. 23 July 2020 Mr. Chris For • Notes that in the 2019 season, farmers managed to produce approx. 14kg of cereal grain per millimetre Butler – a remarkable feat based upon the use of modern technologies and techniques; Roseworthy • Rural Supplies Notes that he would like his clients to be able to grow GM Safflower as is done in Victoria. This offers P/L a choice as a break crop for weed/ disease management and a sustainable choice as a speciality industrial oil can be produced from this for commercial use. InfoXpert # • Other GM crops can potentially provide alternatives and give relief to pressures on other industries 435378 (‘long-chain omega-3 producing canola mentioned as an alternative to sardines mentioned as an example). • Is not as supportive of ‘Round-up Ready’ ® GM Canola but notes that there is a place for such products in the farming system.

APPENDIX SPECIAL COUNCIL 5.1A-8SEPTEMBER2020 PAGE 20 AGENDA ITEM SPECIAL COUNCIL 5.1.1 Genetically Modified Crops – Summary of Submissions Table # Date Respondent For/ Comments Against • Notes that a “recent study conducted by Mercado® has proven the oft quoted “positive economic impacts” of a non-GM production status in this state is unfounded. This supports a multitude of global studies that have been undertaken since the commercial release of the first GM crops over 30 years ago.” • Notes that Viterra receival sites interstate already handle segregation between GM and Non-GM crops without problems being reported, however acknowledges that due care is needed. • Notes that with planning for next year’s season, there is a need to be aware of what GM crops will be on offer to the farmers of SA • Note that GM crops have “shown great social and health benefits in the rest of the world” and that it seems that allowing “allowing GM crop production in SA will bring 99+% positives and 1-% negatives.” 14. 29 July 2020 Ms. Annette Against • Asks that Council does everything it can to ensure that LRC remains a GM-free Crop Zone, as “losing Burmeister our region’s GM-free status, and reputation for high-quality GM-free foods and beverages, will disrupt markets and deny us trade benefits” InfoXpert # • 435967 Requests that Council “embrace and promote the GM-free Crop Zone review process” and asks that Council resolves to consider this matter, consult with the community and apply to the Minister for Primary Industries and Resources to remain a GM-free Crop Zone. • Notes that GM-free is an important part of SA’s enviable reputation for high-quality fresh produce. • Notes that a wide range of industries rely upon SA’s clean, green image to market products at a premium, with the loss of the GM crop moratorium risking that image and the benefits it provides • Notes that consumers are not comfortable with foods and beverages with GM ingredients. • Notes the opportunity to remain GM-free like Kangaroo Island, preserving its market premiums. Additional submissions received during the public consultation period – 12 August 2020 to 2 September 2020 15. 14 August 2020 Ms. Janis For • Supports the farming community and their right to use GM technology. Stewart

InfoXpert # 437707

APPENDIX SPECIAL COUNCIL 5.1A-8SEPTEMBER2020 PAGE 21 AGENDA ITEM SPECIAL COUNCIL 5.1.1 Genetically Modified Crops – Summary of Submissions Table # Date Respondent For/ Comments Against 16. 16 August 2020 Mr. Malcolm For • Mr. Bubner is a farmer in the LRC area and supports access to GM technology to ensure continued Bubner advancement of viable agriculture in the current uncertain times and into the future.

InfoXpert # 437854

17. 18 August 2020 Barossa Against • BGWA supports maintaining the existing moratorium to September 2025. Grape and • Wine BGWA requests that the Local Government Areas featuring a part of the Barossa Geographical Association Indication (GI), being The Barossa Council, Mid Murray Council and Light Regional Council apply the (BGWA) Minister for Primary Industries and Regional Development for the Barossa GI to remain ‘GM Free’. (Mr. James • The BGWA bases this on an evidence-based commercial position: March) • Allowing GM-Crops could have a potential negative impact on the reputation and leading brand position of the Barossa and state wine industry • Community/ industry acceptance should be a driver of any significant change • Potential additional costs and complexity (to traceability and labelling requirements) within the Barossa wine industry’s major export markets • The risks of cross-contamination from GM materials • Stakeholders require a purpose-built program to deliver a change in GM status addressing the practicalities and market concerns • With drought and COVID-19, it is a fragile time to introduce any changes which may have additional costs for businesses or brand position • In its submission, BGWA notes: • Currently, the Australian wine industry is no permitted to use GM material (either vines or microorganisms) in its production processes. No materials, additives or production aids used in the production of wine are approved by the Office of Gene Technology Regulator for commercial use in Australia;

APPENDIX SPECIAL COUNCIL 5.1A-8SEPTEMBER2020 PAGE 22 AGENDA ITEM SPECIAL COUNCIL 5.1.1 Genetically Modified Crops – Summary of Submissions Table # Date Respondent For/ Comments Against • SA’s grape and wine industries represent $2.28B as well as supporting additional gains via tourism. Allowing GM crops risks SA’s GM-free marketing advantage for a $116.1M crop; • That GM is a risk to the Barossa/ Australian wine industry’s international reputation; • Seed drift from GM crops could become pest plants in vineyards; • Such seed drift could present a risk to accreditation for some businesses; • The PIRSA Gross Margins and Enterprise Planning Guide indicates that GM Canola is significantly less profitable than naturally bred cultivars; • Enabling GM crops will unnecessarily place SA and the Barossa in a disadvantageous position in key overlapping export markets with GM-free producing countries and Australian states; • Consumers of premium goods, such as in China and the USA, value products with natural ingredients, no additives and organic certifications • The BGWA acknowledges that GM grapevine planting material could potentially have advantages for the wine industry in the future. Balancing the position will need an understanding and response to market driven factors international markets at that time. • The BGWA encourages Council to consider maintaining the moratorium. 18. 20 August 2020 Monika’s Against • Certified organic grower of vegetables and a wholesaler and distributer with 21 years’ experience and Organics employs 18 staff (Monika • Quattrocchi)) Leading certified organic operator supplying supermarkets in SA, WA, Northern Territory and Victoria. • There is a year on year increase in consumer demand for clean, natural foods. InfoXpert # 438354 • Demand for organic food is increasing. • Allowing GM crops will take away SA’s point of difference and competitive advantage. • GM products are unpopular with consumers. • The USA has some much GM contamination that its organic industry has been forced to set levels of allowable contamination.

APPENDIX SPECIAL COUNCIL 5.1A-8SEPTEMBER2020 PAGE 23 AGENDA ITEM SPECIAL COUNCIL 5.1.1 Genetically Modified Crops – Summary of Submissions Table # Date Respondent For/ Comments Against • GM crops can have unintended side-effects in the environment. • GM crops are patented and controlled by multi-national companies. • Little is understood about the health impacts of GM crops. • Asks that Council applies to the State Government to remain a GM-free area. 19. 22 August 2020 Julie Newman Against • The drive for GM crops does not come from farmers, but the plant breeding sector wishing to profit internationally. InfoXpert # • 438704 Provides a copy of a report prepared by the West Australian government ‘’Delivering market choice with GM canola” • Notes that there is risk that GM wheat could be introduced, whereas other countries refuse to accept the economic risks attached to this. • Notes that the introduction of GM has achieved very little. • Yields have not improved and, in some cases, have been lower. • There are additional costs attached to using GM (high seed costs, royalties, extra chemicals, storage and handling restrictions, training time, contracts). • The Anderson Review relied upon by the State Government was flawed. • The Grains Research and Development Corporation (GRDC) is funded by farming industry contributions, however GM plant breeders have seemed to benefit. 20. 24 August 2020 Mr. Jim Against • Owns the Appellation restaurant, the Louise accommodation and three75 bar and kitchen a 375 Carreker Seppeltsfield Road, Marananga. The Louise • Barossa Valley Has observed the growing appeal of the Barossa area for interstate and international visitors, who travel here in order to experience the unique wine and food culinary offerings brought to market by local businesses. • In 2019, more than 48% of the guests of the Louise came from locations outside Australia.

APPENDIX SPECIAL COUNCIL 5.1A-8SEPTEMBER2020 PAGE 24 AGENDA ITEM SPECIAL COUNCIL 5.1.1 Genetically Modified Crops – Summary of Submissions Table # Date Respondent For/ Comments Against • The belief is that such visitors are drawn by the reputation of the Barossa brand and its hard-earned reputation for its attributes of purity, quality and integrity. Included in these attributes is crop-raising practices that minimise chemical and the moratorium on GM products. • Introducing GM would lose these attributes forever, diminishing the market-appeal of the Barossa brand. • The opportunity to block GM farming practice is of substantial economic importance to the future of the vibrant tourism industry in our region and LRC is encouraged to apply to the Minister to remain GM- free. 21. 1 September Viterra N/A • Where GM crops are permitted, Viterra will support the choice of growers to grow GM crops through 2020 its storage facilities and will meet market requirements to safely handle and segregate both GM and InfoXpert # non-GM commodities. 439703

Survey Attachments 4 August 2020 - Memo to Mayor and CEO – Mr. Graham Brookman – The Food Forest - Refer to Item #10 in the Summary of Submissions Table

The Independent Review of the South Australian GM Food Crop Moratorium prepared by Kym Anderson (Emeritus Professor, School of Economics, University of Adelaide – March 2019), which is accessible here Draft Report on Regulation of Agriculture by Australian Productivity Commission - by Julie Newman, National Spokesperson for the Network of Concerned Farmers this document is accessible here Crop Science Society of South Australia, per Craig Davis (President) - Refer to Item #1 in the Summary of Submissions Table GMO Myths and Truths (2nd edition) by ‘earthopensource’ – provided to Council separately (as this document requires registration to access on-line) Benefits to vignerons winemakers from a GM-free Crop Zone - Mr. Graham Brookman – The Food Forest - provided to Elected Members under separate cover Widely Used Crop Herbicide is Losing Weed Resistance – New York Times – accessible here

APPENDIX SPECIAL COUNCIL 5.1A-8SEPTEMBER2020 PAGE 25 AGENDA ITEM SPECIAL COUNCIL 5.1.1 Business Owner or Business Owner or LRC Resident Responses Primary Producer in LRC Primary Producer area outside of LRC area

Daveyston 1 Business Activity Freeling 8 Gawler Belt 2 Agriculture Support Services 3 0 Greenock 3 Beverage manufacturing (other than wine) 1 0 Hewett 5 Grain farming 38 3 Kapunda 22 Grain mill and cereal product manufacturing 1 1 Marananga 2 Grape growing 7 1 Moppa 2 Livestock farming (other than dairy) 1 0 Pinkerton Plains 1 Other food or beverage product manufacturing (not 2 0 Roseworthy 8 specified above) Other plant or crop growing (not specified above) 2 0 Seppeltsfield 1 Supermarket and grocery stores 0 1 Stonewall 2

Wine making 4 0 Tamma 1

Not specified (blank) 16 Wasleys 1

Total 75 6 59

Likelihood of trade and marketing impacts on business Business Owner or Business Owner or Association or Total %age from GM crops being allowed in the Light Regional Primary Producer in LRC Primary Producer incorporation Council area (positive or negative) area outside of LRC area representing members

Very likely 18 4 1 23 27.71 Likely 8 1 9 10.84 Neutral 7 7 8.43 Unlikely 10 10 12.05 Not at all likely 15 1 16 19.28 Unsure 1 1 1.20 No response (blank) 16 1 17 20.48 Total 75 7 1 83 100.00

Based only on trade and marketing implications, Business Owner or Business Owner or Association or Total Percentage (using suppoort for Council to apply to the Minister for Primary Primary Producer in LRC Primary Producer incorporation Community Members 'less blank Industries and Regional Development, asking that the area outside of LRC area representing members LRC Resident LRC property owner Works in LRC area Visitor to LRC area Blank responses' Totals) Light Regional Council is designated as a non-GM crop that lives elsewhere area

Strongly support 22 4 40 1 2 6 75 53.6 Support 5 1 6 4.3 Neutral 1 4 5 3.6 Do not support 7 2 9 6.43 Strongly do not support 28 2 1 7 1 1 4 44 31.4 Unsure 1 1 0.7 Blank responses 16 1 1 1 2 3 1 0.0 (Sub total) 75 7 1 59 3 5 14 1 165 %age 45.5 4.2 0.6 35.8 1.8 3.0 8.5 0.6 100.0 100.0

Less 'blank' responses = Total 59 6 1 58 2 3 11 0 140 %age 42.1 4.3 0.7 41.4 1.4 2.1 7.9 0.0 100.0

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P.M.B. No.1 GLEN OSMOND SA 5064, AUSTRALIA Craig Doyle General Manager - Strategy & Development Light Regional Council PO Box 72 KAPUNDA SA 5373 (08)85253200 [email protected]

Genetically modified (GM or GMO) tools are a benefit to grain growers – why disadvantage them?

To Craig,

Your council is currently considering whether to apply to the Primary Industries Minister to impose a GMO moratorium in your region.

Please find this letter in support of the cultivation of genetically modified crops in South Australia, and that to deny farmer's access of these tools is a clear message that you do not trust science, including that behind GMO's.

The moratorium on the cultivation of genetically modified crops has hampered progress of Agricultural science in this state, and the flow on effect has hindered the broader agricultural community. More specifically, the benefits to the SA economy, environment & farmers through the cultivation of Genetically Modified (GM) technology have proven to be substantial.

Currently consumers, feedlotters and processors can legally import and manufacture from GM products in SA. These products are widely available on supermarket shelves. After over 30 years of global, and Australian GM food and fibre production, the global science has proven GM technology is safe. In addition, GM crops have successfully co- existed with conventional farming systems and identity preserved crops such as organic.

With respect to grower premiums, a recent study conducted by Mercado (attached) has proven that our non-GM production status has not led to increased returns to growers. This study supports a multitude of global studies that have been undertaken since the commercial release of GM crops over 30 years ago. Not only have the economic studies shown that there is no advantage to the state but commodities are trading at a penalty – a cumulative $33 million penalty.

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The bulk handlers (including WA's CBH, NSW's Graincorp etc) have demonstrated the ability to segregate and market GM products effectively. Viterra Australia (a Glencore Company) has demonstrated they are able to segregate, market & distribute commodities effectively. GM grain products will be no different. Marketers & buyers can be confident that through rigorous protocol & testing the level of contamination of non-GM products has been within established global & national safety standards. Although there are slightly increased costs to growers due to segregation, those values are taken into account when growers decide whether to propagate GM crops or not.

The moratorium was initially supported by a survey that appears limited to a niche of primary producers. This survey was not considered representative of the industry. Since its inception, the evidence for support of the moratorium within the agricultural community of SA has been limited to say the least. In fact during the parliamentary & independent reviews & subsequent surveys, it has been demonstrated that there is strong support for access to this technology & the rights to choose should be returned to the farmer.

It must also be noted that the initial moratorium was based on safety concerns. Given the time since GMO technology has been commercially available, the safety of GM crops has been rigorously tested. The proof has been overwhelming – the technology available to growers can be trusted to be safe for them, the environment & consumers. On the counter to safety concerns, the development of GMO technology such as golden rice (Vitamin A fortification), Omega-3 enriched canola & reduced gluten wheat has the potential to improve health outcomes for consumers.

The science of climate change has been strongly adopted by government and government agencies in Australia. Climate change presents a real risk to Australian farmers. The use of GM and emerging technologies for crop breeding to better manage these present and apparent risks is a must for the industry and society. GM crops can assist in the creation of a sustainable future through improved crop production, environmental health and a reduction of pesticide applied in the environment. The acceptance of GM technology will also ensure farmers have all the available tools to produce food and fibre crops sustainably and competitively into the future. These improvements in sustainability are not only through improved yields but through reduced farm chemical use and adoption of sustainable farming practices such as improved fertiliser and water use efficiency & reducing tillage.

There is a common misunderstanding that large multinational companies are the only businesses conducting GM research and development. The fact is there are hundreds of government & university based programs that conduct GM research & development, and much of this will make it to market. One particular example from Australia is the Omega-3 GM canola (mentioned above) developed by the CSIRO (in collaboration with the Grains Research Development Corporation (GRDC) and marketed through Nu-Seed). Unfortunately though, due to stringent and expensive regulations required, the main companies that can afford to commercialise & deliver this technology are the large-multinationals. This does not preclude industry development, and in fact pre-breeding investments in a range of grain crops by the GRDC will certainly include GM technology – this would be another direct farmer investment into GM technology – for grower's direct benefit.

Farmers are not forced to use a particular technology or practice, unless legislated to do so. Farmers, like other business owners & managers typically choose to make decisions based on evidence based testing until it is proven. Investment by organisations such as the SA Grains Industry Trust (SAGIT) & the GRDC doesn't give instant green light to a practice change. Farmers can continue to make personal & business decisions to use or not to use technology or practices, and GM will be no different.

The decision for a grower to propagate a GM crop also doesn’t mean organic & conventionally bred crops cannot also be grown. There are protocols for propagation & segregation that mean GM crops can be safety & confidently grown together within the state, and even on the same farm. Although there have been cases taken to court against growers of GM crops, it has been proven that by following the guidelines around production of GM crops the contamination of non-GM food & agricultural products can be avoided, and consumers & marketers can buy with confidence.

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For the members of your council that argue the need for the region to remain GMO free to maintain their market access or market premiums, it would be pertinent to ask whether they have truly investigated their market. It may be that they are actually receiving a premium for their produce being GMO free and not the region as a whole. It would be difficult to deny a large industry access to this important technology just because of languid marketing.

I would like to thank you for the time you have taken to read this letter, and ask that you assist in moving your region forward by supporting the propagation of GM crops in your region.

Please feel free to contact me directly via the number below if you seek further information. The Crop Science Committee members are willing to meet with you as required if particular details or clarification is required.

Best regards,

Current Crop Science Society President, Craig Davis.

Mob: 0447 541 654.

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Analysis of price premiums under the South Australian GM moratorium MARCH 2018

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Authors Andrew Whitelaw Matt Dalgleish Olivia Agar This report has been independently produced by Mecardo, under commission from Grain Producers South Australia (GPSA) and the Agricultural Biotechnology Council of Australia (ABCA). © Copyright, GPSA and ABCA, March 2018 This work is copyright. Apart from any use as permitted under Copyright Act 1968, no part may be reproduced without written permission of GPSA and ABCA.

Disclaimer

Neither Mecardo nor any member or employee of Mecardo. takes responsibility in any way whatsoever to any person or organisation (other than that for which this report has been prepared) in respect of the information set out in this report, including any errors or omissions therein. In the course of our preparation of this report, projections have been prepared on the basis of assumptions and methodology which have been described in the report. It is possible that some of the assumptions underlying the projections may change. Nevertheless, the professional judgement of the members and employees of Mecardo. have been applied in making these assumptions, such that they constitute an understandable basis for estimates and projections. Beyond this, to the extent that the assumptions do not materialise, the estimates and projections of achievable results may vary.

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Analysis of price premiums under the South Australian GM moratorium MARCH 2018

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Contents

Executive summary 1

Project overview 2 About Mecardo 2 Consultants 3 About the project 4

Background 6 GM regulation 6 Crop production in South Australia 8 Adoption of GM canola in Australia 9 Canola exports 10 Co-existence 11 Wheat 12 Barley 14 Canola 16 Wool 19 Cattle 20 Sheepmeat 22 Pork 24 Wine grapes 26

Conclusion 29

Tables

Table 1: Value of South Australian Broadacre Commodities 5 Table 2: Growth in canola area (Ha) 8 Table 3: Canola ﬂows 10

Maps

Map 1: GM crop status (Australia) 7 Map 2: Organic Farms (Australian Certiﬁed Organic) 11

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Figures, tables maps

Figure 1: Planting area as a percentage of total broadacre crop area in South Australia 8 Figure 2: Total area of canola planting in each state (Ha) 8 Figure 3: Percentage of canola sown as GM varieties 9 Figure 4: Overall percentage of canola crops planted to GM varieties in Australia by state 9 Figure 5: Correlation of Geelong and Adelaide wheat price at port 12 Figure 6: Correlation of Kwinana and Adelaide wheat price at port 12 Figure 7: APW price at Geelong and Adelaide port zones 13 Figure 8: APW price at Kwinana and Adelaide port zones 13 Figure 9: Percentage premium or discount in APW price to Adelaide from Geelong 13 Figure 10: Percentage premium or discount in APW price to Adelaide from Kwinana 13 Figure 11: Correlation of Adelaide and Geelong F1 barley prices at port 14 Figure 12: Correlation of Adelaide and Kwinana F1 barley prices at port 14 Figure 13: F1 barley price to growers at Adelaide and Geelong port zones 15 Figure 14: F1 barley price to growers at Adelaide and Kwinana port zones 15 Figure 15: Percentage premium or discount in F1 Barley price to Adelaide from Geelong 15 Figure 16: Percentage premium or discount in F1 Barley price to Adelaide from Kwinana 15 Figure 17: Correlation of Adelaide and Geelong Canola prices at port 17 Figure 18: Correlation of Adelaide and Kwinana Canola prices at port 17 Figure 19: Canola price to growers at Adelaide and Geelong port zones 17 Figure 20: Canola price to growers at Adelaide and Kwinana port zones 17 Figure 21: Percentage premium or discount in Canola price to Adelaide from Geelong 18 Figure 22: Percentage premium or discount in Canola price to Adelaide from Kwinana 18 Figure 23: Annual Returns Correlation Vic to SA trade steer 21 Figure 24: Monthly Returns Correlation Vic to SA trade steer 21 Figure 25: Monthly average price Vic to SA trade steer 21 Figure 26: Monthly average spread Vic to SA trade steer 21 Figure 27: Monthly returns correlation Vic to SA trade lamb 22 Figure 28: Monthly returns correlation Vic to SA mutton 22 Figure 29: Monthly average spread Vic to SA trade lamb 23 Figure 30: Monthly average spread Vic to SA mutton 23 Figure 31: Correlation of 60–75kg carcase weight pork price between SA and Vic 24 Figure 32: Correlation of 75–85kg carcase weight pork price between SA and Vic 24 Figure 33: 60–75kg carcase weight pig price in SA and Vic 25 Figure 34: 75–85kg carcase weight pig price in SA and Vic 25 Figure 35: 60–75kg carcase weight pork price percentage premium or discount to SA from Vic 25 Figure 36: 75–85kg carcase weight pork price percentage premium or discount to SA from Vic 25 Figure 37: Difference between average $/tonne price in South Australia and various states and districts 27 Figure 38: Average percentage price discount received by South Australian growers, to Victoria and Western Australia 27 Figure 39: $/tonne average price for 2008–17 for select varieties and regions 28

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Executive summary

The South Australian Government have continued the moratorium on the cultivation of GM crops until 2025. The moratorium was extended based on the presumption of premium prices are being achieved by South Australian farmers as a result of the status as a GM-free state. It is important that thorough research is conducted by experienced industry analysts to substantiate the presumption of premiums attained by South Australian farmers. This report is the most exhaustive analysis produced to date of the premiums and discounts achieved by farmers in South Australia, covering commodities which contribute approximately 63% of the state’s agricultural economy. The results demonstrate overwhelmingly that the majority of farmers in South Australia do not receive a premium as a result of the moratorium. The only agricultural commodity with a premium over a comparable market is pork, albeit a very slim premium, and likely based on supply and demand factors as opposed to the moratorium and subsequent marketing opportunities. It is our opinion, supported by economic analysis, that the moratorium in South Australia has not led to enhanced premiums over comparable markets to farmers producing the following commodities:

● wheat

● barley

● canola

● wine grapes

● wool

● cattle

● sheep and lamb. There is a slight premium for pork prices in South Australia, however it is not possible to determine whether this is due to the moratorium. Despite GM canola being the only GM crop currently grown in Australia that is likely to be adopted by SA farmers; the additional agricultural commodities were included in this analysis to test the presumption that the GM moratorium provides a premium to other South Australian agricultural commodities. Our analysis demonstrates that the GM moratorium removes the option of utilising innovative agronomic tools, licenced by the Gene Technology Regulator (GTR) as safe, with little in the way of trade and marketing beneﬁt to the majority of agricultural producers in South Australia. We have found no evidence to suggest that the repeal of the moratorium, and the introduction of GM canola, would lead to any reduction in comparable prices to South Australian farmers.

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Project overview

This report has been independently produced by Mecardo, under commission from Grain Producers South Australia (GPSA) and the Agricultural Biotechnology Council of Australia (ABCA).

About Mecardo

Mecardo is the leading multi-commodity analysis and risk management advisory enterprise in Australia, covering all major agricultural industries. Mecardo have one of the largest agricultural price datasets in Australia, however converting this data into meaningful analysis requires an underlying understanding of the industry. This is delivered through the diversity of the Mecardo team, with multifaceted skillsets developed through experience in a wide range of sectors and industries, which sets us apart from our competitors in the agriculture industry. This provides Mecardo with an ability to provide robust analysis crossing commodity boundaries, as opposed to single commodity views. Agricultural commodities are extremely complex, with a myriad of inﬂuences having an impact on market performance. The Mecardo ethos is to distil complex market analysis into a comprehensible and interpretable format. Across the agriculture sector Mecardo is recognised as possessing the required skills, industry understanding and experience to provide research outcomes, advice, strategy and recommendations based on underlying analytical market evidence and backed by ground truthing consultations. This report has been produced to be easily understood by all stakeholders within and outside the agricultural and agribusiness industry.

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Consultants

The Mecardo business prides itself on being a diverse and capable business which has carefully selected its employees to have complimentary skillsets. Robert Herrmann Robert Herrmann is the Managing Director of Mecardo. The company was established as Agconcepts by Robert Herrmann in Adelaide in 1996. Robert has a longstanding background in the wool and sheep industry in Australia. ● Cert 4, Workplace Training and Assessment ● RG146 Derivatives

Matt Dalgleish Prior to joining Mecardo, Matt began his career in 1993 with ANZ Bank as a technical analyst for foreign currency and interest rate markets. Matt progressed onto the currency trading desk, both in Australia and London. ● BA Economics and Finance (RMIT) ● Diploma of Education (Monash)

Andrew Whitelaw Andrew started his agricultural career in the United Kingdom in the feed and biofuel industry. Andrew has been involved in the trading of various agricultural commodities including Cert-ID NON-GM soymeal, organic wheat and conventional varieties. ● BSc Business IT and eBusiness (West Scotland) ● MA Agribusiness (UQ) ● RG146 Derivatives ● Chartered Quality Institute—ISO:9001 Certiﬁed Lead Auditor

Olivia Agar Olivia completed a Bachelor of Science in Agriculture Degree (Hons) at the University of Sydney in 2014, specialising in Agronomy. In 2017 Olivia joined the Mecardo team, further developing her skillset in data analysis and client consultancy. ● BSc Science in Agriculture (Sydney)

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About the project

This report has been commissioned to provide a data driven analysis of the presumed trade and marketing premiums achieved by farmers through the South Australian moratorium on the commercial cultivation of genetically modified (GM) crops. The SA Greens’ MLC Mark Parnell recently claimed that: The current moratorium has provided a significant price premium for our state’s farmers compared to other states.1 The SA Primary Industries Minister, Leon Bignell commented on premiums in 2014: Anecdotally, we know there are producers here in South Australia who are getting a premium for their GM-free produce. I have spoken to Viterra and grain producers.2 It is important to provide stakeholders with data driven evidence to ensure that government decisions are not made by anecdotes, but by facts. This report will not examine the agronomic nor regulatory aspects of the cultivation of GM crops, as this is outside the terms of reference. However, the authors note the following findings made by the Productivity Commission, in the 2017 report Regulation of Australian Agriculture: There is no economic or health and safety justification for banning approved genetically modified (GM) organisms.

● The Ofﬁce of the Gene Technology Regulator (OGTR) and Food Standards Australia New Zealand (FSANZ) assess GM organisms and foods for their effect on health, safety and the environment. Scientiﬁc evidence indicates that GM organisms and foods approved by the OGTR and FSANZ are no less safe than their non-GM counterparts.

● The successful coexistence of GM and non-GM crops is possible and has been demonstrated both in Australia and overseas. This means that if there are any market access or trade beneﬁts (including price premiums for non-GM products), they would be achieved regardless of whether GM crops are in the market.

1 Source: markparnell.org.au/mr.php?mr=1079 2 Source: www.abc.net.au/news/2017-07-29/sa-growers-challenge-gentically-modiﬁed-food-ban-jay- weatherill/8748398

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Project aim The Weatherill Labor government in South Australia have identiﬁed that the continuation of the moratorium on the cultivation of GM crops provides a premium to farmers. The purpose of this paper is to identify the existence and extent of the premiums achieved in South Australia. The methodology is to analyse on a ‘like for like’ basis, agricultural commodity prices in South Australia against comparable markets in states where the cultivation of GM crops is permissible.

Project scope The scope of this project is limited to analysing the price premiums received by South Australian farmers. The report does not consider any agronomic factors involved in the selection of GM crops, nor the traded price of consumer foods.

Commodity selection To ensure a thorough examination of the presumed premiums available to food and ﬁbre producers in South Australia, we have chosen a set of commodities based on the value to the South Australian economy, which have a high degree of pricing transparency available. The commodities selected are detailed in Table 1, and comprise 63% of the South Australian agricultural economy.

Table 1: Value of South Australian Broadacre Commodities

Percentage Commodity Gross value of overall Wheat 927,247,960 15%

Barley 365,584,539 6%

Canola 111,863,194 2%

Wool 447,542,321 7%

Sheep and lamb 534,546,618 9%

Cattle 682,665,753 11%

Pork 326,582,263 5%

Grapes 536,482,844 9% Total 3,932,515,492 63%

Source:ABS

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Background

To provide a foundation of knowledge, a synopsis of the background of a number of important factors relating to the cultivation of GM crops has been included in the following sections. These sections will provide a summary of the following:

● GM regulation and the role of the Gene Technology Regulator

● An overview of crop production in South Australia

● The adoption of GM canola in Australia on a state-by-state basis

● An overview of Australian canola exports on a state-by-state basis

● An overview of co-existence in states cultivating both GM and non-GM crops.

GM regulation

Agriculture is a key driver of the Australian economy, and it is of great importance to ensure the continued high integrity of our produce. Australia has one of the most stringent regulatory regimes coordinating the management and introduction of genetically modified crops. The Gene Technology Regulator, assisted by the Office of the Gene Technology Regulator (OGTR) is responsible for the identification and management of risks posed by live and viable genetically modified organisms (GMOs), including GM crops. The OGTR carries out risk analysis to identify and manage any risks posed to human health and the environment by new GM crops before allowing field trials and before seeds can be commercially produced and sold to farmers. The OGTR prepares a risk assessment and risk management plan before granting a licence for commercial release of new GM crops. This includes:

● identifying if a new characteristic of a GM crop may cause harm, compared to its conventional counterpart

● developing risk management plans, on a case-by-case basis, to ensure that any identiﬁed risks (if any) can be managed

● asking for both expert and public feedback on the risk assessment and management plan on both ethical as well as technical issues. These stringent controls are in place to ensure that new GM crops are thoroughly scrutinised, to ensure any risks to human health and the environment have been identiﬁed and can be managed. In 2003, the OGTR issued licences for the commercial release of two types of GM Canola in Australia. All state and territory governments, except Queensland and the Northern Territory subsequently established GMO-free zones to delay the release of GM canola until trade and marketing considerations had been addressed. New South Wales, Victoria and Western Australia now allow the commercial production of GM canola.

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The moratoria in South Australia and Tasmania have been identified by the Productivity Commission (PC), as a regulation reducing flexibility and constraining the use of more efficient production techniques. The PC highlight limited evidence of the moratoria providing substantiative premiums, and the capacity for co-existence between GM crops and non-GM crops. Successful co-existence has been proven throughout Australia and overseas. The only regions in Australia which have maintained moratoria on the commercial cultivation of GM crops, are South Australia, Australian Capital Territory and Tasmania (see Map 1).

Map 1: GM crop status (Australia)

GM cultivation Permitted Forbidden

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Crop production in South Australia

Crop production is the largest single contributor to the South Australian agricultural economy. The production of wheat, barley and canola contribute $1.4 billion annually to the South Australian economy, or 23% of all agricultural income. In South Australia, wheat makes up the bulk of crop grown, at on average 56% of the area allocated to cultivating broadacre crops. This is followed by barley at 23%, and canola at 6% (Figure 1). In South Australia, the bulk of the crop is exported due to the limited domestic demand. However, during periods of production deficit in eastern Australia the South Australian supply can be utilised by the domestic market. At present the majority of grain and oilseed production is exported through the bulk handling system operated by Viterra. In recent years, small scale export pathways have emerged, and future port infrastructure projects are expected on the Eyre Peninsula. The canola crop in South Australia, is predominantly the focus of any debate relating to the adoption of GM crops, as any removal of the GM moratorium will likely result in the cultivation of GM Canola. The area devoted to canola in Australia has increased dramatically since the turn of the century (Figure 2). In Table 2, a comparison is provided of the average area for the first five years of the century, versus the average of the past five years. It is interesting to note that of the major canola producers, South Australia has demonstrated the least growth between the two periods at 27%.

Figure 1: Planting area as a percentage of total Figure 2: Total are of canola planting in each broadacre crop area in South Australia state (Ha)

70% 1,600,000

60% 1,400,000

50% 1,200,000

40% 1,000,000 800,000 30% 600,000 20% 400,000 10% 200,000 0% -

Wheat Barley Canola NSW Vic SA WA

Table 2: Growth in canola area (Ha)

State 2000–05 2013–17 Change NSW 469,356 612,394 30%

Vic 254,084 413,534 63%

Qld 846 1,434 70%

SA 201,044 256,051 27%

WA 409,272 1,298,169 217%

Tas 469 1,026 119% Total 1,335,070 2,582,606 93%

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Adoption of GM canola in Australia

The cultivation of GM crops is a voluntary activity, and farmers in countries and regions where GM cultivation is permitted will make their own decision on utilising GM production techniques. It is therefore appropriate to examine the adoption of GM crops in Australia. The adoption of GM canola in Australia has been swift, with the strongest growth recorded in Western Australia. In Figure 3, we can see overall percentage of canola crops planted to GM varieties in Australia. The overall canola crop comprises 19% of area. When South Australia is excluded, due to the lack of access the GM canola area increases to 21% of eligible canola cultivation. In Figure 4, highlights the percentage of canola sown as GM varieties for NSW, Vic and WA. The most substantial growth in GM cultivation has occurred in Western Australia, with approximately 28% of the states canola planted as GM in 2017. In Vic and NSW, the growth has not been as strong however it remains a popular crop choice, at 14%, and 11% respectively. Independent research from Brookes and Barfoot (2017)3 indicates an average net increase in gross margins for Australian GM canola in 2015 of US$37/ha. The grower is ultimately the decision maker when determining which crops to plant on their property. The decision will be elected by many reasons including both economic and agronomic judgements. In the case of the majority of the GM canola varieties currently commercially available, the economic decision is not solely based on one year’s performance. There are residual benefits which flow onto subsequent years through improved field health.

Figure 3: Percentage of canola sown as Figure 4: Overall percentage of canola crops GM varieties planted to GM varieties in Australia by state 25% 30%

20% 25% 20% 15% 15% 10% 10% 5% 5%

0% 0%

% GM of overall crop % GM of overall crop (ex SA) NSW VIC WA

3 Brookes G and Barfoot P 2017, The Global Socio-Economic and Environmental Impact of GM Crops: 1995 to 2015, PG Economics Ltd Dorchester.

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Canola exports

The South Australian Government have publicly signalled that the GM moratorium allows the state to protect the canola trade. To give an indication of the countries that South Australia has traded canola in recent years, and whether this is true, we have examined the ﬂows of canola in the past three years (Table 3). The canola ﬂow data does not indicate the GM or non-GM status of the canola. Interestingly, there are no export destinations with whom South Australia has traded canola with, that the neighbouring states (which permit GM canola cultivation) have not also traded. In addition, South Australia has not exported any canola into France or Germany, which are countries that currently prohibit commercial GM cultivation. The trade of canola from Western Australia, which is the largest producer of GM canola, into the same export destinations as South Australia points to evidence of the capacity for bulk handlers to effectively segregate between conventional (non-GM) and GM varieties.

Table 3: Canola ﬂows

Country NSW SA Vic WA Netherlands 60,000 216,754 30,000 881,992

Belgium 60,000 181,465 180,000 679,445

Argentina - 81,816 90,000 331,582

South Africa 167,550 61,834 155,482 228,265

United Arab Emirates - 57,470 - 75,727

Japan - 53,865 5,249 279,121

China - 49,850 - 296,476

France 80,000 100,862 614,613

Germany 99,839 - - 550,491

Hong Kong - - - 50,000

Indonesia - - - 5,000

Oman - - - 16,000

Pakistan - - 30,377 122,061

Portugal - - - 54,999

Singapore - - 66,714 -

South Korea - - - 25,000

Spain 65,000 - 113,000 411,530

Sri Lanka 60,000 - - -

Taiwan - - - 50,000

United States - - 10,000 120,169

Source: Reuters Eikon

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Co-existence

In Australia, the co-existence between non-GM and GM canola, can be considered effective. At present there have been few, if any, issues relating to seed incursions between crops, and with modern bulk handling systems segregation of stocks has been effective. There are concerns from organic certified businesses, relating to issues around the unintended presence of GM material on their land or in their products. This concern is often used to justify the continued GM moratorium in South Australia. It is important to note however, that within Australia there are a considerable number of states that hold high levels of organic certifications, co-existing with GM cultivation. At present, Queensland, New South Wales and Victoria, all have a higher number of organic certifications than South Australia, and all permit the commercial cultivation of GM crops. It is possible to extrapolate on this basis, that the cultivation of GM crops in South Australia could operate effectively alongside the organic food production industry, as is the case in other states.

Map 2: Organic Farms (Australian Certiﬁed Organic)

8 494 92 141 677

377

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Pricing analysis

Wheat

In South Australia, wheat is the most important agricultural commodity, providing 15% of the state’s agricultural income and comprising 56% of the states cropping area in the past decade. Due to its importance to the South Australian economy, it is extremely important to understand whether a repeal of the GM moratorium would impact upon the prices received by farmers. If there are substantial premiums available in South Australia, as result of its status as a GM-free state, then it should be clear when compared to other GM growing states.

Methodology To produce an analysis of wheat prices, it is important to choose comparable markets. In our analysis of the premium achieved in South Australia because of the GM moratorium we have elected to compare Adelaide with Geelong (Victoria) and Kwinana (Western Australia). The wheat crop in South Australia is typically destined for the export market, however occasionally there will be demand into Victoria. It is therefore appropriate to study the differential between South Australia and a domestic and export state which both produce GM crops. The wheat crop, is not one homogeneous product, and is made up of various grades. The grade which we have selected for analysis is APW (Australian Prime Wheat), which is the base grade used by the grain trade. The wheat market is driven by both global and domestic factors, with prices rising and falling largely due to supply issues. The port zones in Australia all tend to correlate closely with one another. When two markets have a high degree of correlation, this means that they have a strong relationship with one another. In effect, this shows that when a price falls/rises in one zone, it will be repeated in others. In Figure 5 and Figure 6, the correlation of Geelong/Kwinana and Adelaide wheat at port is displayed. The data shown is the daily price from 1 January 2012 to present. The charts clearly display an interdependence upon one another. The Geelong port has a correlation of 0.92, and Kwinana 0.85, with 1 being a perfect correlation and 0 being no correlation.

Figure 5: Correlation of Geelong and Adelaide Figure 6: Correlation of Kwinana and Adelaide wheat price at port wheat price at port 340 360 R² = 0.9183 R² = 0.846 320 340

300 320

280 300

260 280

240 260

220 240

200 220

180 200 200 220 240 260 280 300 320 200 220 240 260 280 300 320

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Results In Figure 7 the comparison of the APW price available to growers at the Geelong and Adelaide port zones. The price at both ports tend to follow one another closely, however as can be clearly determined, the Geelong price trades more often at levels above the Adelaide port. In Figure 8, the comparison of the APW price at the Kwinana and Adelaide port is studied. As expected, the ports both follow similar patterns, however again Kwinana tends to trade more often at a premium to Adelaide.

Figure 7: APW price at Geelong and Adelaide port Figure 8: APW price at Kwinana and Adelaide port zones zones 355 340

335 320

315 300 295 280 275 260 255 240 235 215 220 195 200

Adelaide Geelong Kwinana Adelaide

To give a clearer vision of the comparison of Adelaide and Geelong/Kwinana, the below charts have been produced. In Figure 9, the percentage premium or discount between Adelaide and Geelong is displayed. Any pricing below 0% signiﬁes a discount in Adelaide versus Geelong. On average since 2012 Adelaide has traded at a 3% discount to Geelong. In Figure 10, the comparison of Adelaide and Kwinana is displayed, in a similar pattern the majority of the time farmers delivering into Adelaide are receiving a discount to Kwinana, at an average of 5%. Interestingly, the orange lines on both these charts represent the linear trajectory, and in both comparisons the discount in Adelaide has been steadily increasing. This highlights that wheat in South Australia is in fact reducing in value against two states which are growing GM crops, contradicting the argument for an increasing premium for South Australia wheat due to the GM moratorium.

Figure 9: Percentage premium or discount in APW Figure 10: Percentage premium or discount in APW price to Adelaide from Geelong price to Adelaide from Kwinana ϭϬй

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Barley

In South Australia, the barley crop comprises 25% of the broadacre cropping industry in South Australia for the past decade, and contributes 6% of the overall agricultural income for the state. The barley grown in South Australia is used for both feed consumption, and in the domestic and international malt market.

Methodology To produce an analysis of barley prices, it is important to choose comparable markets. In our analysis of the presumed premium achieved in South Australia because of the GM moratorium we have elected to compare Adelaide with Geelong (Victoria) and Kwinana (Western Australia). The barley crop in South Australia is used in both the domestic and export markets. It is therefore appropriate to study the differential between South Australia and a domestic and export state which both produce GM crops. There are a multitude of different barley varieties which have been developed for both the feed market and the malt market. The bulk of the barley crop produced is for the feed market, and even malting barley can become feed grade, due to downgrading based on seasonal conditions. It is therefore appropriate to examine the feed price, which for the case of this study will be the F1 grade. The port zones in Australia all tend to correlate closely with one another. When two markets have a high degree of correlation, this means that they have a strong relationship with one another. In effect, this shows that when a price falls/rises in one zone, it will be repeated in others. In Figure 11 and Figure 12, the correlation of Geelong/Kwinana and Adelaide F1 barley at port is displayed. The data shown is the daily price from 1 January 2012 to present. The charts clearly display an interdependence upon one another. The Geelong port has a correlation of 0.89, and Kwinana 0.91, with 1 being a perfect correlation and 0 being no correlation.

Figure 11: Correlation of Adelaide and Geelong Figure 12: Correlation of Adelaide and Kwinana F1 barley pricesg() at port F1 barley prices at port 310 310 R² = 0.8907 R² = 0.915 290 290

270 270 250 250 230 230 210 210 190 190 170 170 150 150 170 190 210 230 250 270 290 150 170 190 210 230 250 270 290

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Results In Figure 13 the comparison of the F1 barley price available to growers at the Geelong and Adelaide port zones. The price at both ports tend to follow one another closely, however as can be clearly determined, the Geelong price trades more often at levels above the Adelaide port.

Figure 13: F1 barley price to growers at Adelaide Figure 14: F1 barley price to growers at Adelaide and Geelong port zones and Kwinana port zones 300 300 280 280 260 260 240 240 220 220 200 200 180 160 180 140 160 140

Adelaide Geelong

Kwinana Adelaide

In Figure 14, the comparison of the F1 barley price at the Kwinana and Adelaide port is studied. In a similar manner to the Geelong and Adelaide comparison, Kwinana trades more often at a premium to Adelaide. To give a clearer vision of the comparison of Adelaide and Geelong/Kwinana, the below charts have been produced. In Figure 15, the percentage premium or discount between Adelaide and Geelong is displayed. Any pricing below 0% signiﬁes a discount in Adelaide versus Geelong. On average since 2012 Adelaide has traded at a 5% discount to Geelong. In Figure 16, the comparison of Adelaide and Kwinana is displayed, in a similar pattern most of the time farmers delivering into Adelaide are receiving a discount to Kwinana, at an average of 7%. Interestingly, the orange lines on both these charts represent the linear trajectory, and in both comparisons the discount in Adelaide has been steadily increasing. This highlights that barley in South Australia is in fact reducing in value against two states which are growing GM crops, contradicting the argument for an increasing premium for South Australian barley due to the GM moratorium.

Figure 15: Percentage premium or discount in F1 Figure 16: Percentage premium or discount in F1 Barley price to Adelaide from Geelong Barley price to Adelaide from Kwinana ϭϬй ϱй

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Canola

Canola comprises 6% of the broadacre cropping industry in South Australia over the past decade, and contributes 2% of the overall agricultural income for the state. The canola crop is the key commodity when it comes to the moratorium, as it will be the primary GM product grown in SA in the event of a repeal of the GM moratorium.

Methodology — Greens South Australia The Hon. M.C. Parnell, in his private members bill to the South Australian Parliament,4 provided evidence of a premium achieved by South Australian growers as a direct result of the moratorium. This is the only instance of evidence presented of a premium being provided to South Australian farming businesses. It is therefore important to discuss the methodology used by the Hon. M.C. Parnell as it was highly inconsistent with commonly used analytical procedures. The evidence provided was a comparison of the spread between Non-GM and GM canola in several states on the week commencing 9 October 2017. There are two major ﬂaws in this methodology:

● Comparing the discount between non-GM and GM in another state is not an analogous comparison to South Australian canola pricing.

● When comparing pricing, it is important to choose an appropriate time period, one week is not considered a long enough period for a robust analysis. This is especially important in agricultural commodities which can be volatile due to weather conditions causing supply constraints.

Methodology In order to compare analyse comparable markets, we have elected to compare South Australia with Western Australia and Victoria. These are both states which cultivate GM canola, and the assumption from the Weatherill Labor government and the Greens SA party are that premiums would be visible. In South Australia, the majority of canola is exported in a similar fashion to Western Australia, giving a more comparable relationship between the two. There are however times when South Australian canola will ﬂow into the domestic markets in Victoria, therefore a comparison between these two states will be included. The most logical pricing point to analyse, is a comparison of the price of non-GM in Adelaide, with non-GM in other states growing GM crops. The Australian canola market is driven by both global and domestic factors, with prices rising and falling largely due to supply issues. The port zones in Australia all tend to correlate closely with one another. When two markets have a high degree of correlation, this means that they have a strong relationship with one another. In effect, this shows that when a price falls in one, it will also fall in another.

4 Genetically Modiﬁed Crops Management Regulations (Postponement of Expiry) Bill, SA Hansard, 18 October 2017.

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In Figure 17 and Figure 18, the correlation of Geelong/Kwinana and Adelaide canola at port is displayed. The data shown is the daily price from 1 January 2012 to present. The charts clearly display an interdependence upon one another. The Geelong port has a correlation of 0.91, and Kwinana 0.82, with 1 being a perfect correlation and 0 being no correlation.

Figure 17: Correlation of Adelaide and Geelong Figure 18: Correlation of Adelaide and Kwinana Canola prices at port Canola prices at port 650 700 R² = 0.9057 R² = 0.8342 650 600

600 550 550 500 500

450 450

400 400 400 450 500 550 600 650 400 450 500 550 600 650

Results In Figure 19, a comparison of the grower price of non-GM canola in Adelaide (Green) and Geelong (orange) is displayed. They both follow closely, however Geelong is more often trading at a premium to Adelaide. Figure 20, is the comparison of non-GM canola in Adelaide and Kwinana. The Kwinana port cost has been adapted to consider the intake fees, which are paid by the grower in order to give a like for like comparison.

Figure 19: Canola price to growers at Adelaide and Figure 20: Canola price to growers at Adelaide and Geelong port zones Kwinana port zones

600 650

550 600

550 500

500 450 450 400 400

Adelaide Geelong Kwinana Adelaide

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To give a clearer vision of the comparison of Adelaide and Geelong/Kwinana, the below charts have been produced. In Figure 21, the percentage premium or discount between Adelaide and Geelong is displayed. Any pricing below 0% signiﬁes a discount in Adelaide versus Geelong. On average since 2012 Adelaide has traded at a 2% discount to Geelong. In Figure 22, the comparison of Adelaide and Kwinana is displayed. In a similar pattern, the majority of the time farmers delivering into Adelaide are receiving a discount to Kwinana, at an average of 3%. Interestingly, the orange lines on both these charts represent the linear trajectory, and in both comparisons the discount in Adelaide has been steadily increasing. This highlights that canola in South Australia is in fact reducing in value against two states which are growing GM crops, contradicting the argument for a premium to South Australian canola farmers due to the GM moratorium.

Figure 21: Percentage premium or discount in Figure 22: Percentage premium or discount in Canola price to Adelaide from Geelong Canola price to Adelaide from Kwinana ϱ͘ϬϬй ϱй

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Wool

The wool market is worth an estimated 7% to the South Australian agricultural economy. The wool produced in South Australia is typically sold at auction in Melbourne. The price received at auction for wool is based on several quality factors including micron levels and vegetable. Due to the nature of South Australian wool being sold at auction in Melbourne, and no sales originating in South Australia, there is no data on pricing at a state-by-state level. We have however spoken with a number of prominent industry professionals who provided the following insights: There is no differentiation for wool based on its proximity to the cultivation of GM crops. The main factors are the micron, length and strength of the combined samples. We have seen increased interest in the “providence” of wool, with customers interested in the origin of the sheep producing the ﬁbre. To date, this has been contained to factors relating to animal husbandry, land management etc. Andrew Woods, Wool Analyst, Independent Commodity Services, December 2017

Wool is traded internationally in the world ﬁbre market, with blending on many types to produce the ideal yarn and fabric. Factors such as softness, style and character are subjective assessments used by exporters alongside the more robust measured traits of micron, ﬁbre strength and length, vegetable matter and yield. There is no evidence to date that the wool market rewards or indeed seeks any information relating to the GM status. Michael De Kleuver, Wool Broker, Rodwells December, 2017

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Cattle

To determine if a premium exists for South Australian cattle producers we need to be able to compare markets that are interdependent and share a degree of correlation in price movement to ensure that we are measuring like for like. We have run a series of correlation analysis over historic cattle price movements contrasting SA to other states and a variety of cattle categories. Results of the analysis indicate a strong correlation on an annual basis when comparing Victorian Trade Steer price movements to SA Trade Steer price movements.

Methodology Price differences between Victorian Trade Steers and SA Trade Steers were converted to both annual and monthly logarithmic returns and a correlation analysis was run on these returns to measure the Pearson correlation coefﬁcient (r2). Price variations are converted to logarithmic returns because correlation measurements are used more appropriately when the underlying distributions satisfy certain properties — such as being normally distributed and when the data is non-stationary. Logarithmic returns are preferred to simple returns as these are more normally distributed than simple returns. The main reason that returns are used to measure correlation instead of nominal prices is because prices are ‘non-stationary’. This means that they have trends. One requirement for practically all statistics functions (including correlation) is that the data is ‘stationary’ otherwise the results are overstated by the trend following nature of prices. The result of calculating price returns over a designated timeframe are considered stationary and can therefore be used to provide a much more appropriate measure of price interdependence between periods. The formula used to calculate the monthly and annual returns is outlined below: Return = log10 (Price T/ Price T+1) where T denotes the time period, i.e. monthly or annual. Percentage spread analysis was undertaken between the monthly average prices of Victorian Trade Steers and SA Trade Steers by calculating the percentage variation between the two-price series expressed as a percentage. The formula for calculating the percentage spread was as follows: Percentage Spread = ((Monthly Average Price of Vic Trade Steer/ Monthly Average Price of SA Trade Steer) -1) x100)

Results On an annual basis, the returns correlation between SA and Victorian Trade Steers shows a very strong interdependence, scoring an r2 of 0.9405 (Figure 23). This means that nearly all of the time the annual price movement in SA Trade Steers and Victorian Trade Steers follow each other. Analysis of the monthly returns between SA and Victorian Trade Steers shows a moderate correlation with an r2 of 0.4165 (Figure 24), which suggests that over a monthly timeframe prices between the two states can deviate according to local supply and demand conditions but, as the annual correlation highlights, will move back in line over the longer term as arbitrage opportunities and competitive pressures bring the two markets back into balance.

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Figure 23: Annual Returns Correlation Vic to SA Figure 24: Monthly Returns Correlation Vic to SA trade steer trade steer 0.20 0.20 R² = 0.9405 R² = 0.9464 0.15 0.15

0.10 0.10

0.05 0.05

0.00 0.00

-0.05 -0.05

-0.10 -0.10 -0.10 -0.05 0.00 0.05 0.10 0.15 0.20 0.25 -0.10 -0.05 0.00 0.05 0.10 0.15 0.20 0.25

Source: MLA's NLRS, ACA Source: MLA's NLRS, ACA

Figure 24 highlights the average monthly price achieved by SA and Victorian Trade Steer producers at the saleyard according to the weekly MLA reported statistics. A cursory glance at the chart illustrates two fairly obvious characteristics of the two price patterns; namely, that the prices of SA and Victorian Trade Steers share a close interdependence and that SA prices usually run at a discount to Victorian prices.

Figure 25: Monthly average price Vic to SA trade Figure 26: Monthly average spread Vic to SA trade steer steer ΪͬŬŐĐǁƚ DŽŶƚŚůǇй 800 ^ƉƌĞĂĚ ϰϬй 700 Vic Trade Steer SA Trade Steer 600 ϯϬй

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Source: MLA's NLRS, ACA Source: MLA's NLRS, ACA

An overview of the historic percentage spread between SA and Victorian Trade Steer monthly average prices from 1998 to 2017, as outlined in Figure 25, demonstrates how few times SA producers have enjoyed a premium over their Victorian counterparts. Indeed, there have only been four brief periods over the last two decades when SA Trade Steers achieved a premium over Victorian Trade Steers on a monthly basis. Analysis of the monthly spread data (Figure 26) shows that Victorian Trade Steers have posted a long run average premium of 8.3% over SA Trade Steers (black dotted line) and the orange spread trendline shows that over the last two decades the premium spread in favour of Victoria has been expanding, as denoted by the upward slope to the trendline. As highlighted above, the spread for Victorian to SA Trade Steers from 1998 to 2017 sits at 8.3% premium. However, measuring the average spread from 2008 to 2017, shows that the premium spread has widened to 9.1% in favour of Victorian cattle producers.

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Sheepmeat

The two most highly correlated markets for South Australian Trade Lamb and South Australian Mutton are their Victorian counterparts, so this is the most appropriate place to begin an investigation into the proposition that the non-GM status of South Australia affords a price premium being obtained by SA producers, over the long term, when compared to their Victorian cousins.

Methodology As was the case with the cattle price analysis, the methodology for determining the correlation between markets was to compare the logarithmic returns for SA Trade Lambs and Mutton to Victorian Trade Lambs and Mutton, over a monthly basis. The percentage spread analysis was also conducted using weekly price data of the Trade Lambs and Mutton according to the following formulae: Percentage Spread Trade Lamb = ((Weekly Average Price of Vic Trade Lamb/ Weekly Average Price of SA Trade Lamb)-1) x100) Percentage Spread Mutton = ((Weekly Average Price of Vic Mutton/ Weekly Average Price of SA Mutton) -1) x100)

Results Figure 27 and Figure 28 highlight that on an average, monthly basis price changes between both SA Trade Lamb and Mutton share a very strong correlation with Victoria with Trade Lambs scoring an r2 of 0.7867 and Mutton posting an even higher r2 of 0.8057, both indicative of a strong price interdependence between these respective markets.

Figure 27: Monthly returns correlation Vic to SA Figure 28: Monthly returns correlation Vic to SA trade lamb mutton 0.15 0.5 R² = 0.7867 0.4 R² = 0.8057 0.1 0.3 0.2 0.05 0.1 0 0 -0.1

-0.05 -0.2 -0.3 -0.1 -0.4 -0.15 -0.1 -0.05 0 0.05 0.1 0.15 -0.5 -0.3 -0.1 0.1 0.3 0.5

Source: MLA's NLRS, ACA Source: MLA's NLRS, ACA

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Analysis of the Trade Lamb spread since 2000 shows that over the long term Victorian producers have been enjoying a 3% price premium, as highlighted by the black dotted line in Figure 29. Interestingly, in recent times the spread has widened in favour of Victorian Trade Lamb producers, such that the recent price premiums have been closer to 4%, as indicated by the upward sloping spread trend line, displayed in orange. Similarly, the long term historic spread pattern for mutton shows a price advantage to Victorian producers over SA too. Indeed, the average premium is even more pronounced at 9% since 2000 — dotted black line as per Figure 30. As was the case with Trade Lambs, the spread for Mutton has been widening in favour of Victorian Mutton producers such that in more recent years the spread has moved toward a 10% premium.

Figure 29: Monthly average spread Vic to SA Figure 30: Monthly average spread Vic to SA mutton trade lamb 30% 80% 25% 60% 20% 15% 40% 10% 20% 5% 0% 0% -5% -20% -10%

-15% -40%

Source: MLA's NLRS, ACA Source: MLA's NLRS, ACA

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Pork

The pork industry contributes 5% of the agricultural economy in South Australia. According to ABS statistics,5 there are 209 businesses with pigs, which in 2015–16 equated to 408,468 pigs, or 18% of the national herd. In this analysis, a comparison of premiums and discounts between South Australia and Victoria has been chosen. These states operate largely in the same domestic market, and therefore a comparison is appropriate.

Methodology In order to give a representation of the ﬁnal pork price paid to pig producers in South Australia, we have elected to compare two pricing points. The 60–75kg and 75–85kg carcase weight price, these are the weight ranges that pigs are typically sold. In Figure 31 and Figure 32, the correlation of pork pricing between South Australia and Victoria is displayed. In Figure 31, the 60–75kg carcass weight is shown, and in Figure 32 on a weekly price basis. These charts show a clear interdependence, with the 60–75kg weight range having a correlation of 0.9663, and 75–85kg at 0.9613. A correlation of 1 is a perfect correlation, whilst 0 would indicate no correlation.

Figure 31: Correlation of 60–75kg carcase weight Figure 32: Correlation of 75–85kg carcase weight pork price between SA and Vic pork price between SA and Vic ϰϬϬ ϰϬϬ

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5 ABS, Agricultural Commodities, Australia, 2015–16

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Results In Figure 33, the pig price in South Australia and Victoria is displayed for 60–75kg carcase weight animals, Figure 34 displays the same comparison however with the 75–85kg carcase. As we can see the two states typically tend to trade at very similar levels. Since 2012, both Victoria and South Australia have held premiums over one another. Interestingly, from May 2017 through to August 2017, a substantial premium was achieved in South Australia. This period of time coincides with a period, when producers in Victoria were being turned away by abattoirs.6 However, prices have since reverted back to more typical levels.

Figure 33: 60–75kg carcase weight pig price in SA Figure 34: 75–85kg carcase weight pig price in SA and Vic and Vic 400 400 380 380 360 360 340 340 320 320 300 300 280 280 260 260 240 240 220 220

SA VIC SA VIC

To give a clearer indication of the premium/discount between South Australia and Victoria, Figure 35 and Figure 36 have been produced. These display the premium or discount as a percentage, the substantial premium in 2017 is clearly apparent, and could be considered anomalous. The pork price in South Australia for 60–75kg carcase weight pigs since 2012 has averaged a premium of 0.46%, when the 2017 anomalous period is excluded this drops to -0.13%. The pork price in South Australia for 75–85kg carcase weight pigs since 2012 has averaged a premium of 1.08%, when the 2017 anomalous period is excluded this drops to 0.5%. Overall this points to the pork market in South Australia and Victoria trading at very similar levels, with a somewhat limited premium in South Australia, dependent upon carcase weight.

Figure 35: 60–75kg carcase weight pork price Figure 36: 75–85kg carcase weight pork price percentage premium or discount to percentage premium or discount to SA from Vic SA from Vic ϭϲ͘ϬϬй ϭϲ͘ϬϬй

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6 www.weeklytimesnow.com.au/agribusiness/pig-cull-warning-falling-pork-prices-may-force-producers-to-destroy-pigs/ news-story/7e191c146167ef785cfad761a15d7e65

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Wine grapes

Grape production has become an important agriculture product in both domestic and export markets. The industry has a global reputation for high quality wines which has subsequently contributed to growth in the secondary output of agritourism. The total estimated value of the Australian winegrape crush in 2016 was $1.08 billion. Of which, South Australia contributed 51% of the tonnes crushed (Wine Australia). This amounted to a farmgate value of $581 million to South Australian growers in 2015–16 (SA Scorecard). Wine grape prices have been on an upward trend since 2011. The average national purchase price across all varieties was $565 per tonne in 2017. South Australia has 23 distinct wine regions. The Lower Murray, Fleurieu, Limestone Coast and Barossa Valley regions contribute the greatest value to the state through grape production.

Methodology To compare the local price received for grape production in South Australia with other states and the Murray Darling–Swan Hill (MDSW) district the calculated average purchase value per tonne by region and variety was used. This data was summarised for the period of 2008–17 and provided by Wine Australia.7 To ensure like for like analysis, any varieties not grown in South Australia were not included in the calculations. To indicate whether SA growers on average received premiums or discounts for their grapes by comparison, the average spread of $/tonne between SA and each state and MDSW was calculated each year.8 The percentage discount of average local price between SA and Vic, and SA and WA from 2008 to 2017 was calculated and plotted in Figure 37. Victoria was selected based on its proximity and similar market to South Australia, while Western Australia was selected because it is the largest producer of GM Canola and hence should in theory reﬂect any market and trade advantages or disadvantages due to GM use most. Further analysis was conducted to compare the markets at a regional level. The regions of Riverland (SA), Riverina (NSW) and Murray Darling–Swan Hill (Vic and NSW) were selected as comparable markets under advice from Wine Australia. The average $/tonne price of three varieties of wine in the distinct regions was calculated and plotted in Figure 39.

7 Any variety/region combination that did not have at least three separate batches purchased was not included in the data provided by Wine Australia. 8 Queensland has been excluded from the analysis due to insufﬁcient volumes.

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Results On average, South Australia grapes are priced at a discount to Tasmania, Victoria and Western Australia. The only state which South Australia receives a premium to is New South Wales and the Murray Darling–Swan Hill district.

Figure 37: Difference between average $/tonne price in South Australia and various states and districts

1,000

500

-500

-1,000

-1,500

-2,000 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 MDSW NSW TAS VIC WA

Figure 38 shows that since 2008 South Australia has continuously received a discounted local price for wine grapes on a $/tonne basis. The discount was largest in 2010–11 and the spread began to narrow over the years. The discount SA received to Victoria has again been rising since 2014 to an estimated 30% discount in 2017. While it is only in the last two years that the spread to Western Australia has been growing.

Figure 38: Average percentage price discount received by South Australian growers, to Victoria and Western Australia 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 0% -5% -10% -15% -20% -25% -30% -35% -40% -45% -50% % Dicount SA to VIC % Discount SA to WA

ANALYSIS OF PRICE PREMIUMS UNDER THE SOUTH AUSTRALIAN GM MORATORIUM 27 APPENDIX SPECIAL COUNCIL 5.1C-8SEPTEMBER2020 PAGE 36 AGENDA ITEM SPECIAL COUNCIL 5.1.1 SUBMISSION #1

It is worthwhile noting that despite Western Australia being Australia’s largest GM canola growing state, this does not correlate with lower prices for wine grapes.

Figure 39: $/tonne average price for 2008–17 for select varieties and regions ΨͬdŽŶŶĞ ϱϬϬ ϰϱϬ ϰϬϬ ϯϱϬ ϯϬϬ ϮϱϬ ϮϬϬ ϭϱϬ ϭϬϬ ϱϬ Ϭ ŚĂƌĚŽŶŶĂǇ WŝŶŽƚEŽŝƌ ^ĂƵǀŝŐŶŽŶůĂŶĐ DƵƌƌĂǇĂƌůŝŶŐͲ^ǁĂŶ,ŝůů ZŝǀĞƌŝŶĂ ZŝǀĞƌůĂŶĚ

Analysis of the $/tonne price of grapes at a variety and region level showed that the premiums and discounts to specific regions changed seasonally for all three varieties. For example, Riverland (SA) received a premium price for Sauvignon in 2010–12 and again in 2015, but was at a discount to Riverina and/or Murray Darling–Swan Hill in all other years between 2008–17. Over the total period, Riverland received an average premium for Sauvignon of $6 to the Riverina and $8 to MDSW. For Pinot Noir it received an average discount of $42 to Riverina and premium of $10 to MDSW. For Chardonnay, Riverland received a discount of $9 to Riverina and discount of $6 to MDSW. These variability in price, and hence premiums or discounts between years, varieties and regions indicates the wide range of factors that determine price. The following statement was provided by Wine Australia, which highlights the lack of concern for GM crops being cultivated in proximity to vineyards. Winegrapes are not traded as a homogeneous commodity and the $/tonne price received by grape growers is determined by a wide variety of factors. The location of the vineyard and quality of the grapes are significant determinants of price, while other factors such as distance to the winery and contract arrangements can also have an influence. It is the view of the industry analysts at Wine Australia that a region or state’s status as ‘GM-free’ would be unlikely to have an effect on grape price and therefore would not be expected to play a role in premiums or discounts to any states. December, 2017

28 Mecardo Expert Market Analysis APPENDIX SPECIAL COUNCIL 5.1C-8SEPTEMBER2020 PAGE 37 AGENDA ITEM SPECIAL COUNCIL 5.1.1 SUBMISSION #1

Conclusion

The intended purpose of this report was to provide an in-depth analysis of price premiums achieved by primary producers in South Australia. The moratorium on commercial GM crop production has been extended until 2025, based on presumed premiums being achieved by farmers. This project was commissioned in response to public assertions that South Australian farmers were receiving substantive premiums because of the GM moratorium. This analysis examined commodities which contribute 63% of the South Australian agricultural economy. The thorough pricing analysis in this report, outlined that the GM moratorium has not resulted in substantive premiums, or a trade and marketing advantage for the majority of primary producers in South Australia. The only commodity displaying a premium is pork, albeit very a slight one. It is not possible to determine whether this premium is because of the GM moratorium; however, industry stakeholders have pointed towards logistical issues in 2017 creating a short-term and isolated trade imbalance. The premiums and discounts available to South Australian primary producers are in the opinion of our researchers linked to logistics, and proximity to market as opposed to the presumed beneﬁts of the GM moratorium. When commodity prices are compared on a like for like basis with analogous regions, using stringent analytical methodology, the evidence of price premiums or a trade and marketing advantage as a proposition for the continuation of the GM moratorium is insufﬁcient.

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Mr Brian Carr Chief Executive Officer Light Regional Council PO Box 72 Kapunda SA 5373

By email: [email protected]

13 August 2020

Dear Mr Carr

RE: Consultation on application for designation under the Genetically Modified Crops Management Act 2004

As the peak industry body for South Australia’s 4,500 grain producing businesses, GPSA welcomes consultation on the Genetically Modified Crops Management Act 2004 by the Light Regional Council in advance of any application for designation as a GM cultivation-free area. We note that, while the Council has elected to undertake consultation on this matter, the Council is not obliged to make an application for designation pursuant to the Act.

To assist the Light Regional Council, GPSA has prepared a submission in relation to genetically modified crops and the trade and marketing effects of any designation. The evidence produced through two separate economic assessments and nearly two decades of successful coexistence between GM, non-GM, and organic crops interstate demonstrates that there are no trade and marketing benefits as a result of SA’s GM-free status, and that the removal of restrictions relating to GM crops will not have any adverse trade or marketing impacts in your local government area.

GPSA would be happy to answer any further questions that the Light Regional Council might have in relation to this issue.

Yours sincerely,

Caroline Rhodes Chief Executive Officer Grain Producers SA

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Submission to the Light Regional Council in relation to the Genetically Modified Crops Management Act 2004.

CONTENTS

1.0 EXECUTIVE SUMMARY ...... 3 2.0 INTRODUCTION ...... 3 3.0 AN INTRODUCTION TO GENETICALLY MODIFIED CROPS ...... 4 4.0 REGULATORY FRAMEWORK...... 6 5.0 TRADE AND MARKETING IMPACT OF GENETICALLY MODIFIED CROPS ...... 7 5.1 MECARDO REPORT ...... 8 5.2 ANDERSON REVIEW ...... 9 6.0 INDUSTRY COEXISTENCE ...... 10 7.0 GPSA’S POSITION ...... 12 8.0 CONCLUSION ...... 12

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1.0 EXECUTIVE SUMMARY Local governments have a time limited opportunity to apply for designation as a GM cultivation-free area under changes to the Genetically Modified Crops Management Act. A designation under the Act will only affect cultivation of GM crops. Current GM crop varieties confer a variety of benefits, including weed control, farming system, and environmental benefits. New varieties are being developed that respond to other challenges facing the sector. Under the nationally consistent framework, designations as GM-free areas may only be made where there is a trade or marketing benefit/ reason. The cultivation of genetically modified crops has been restricted in South Australia since 2004, at a direct cost of over $33 million to canola production in SA. Two separate independent economic assessments have found that the majority of farmers in South Australia do not receive a premium as a result of the moratorium, with a qualified exception for Kangaroo Island. Australia’s robust supply chain guarantees industry coexistence between GM, non-GM, and organic farming systems as demonstrated interstate.

2.0 INTRODUCTION

South Australia is the last mainland state to remove its ban on the commercial cultivation of genetically modified (‘GM’) crops. Recent changes to the Genetically Modified Crops Management Act 2004 (‘the Act’) have provided local governments with a time-limited opportunity to apply for designation as a GM cultivation-free area. Pursuant to the Act, an application may only be made after consultation with specified groups has occurred.

All applications are assessed by the expert GM Crop Advisory Committee, with the final decision on all applications made by the Minister for Primary Industries and Regions, the Hon. David Basham MP.

Independent economic analysis demonstrates that the GM moratorium does not provide trade and marketing benefits to the majority of agricultural producers in South Australia. The only effect of SA’s GM-free status is to remove the option of utilising innovative tools, licenced by the Commonwealth’s scientific regulator, the Gene Technology Regulator (GTR), as safe.

As a result, GPSA strongly believes that the Light Regional Council has no sound trade and marketing basis on which to apply to be designated as a GM cultivation-free zone. We note that opponents of GM technology have not been able to demonstrate substantive benefits of SA’s GM- free status beyond mere platitudes.

By declining to make an application the Light Regional Council will contribute to regulatory certainty across the state, and will provide growers with the choice to grow the cereal, legume and oilseed varieties that best fit their farming system.

Australian grain producers have a long history of innovation and adopting new technology to improve productivity. We need to ensure that South Australian growers have access to all the tools on offer for best practice crop production.

Restrictions on GM crops constrains business growth and the overall. This has ramifications for the South Australian economy more broadly.

GPSA strongly opposes any application for designation as a GM cultivation-free area to support:

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x Increased competitiveness nationally and globally.

x Increased profitability for individual grain growing enterprises, which contributes to higher employment and jobs growth. x Increased research in cropping varieties and other agricultural technologies in South Australia, including attracting or retaining research dollars, scientists, and post-graduate students. GPSA’s position is not about picking winning production systems, but rather enabling all producers to have the freedom to grow the crops that best suit their business.

3.0 AN INTRODUCTION TO GENETICALLY MODIFIED CROPS

GM crops have been prohibited in South Australia since the introduction of the Act in 2004. As noted in the Act’s second reading speech, the moratorium was first introduced to protect existing and future markets for farm produce until supply systems are developed to provide the necessary segregation and identity preservation of crops as a precautionary measure.1

Since first imposing moratoria, other Australian states have progressively either removed their moratoriums or provided wholesale exemptions from the operation of the applicable acts. This is largely due to confidence in industry supply systems and the availability of suitable GM varieties. GM canola is widely grown across Australia, while Australia’s cotton industry now almost exclusively cultivates GM varieties.

South Australia will be the last mainland state to remove its ban on the commercial cultivation of GM crops when changes take effect in November 2020.

GM canola and super-high oleic safflower are currently the only two GM crops that are relevant to South Australian conditions. Current GM canola varieties include herbicide tolerance, omega-3 oil content, and hybrid breeding system benefits, providing a variety of agricultural and environmental benefits, including:

x Increased weed control options, x A range of farming system benefits through reduced tillage and less fuel usage, sow on time, better farm management and increased crop rotation options, x Environmental benefits through the sustainable usage of crop protection products, x A more sustainable canola industry through potentially higher yields, higher oil retention, and more consistent production. GM technology also extends beyond herbicide (glyphosate) resistance traits. New varieties of GM canola with high omega3 oil content (genes derived from microplankton)2,3 and super-high oleic

1 South Australia. Legislative Council (2004) Parliamentary Debates. 24 February, 1064. The Hon. P. Holloway MLC, Minister for Agriculture, Food and Fisheries. https://history.pir.sa.gov.au/__data/assets/pdf_file/0006/161916/Scan_Genetically_modified_Crops_Bill_2004.pdf 2 Petrie, J.R. et al. (2010). Metabolic engineering of omega-3 long-chain polyunsaturated fatty acids in plants using an acyl- CoA Delta6-desaturase with omega3-preference from the marine microalga Micromonas pusilla. Metab. Eng 12: 233-240 3 OGTR (2018a). Licence for dealings involving an intentional release of a GMO into the environment. DIR155: Commercial release of canola genetically modified for omega-3 oil content (DHA canola NS B5ØØ27 4). Issued: 13 February 2018. Retrieved October 2018 from: http://www.ogtr.gov.au/internet/ogtr/publishing.nsf/Content/DIR155

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safflower 4,5 have recently been approved for commercial cultivation. These varieties promise to sustainably produce special products and decrease reliance on fish stocks (omega3) and fossil fuels (industrial oils). GM technology is being applied interstate to overcome climate change induced production constraints, including drought and frost tolerance. The University of Adelaide is currently conducting research into experimental GM wheat and barley crops that offer benefits like drought and frost tolerant wheat and barley.6 Trials are also underway in other parts of Australia into drought tolerant chickpeas, disease resistant wheat, and grains with improved health benefits for consumers.7 However, these advancements will only be beneficial if our grains sector has the freedom of choice to adopt this technology and incorporate it into South Australian farming systems. South Australia’s broader ability to remain competitive domestically and internationally will be jeopardised for as long as the choice to access GM varieties is denied. A 2016 report demonstrated that over the first 20 years of commercial GM crop cultivation in Australia (1996-2015), Australian cotton and canola farmers gained $1.37 billion in extra income and produced an additional 226,000 tonnes of canola that would otherwise have not been produced if non-GM technology alone had been used.8 Importantly, South Australian farmers did not benefit from this opportunity. Similarly, Brookes and Barfoot (2017) estimate the average net increase in gross margins for GM canola in Australia in 2015 was US$38/ha (eq. to AU$48.50/ha based on a US exchange rate of 0.78).9 Again, a benefit denied to South Australian farmers.

An international meta-analysis suggests that GM crops have contributed significant benefits, including a reduction in pesticide use by 37%, an increase in crop yield by 22%, and importantly an increase to farmer profits of more than 68% with the latter having positive flow on effects to local economies and communities. 10

The most recent analysis by Biden et al. (2018) found that the environmental opportunity costs from delaying the adoption of GM canola in Australia include an additional 6.5 million kilograms of active ingredients applied to canola-growing land; a 14.3% increase in the environmental impact to farmers, consumers and the ecology; an additional 8.7 million litres of diesel fuel burned; and an additional 24.2 million kilograms of greenhouse gas (GHG) and compound emissions released. The economic opportunity costs of the moratoria resulted in foregone output of 1.1 million metric tonnes of canola and a net economic loss to canola farmers of AU$485.6 million.11

4 Wood CC, Okada S, Taylor MC, Menon A, Mathew A, Cullerne D, Stephen SJ, Allen RS, Zhou XR, Liu Q,. Oakeshott JG, Singh SP, Green AG. (2018). Seed-specific RNAi in safflower generates a super high oleic oil with extended oxidative stability. Plant Biotechnology Journal https://doi.org/10.1111/pbi.12915 5 OGTR (2018b). Licence for dealings involving an intentional release of a GMO into the environment. DIR158: Commercial release of safflower genetically modified for high oleic acid composition. Issued: 27 June 2018. Retrieved October 2018 from: http://www.ogtr.gov.au/internet/ogtr/publishing.nsf/Content/DIR158 6 OGTR (2020). Table of applications and authorisations for Dealings involving Intentional Release (DIR) into the environment. Retrieved June 2020 from: http://www.ogtr.gov.au/internet/ogtr/publishing.nsf/Content/ir-1 7 Ibid. 8 Brookes G (2016) ‘Adoption and impact of Genetically Modified Crops in Australia: 20 Years’ Experience’. Report prepared for CropLife Australia Ltd, Canberra, May 2016. 9 Brookes G and Barfoot P (2017) ‘GM crops: Global Socio-economic and Environmental Impacts 1996-2015’. PG Economics Ltd, Dorchester, UK. June 2017. 10 Klumper, W and Qaim M (2014). A meta-analysis of the impacts of genetically modified crops. PloS one, 9(11), p.e111629 11 Biden S, Smyth SJ and Hudson D (2018) ‘The economic and environmental cost of delayed GM crop adoption: The case of Australia's GM canola moratorium,’ GM Crops & Food, 9:1, 13-20.

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4.0 REGULATORY FRAMEWORK

Australia maintains one of the most respected regulatory systems for the evaluation and assessment of GM products. Australia has a nationally consistent regulatory framework under the Intergovernmental Gene Technology Agreement (IGA) and the Gene Technology (Recognition of Designated Areas) Principle 2003.

Under this framework, the Commonwealth is largely responsible for regulating GM varieties, including determining whether they meet applicable health and environmental requirements.

States may only regulate GM varieties for trade and marketing purposes.12 Historically, this has been enacted through the establishment of blanket moratoriums in order to gain a marketing advantage as a result of a state’s GM-free status.

Under the nationally consistent regulatory framework, those seeking to gain a marketing advantage through the use of a GM-free status are responsible for the verification and integrity of that status.

A GM food crop variety cannot be commercially cultivated in Australia until approval is given by the GTR.13 This is to ensure that GM varieties are as safe as their non-GM equivalents, with respect to both human health and the environment. Trials of GM varieties are also regulated by the GTR in the same scientific manner.

GM foods and ingredients for use in the food supply in Australia and New Zealand must be approved by Food Standards Australia New Zealand.14 All GM foods and ingredients (including food additives and processing aids) that contain novel DNA or novel protein must be labelled with the words ‘genetically modified’.15

Recent changes to South Australia’s Act have provided local governments with a time-limited opportunity to apply for designation as a GM cultivation-free area.16 Pursuant to the Act, an application may only be made after consultation with specified groups has occurred, including the agricultural sector.

All applications are assessed by the expert GM Crop Advisory Committee, with the final decision on all applications made by the Minister for Primary Industries and Regions, the Hon. David Basham MP.17

It is important to note that a designation as a GM cultivation-free area will only restrict the cultivation and handling of GM food crops. The transportation of GM food crops and end products will not be restricted by a designation pursuant to the Act. In addition, the sale and consumption of GM end products will similarly not be restricted by a designation pursuant to the Act.

12 Department of Health. The Gene Technology Agreement. Last updated December 2012. Retrieved June 2020 from: https://www1.health.gov.au/internet/main/publishing.nsf/Content/gene-tech-agreement 13 OGTR. Genetically Modified Organisms in Australia Fact Sheet. Issued September 2018. Retrieved June 2020 from: http://www.ogtr.gov.au/internet/ogtr/publishing.nsf/Content/9AA09BB4515EBAA2CA257D6B00155C53/$File/01%20- %20Genetically%20modified%20organisms%20in%20Australia.pdf 14 FSANZ. Genetically modified (GM) food labelling. Issued August 2019. Retrieved July 2020 from: https://www.foodstandards.gov.au/consumer/gmfood/labelling/Pages/default.aspx 15 Ibid. 16 Genetically Modified Crops Management Act 2004 (SA) s 5A. 17 Ibid.

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Scientific research of GM food crops (including through field-scale trials) may also occur in areas designated as GM cultivation-free under exemption by the Minister for Primary Industries.

The Act also includes numerous investigation and enforcement provisions which provide integrity to the framework. The Minister may appoint inspectors (who hold certain powers specified in the Act) and order the destruction of GM material where that material is in breach of the Act.18 In practice, officers from the Department of Primary Industries and Regions SA (PIRSA) hold the inspection and enforcement powers under the Act. Fines of up to $200,000 are also prescribed for cultivating a GM food crop in breach of the Act.

Strong stewardship protocols are already implemented through commercial License and Stewardship agreements between technology providers and producers, as well as in crop management and resistance management plans developed by technology providers. These agreements, inter alia, require that producers:

1. Complete an accreditation course prior to planting; 2. Comply with a technology management plan and resistance management plan; 3. Grant the technology provider and the national regulator power of entry for auditing and monitoring purposes; 4. Allow the technology provider and the national regulator to collect information in relation to a GM product, and provide information sufficient to identify paddocks where a GM product is being cultivated; 5. Inform the technology provider if there are any unintended or adverse consequences from the use of a GM product; and 6. Allow the technology provider to collect samples and inspect equipment for three years after planting a GM product.19

Breaches of the agreements may lead to producers being denied a future license to grow a GM product and may entitle a technology provider to take out an injunction requiring that the producer destroy the GM product.

Industry and government are jointly responsible for the introduction and maintenance of the 0.9% low-level presence industry threshold level which was set by the Primary Industries Ministerial Council in 2005 and applied nationwide. Industry now determines the threshold tolerances for approved GM canola from non-GM canola in the grain supply chain, using the Ministerial Council decision as the basis for coexistence.

5.0 TRADE AND MARKETING IMPACT OF GENETICALLY MODIFIED CROPS

Two separate economic assessments conducted since 2018 have considered whether producers achieve the often-claimed price premiums as a result of SA’s prohibition GM-free status. Those reviews, summarised below, have found that the GM moratorium does not provide trade and marketing benefits to the majority of agricultural producers in South Australia, with a qualified

18 Genetically Modified Crops Management Act 2004 (SA) s 16. 19 Monsanto Australia (2010) ‘GROWER LICENSE AND STEWARDSHIP AGREEMENT FOR TRUFLEX® CANOLA WITH ROUNDUP READY® TECHNOLOGY and ROUNDUP READY® CANOLA (Also referred to as MONSANTO GROWER AGREEMENT)’.

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exception for Kangaroo Island. The moratorium’s only effect is to remove the option of utilising innovative tools, licenced by the GTR, as safe.

Any local government looking to make an application for designation as a GM cultivation-free area will have to meet the high threshold set by the findings of these two separate independent economic assessments. 5.1 MECARDO REPORT In 2018, GPSA and the Agricultural Biotechnology Council of Australia (ABCA), engaged Mecardo to undertake an economic study into whether South Australian farmers received price premiums as a result of South Australia’s GM-free status.20 This study followed two other studies also undertaken by Mecardo in 201621 and 2017.22

To date, the Mecardo report is the most in-depth analysis examining whether premiums and discounts are being achieved by South Australian farmers as a result of South Australia’s GM-free status. The report researched pricing over time in South Australia compared with other Australian states for a range of key commodities such as wheat, barley, canola, wine grapes, wool, cattle, sheep, lamb and pork. These commodities collectively comprise approximately 63% of South Australia’s agricultural economy.

This analysis suggests that South Australian producers were trading at a 2-30% discount compared to Western Australia (WA) and/or Victoria (Vic) in all but one commodity: pork. Further, since 2012, non-GM canola at South Australian export ports has consistently traded between 2% and 3% below Geelong (Vic), and Kwinana (WA) ports respectively. In addition, over the past 3 years SA has not exported canola to either France or Germany, who both prohibit commercial GM cultivation. However, over the same period, WA exported approximately 1.2 million tonnes to those countries.

The Mecardo Report concludes that “The results demonstrate overwhelmingly that the majority of farmers in South Australia do not receive a premium as a result of the moratorium. The only agricultural commodity with a premium over a comparable market is pork, albeit a very slim premium, and likely based on supply and demand factors as opposed to the moratorium and subsequent marketing opportunities.”23

Further, the Report concludes that there is “...no evidence to suggest that the repeal of the moratorium, and the introduction of GM canola, would lead to any reduction in comparable prices to South Australian farmers.”24

The report also indicates that South Australian grain producers are at a significant disadvantage compared to their major domestic competitors in WA and Vic, continually trading at a discount.

20 Whitelaw A, Dalgleish M and Agar O (2018) ‘Analysis of price premiums under the South Australian GM moratorium’. Report independently produced by Mecardo, under commission from Grain Producers South Australia (GPSA) and the Agricultural Biotechnology Council of Australia (ABCA), March 2018. 21 Whitelaw A (2016) ‘Is the GM ban in South Australia providing a premium?’. Mercado Expert Market Analysis: 25 July 2016. 22 Whitelaw A (2017) ‘Controversial canola’. Mercado Expert Analysis: May 25 2017. 23 Whitelaw A, Dalgleish M and Agar O (2018) ‘Analysis of price premiums under the South Australian GM moratorium’. Report independently produced by Mecardo, under commission from Grain Producers South Australia (GPSA) and the Agricultural Biotechnology Council of Australia (ABCA), March 2018, 1. 24 Ibid.

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The findings of the Mercardo Report make it clear that there is no benefit to grain producers or producers of other key agricultural commodities in South Australia (and by extension the Light Regional Council area) retaining their GM cultivation-free status.

At present, Queensland, New South Wales and Victoria, all have a higher number of organic certifications than South Australia, and all permit the commercial cultivation of GM crops.25 It is possible to extrapolate on this basis, that the cultivation of GM crops in South Australia could operate effectively alongside the organic food Figure 1: Australian Certified Organic production industry, as is the case in other states farms by state (see figure 1).

5.2 ANDERSON REVIEW In 2019 the SA Government commissioned a high-level independent review of South Australia’s moratorium on the cultivation of Genetically Modified (GM) food crops, conducted by Emeritus Professor Kym Anderson.26 This review found that the moratorium has cost SA’s grain industry at least $33 million since 2004.27

The $33 million cumulative cost estimate is relatively conservative and should be considered in the context of the small canola crop in South Australia. The estimate is heavily influenced by the sensitivities highlighted and does not consider any indirect benefits.

GPSA contends that a direct cumulative cost of $33 million for a state that only produces 8.7% of Australia’s canola crop is significant. With no clear pathway to market, crop developers have limited the development of new varieties suited to SA farms. Further, South Australian growers have been denied the benefits of new GM varieties, including canola with high omega3 oil content and super- high oleic safflower. As such, farmers in other states continue to benefit while SA farmers face a lack of competitiveness and the continued reduction in canola production in SA.

The Anderson Review also highlights that indirect on-farm and other costs of SA’s GM-free status are not captured in the estimate of economic effects.28 These costs are likely to be significant. As noted above, the proportion of SA canola exports has reduced whilst overall Australian canola exports have tripled. SA is not capturing any of this additional value, in part due to the lack of choice to SA farmers and the reduced level of non-GM canola development suited to South Australian conditions.

GPSA contends that there are unlikely to be additional segregation or testing costs should the Light Regional Council elect not to make an application to be designated as a GM cultivation-free area. SA

25 Whitelaw A, Dalgleish M and Agar O (2018) ‘Analysis of price premiums under the South Australian GM moratorium’. Report independently produced by Mecardo, under commission from Grain Producers South Australia (GPSA) and the Agricultural Biotechnology Council of Australia (ABCA), March 2018, 11. 26 Anderson K (2019) ‘Independent Review of the South Australian GM Food Crop Moratorium’. Report to the SA Minister for Primary Industries and Regional Development, March 2019. 27 Ibid, 34. 28 Ibid, 34-35.

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grain is already extensively tested for quality and for the presence of GM in accordance with Australian Oilseed Federation Oilseed Standards.

In addition to the $33 million cost, Professor Anderson found that:

x there is no price premium for grain from South Australia despite it being the only mainland state with a GM crop moratorium, x the moratorium will continue to hurt South Australian producers with (at least) another $5 million cost if the moratorium continues until 2025, x GM crops typically use less, rather than more farm chemicals when compared to conventional crops, x GM crops can also deliver reduced weed control costs and increased yields, x KI growers would be able to preserve their unique non-GM market in the event that the moratorium is removed from mainland SA, x South Australia’s moratorium has discouraged both public and private research and development investment in this state, x removing the moratorium will attract or retain research dollars, scientists, and post- graduate students in South Australia, and x segregation protocols (such as those used interstate) ensures the successful co-existence of GM and non-GM crops.

The Anderson Review also identified that only one foreign firm specifically sought produce from South Australia as a result of its GM-free status, being the unique non-GM market referred to above which is sourced directly through Kangaroo Island canola growers. 29

There is no other independently assessed evidence that suggests that any other firm, co-operative, or region derives a premium from a location-based GM-free status.

6.0 INDUSTRY COEXISTENCE

Both the Mecardo Report and the Anderson Review clearly demonstrate that coexistence between GM cropping and other industries will not be affected by changes to SA’s GM-free status.

Australia’s robust supply chain guarantee SA’s ability to export GM-free and/or organic produce, and for South Australian food manufacturers such as San Remo, Maggie Beer, and Paris Creek Farms to successfully market their products as GM-free and/or organic.

Despite (failed) high profile litigation,30 GM and non-GM canola has been successfully and productively grown side-by-side without market issues. There has not been a single market or trade incident in over eight years of commercial GM canola production. 6.5 million tonnes of canola have been delivered domestically, and more than 19 million tonnes of canola internationally to end users (i.e. seed crusher / oil or meal buyer, or food / feed manufacturer) in accordance with their requested GM status.

Separation distances are recommended as part of the technology management plans issued by technology providers. Bayer’s Roundup Ready Canola Technologies Crop Management Plan recommends that a minimum 5 metre buffer be established between Roundup Ready technologies

29 Anderson K (2019) ‘Independent Review of the South Australian GM Food Crop Moratorium’. Report to the SA Minister for Primary Industries and Regional Development, March 2019, 40. 30 Noting that organic litigants failed in the high profile ‘test case’ of Marsh v Baxter 2015 WASCA 169.

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and all other canola. These distances are based on an “extensive review of scientific studies, which shows that GM canola may be grown in proximity to non-GM, with little risk that the non-GM canola will exceed the 0.9% adventitious presence industry threshold level.”31

According to Bayer, “The rate of cross-pollination between two adjacent canola fields is generally low and this declines with distance (leptokurtic response). An Australian study by Rieger et al. (2002) showed that in the great majority of cases, even adjacent canola paddocks in Australia had pollen flow in a range of 0.00 to 0.07%. Whilst in a total of 197 individual samples of paddocks in a range of 0–5 km away from each other, pollen flow from paddock to paddock was always less than 0.25%, with no outcrossing detected at 69% of sites.”32

Further, in Australia, different types of wheat, barley and rice are grown in close proximity to, and channelled to different uses (e.g. bread wheat versus noodle wheat; malt barley versus feed barley and short-grain versus long-grain rice) without adverse effects to those markets.

SA’s predominant grain handler and marketer, Viterra, has advised GPSA that:

“Viterra’s position has always been that we can support the choice to grow GM crops by providing handling and quality management expertise and processes to meet the market requirements of handling and segregating both GM and non-GM commodities.

Viterra’s approach to managing GM commodities will be consistent with our commitment to ensuring South Australian grain meets the requirements of end users, both domestically and internationally. Viterra has maintained its ISO 22000 certification for more than 20 years, the highest certification of any grain supply chain in Australia. Viterra’s $3 million purpose built grain laboratory opened in 2018 helps maintain our international accreditation standards and retain valuable export markets for SA grain.”33 [emphasis added]

The peak winegrape body, Australian Grape & Wine, have outlined a full industry policy position with respect to the use of GM products:

“It is the Australian wine industry’s position that no genetically modified organisms, as defined under the Australia New Zealand Food Standards Code (Standard 1.5.2: Food Produced Using Gene Technology) be used in the production of wine.

This includes additives or processing aids defined as genetically modified foods according to Standard 1.5.2.

Standard 1.5.2 sets down the criteria for defining a genetically modified food by addressing thresholds for formulation and refining processes to remove novel DNA and novel proteins. Underpinning Australian wine is a culture of innovation and a willingness to improve the way grapes are grown and wine is made.

The industry will therefore continue to explore new developments in all areas of science but will only apply these new practices commercially when there are clear consumer benefits and public acceptance of the practices.”34

31 Bayer Australia ‘Roundup Ready Canola Technologies Crop Management Plan’. 2019, 2. 32 Ibid, 1 33 Letter to Grain Producers SA from Viterra Regional Director Tim Krause, 5 June 2020. 34 Australian Grape & Wine. Policy and Issues - Genetically Modified Organisms. No date. Retrieved June 2020 from: https://www.agw.org.au/policy-and-issues/biosecurity-environment-and-sustainability/genetically-modified-organisms/

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GPSA notes that this industry policy has no bearing on the use or cultivation of GM products in other industries, including broadacre cropping.

Wine Australia provided the following statement to Mecardo in the Mecardo Report, which highlights the lack of concern for GM crops being cultivated in proximity to vineyards:

“Winegrapes are not traded as a homogeneous commodity and the $/tonne price received by grape growers is determined by a wide variety of factors. The location of the vineyard and quality of the grapes are significant determinants of price, while other factors such as distance to the winery and contract arrangements can also have an influence. It is the view of the industry analysts at Wine Australia that a region or state’s status as ‘GM-free’ would be unlikely to have an effect on grape price and therefore would not be expected to play a role in premiums or discounts to any states.”35 [emphasis added]

7.0 GPSA’S POSITION

GPSA has consistently argued that the moratorium offers little in the way of trade and marketing benefits to the majority of agricultural producers in SA and only removes the option of using GM tools which have been independently proven to be safe and effective.

GPSA believes that growers deserve the freedom to grow the cereal, legume and oilseed varieties that best fit their farming system. GPSA’s position is not about picking winning production systems, but rather enabling choice for all producers.

We are backing the state’s grain industry to manage the transition out of the moratorium in a sensible manner and look forward to growers finally being able to make their own choices about which crops they want to grow without the hinderance of legislators on North Terrace.

Recent changes to the Act begin an orderly transition towards removing all restrictions on GM crops approved by the GTR in SA and provides certainty for the industry in time for the 2021 season.

Technology providers require confidence and clarity in the regulatory process and as such are awaiting the outcomes of the council process before taking any steps to formalise the commercial introduction of GM products in South Australia.

8.0 CONCLUSION

There is no independently assessed evidence to suggest that the Light Regional Council area and businesses operating within it derive a benefit from SA’s GM-free status, or would derive a benefit from a designation as a GM cultivation-free area under recent changes to the Act.

Independent economic analysis demonstrates that the only effect of a designation as a GM cultivation-free area is to remove the option of utilising innovative tools, licenced by the Commonwealth’s scientific regulator, the Gene Technology Regulator (GTR), as safe.

The available evidence clearly indicates that:

35 Whitelaw A, Dalgleish M and Agar O (2018) ‘Analysis of price premiums under the South Australian GM moratorium’. Report independently produced by Mecardo, under commission from Grain Producers South Australia (GPSA) and the Agricultural Biotechnology Council of Australia (ABCA), March 2018, 28.

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1. There are no trade or marketing benefits to the Light Regional Council holding a GM cultivation-free status, 2. There are significant costs imposed as a result of a GM-free status, and 3. Australia’s robust supply chain guarantees industry coexistence.

GPSA therefore encourages the Light Regional Council to enable freedom of choice for producers in its local government area by electing not to apply for designation as a GM cultivation-free area.

ENDS.

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June 22, 2020

To the Mayor, Councillors and CEO of the Light Regional Council

Please take action to keep your region a GM-free Crop Zone

Dear Mayor, Councillors and CEO,

Losing South Australia's state-wide GM-free status and reputation for high quality GM-free food products will disrupt market and trade opportunities for producers and processors all over the state, including those in your council area.

Kangaroo Island farmers worked hard to stay GM-free as they earn big premiums for the island's GM-free grains and beverages, in local and export markets. KI Pure Grain told the Anderson Inquiry:

“The potential direct cost to KIPG and the KI Grain Growers is the loss of demand for our Non-GM Canola which presently stands at approximately $3,025,000. Additionally, … there is potential to lose further sales of other grains marketed as 'GM Free' which would add to this loss.”

The Palsystem Consumers' Co-operative Union of Japan's submission noted their strict non-GM policy, so they bought canola and honey exclusively from Kangaroo Island, with annual revenues of $6 million to the Island's economy. They added

“In order to further develop our economic contribution for both Kangaroo Island and the whole of South Australia, we are currently working on a plan to expand our range and volume of non-GM products, but the extension of the moratorium is critical to this plan.”

Another GM-free Japanese Consumer Co-operative, Coop Shizenha, which has over 142,000 members said,

“Our turnover is expected to reach AUD$233 million this fiscal year [2018]” and we “hope that we can contribute further to your economy by purchasing agricultural products cultivated in South Australia and Kangaroo Island as the only remaining Non-GM cultivation area of your country.”

To boost its case for lifting the GM Crop Moratorium on mainland SA, the Marshall Government commissioned the Anderson Review with short term and narrow Terms of Reference. The report was based on shaky assumptions, excluded relevant information, and ignored inconvenient data. As the GeneEthics Network’s submission pointed out:

“Australian non-GM canola has earned premiums in Europe since 2006 and the GM canola discounts continue to be significant. CSIRO team leader Dr Sandra Eady and Australian Export Grains Innovation Centre chief economist Ross Kingwell confirmed that "We've achieved a $100 million per year premium for our farmers, given the extra $20-$40/tonne paid for Australian non-GM Australian canola.”

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In the week ending June 5, 2020, GM canola was discounted $95/tonne in WA compared with non- GM varieties, $39/tonne in Port Melbourne, and up to $39/tonne in rural NSW.

What individual councils can achieve

Your council has the opportunity to remain a GM-free Zone, despite the Government’s determination to make the whole South Australian mainland into a GM crop area.

We urge councils to wholeheartedly embrace this process and make their best efforts to marshal the processes and community resources so that a GM-free Crop Zone can be established here. GM pollen is easily carried on the wind and by bees and will not stop at artificial borders. The more councils that are declared a GM-free Crop Zone, the better the protection for all non-GM and organic producers.

How councils can respond

We ask you to: x consider retaining your council as a GM-free Crop Zone, as the Government has lifted the state's GM Crops Moratorium and put the onus of applying to keep any area GM-free onto local government; x consult with members of your community, including persons engaged in primary production activities and food processing or manufacturing activities, following council's usual practices; x gather evidence of the present and future benefits and costs of remaining GM-free vs the potential benefits and costs of allowing GM crops to be grown in your council - canola and safflower now, but possibly GM wheat, rye-grass, lucerne, etc. in future; x apply to Minister for Primary Industries, Tim Whetstone MP, for your council to remain a GM-free Crop Zone, “an area in which no genetically modified crops may be cultivated”; x refute the Anderson report findings on which the government's GM policy is based, in the application, and make the case for the council to remain a GM-free Crop Zone: o give an overview of positive feedback, submissions and evidence that led to council's decision to advocate for a GM-free Crop Zone; o show a marketing advantage for primary producers, food producers and manufacturers from remaining a GM-free Crop Zone; o provide evidence of positive marketing or trade impacts on local businesses from remaining a GM-free Crop Zone.

There are also many compelling health and environmental reasons to avoid GM crops. But it is important to remember that in this process, the only reason the Minister will designate an area as a GM-free Crop Zone is for the preservation of the identity of crops (GM and non-GM) for marketing purposes.

Please also note that the Minister must receive your application by September 30th so it can be approved and gazetted before the legal deadline.

Enclosed is a report from Dr John Paull PhD, an environmental scientist at the University of Tasmania, casting doubts on the findings of the Anderson report. If you require further evidence on the benefits of GM-free Crop Zones, please contact us by email at [email protected] or phone 0449 769 066.

We would greatly appreciate hearing from you as to whether or not you decide to engage in this consultation process.

Yours sincerely,

Donella Peters

APPENDIX SPECIAL COUNCIL 5.1C-8SEPTEMBER2020 PAGE 54 AGENDA ITEM SPECIAL COUNCIL 5.1.1 SUBMISSION #6 for Keep SA GM-free

Keep South Australia GM Free

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A Review of the Independent Review of the South Australian GM Food Crop Moratorium and Fourteen Alternative Findings

Prepared by Dr John Paull, March 2019

Abstract The present review of the Independent Review of the South Australian GM Food Crop Moratorium (Anderson, 2019) reveals that the so-called Independent Review is not independent at all and thus it falls at the first hurdle. Kym Anderson is a long term vocal advocate of genetically modified crops and has expressed such views regularly over the past two decades. The Independent Review was commissioned by the South Australian Minister for Primary Industries and Regional Development. There were 216 public submissions, of these, 78% (n=168) were for retaining the existing Moratorium, 18% (n=39) were for scrapping the Moratorium, and 4% (n=8) were undecided. 100% of the food available in Australian supermarkets is GM-free which mirrors the sentiments of Australian consumers, which are against GM-food; and Australian supermarkets are all aware of such sentiments. South Australia (SA) has a ‘clean and green’ image. This image serves SA well for food production, trade, tourism, education and migration. GMOs would damage SA’s clean and green and smart image and can thereby be economically detrimental to the state. The Independent Review proposes that GM canola is the sole candidate for uptake were the GM Moratorium to be scrapped. The GM canolas (Round-up ready, TT) proposed for SA are herbicide-dependent crops relying on regimes of multiple toxic herbicide applications. Glyphosate is a carcinogen and triazine is banned in Europe. These are chemicals that are dangerous to the health and wellbeing of animals, including humans, and the environment, and prescribing their use can be expected to increase SA’s health costs and future environmental clean-up costs. GM agriculture is an example of privatising the profits and socialising the costs. Australia is the world leader in organic agriculture and accounts for 51% of the world’s certified organic hectares, and, of this, South Australia is the leading organics state in Australia accounting for 40% of Australia’s certified organic hectares (and 20% of the world’s certified organic hectares). Organic produce sells at a price premium - usually in the range of 10% and 110% (compared to non-organic). This contrasts with GM canola which sells at a price penalty of 7%. These price premiums and price penalties reflect market sentiment - what the market wants and what the market does not want. The GM Moratorium has a social licence and is serving SA well and should be maintained on economic and social grounds. The Independent Review should be rejected.

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The Independent Review is not independent

The author of the Independent Review is a vocal, long term and consistent advocate and proponent of GM crops, dating back over two decades. His extreme views were known or should have been known to the South Australian Government at the time of the appointment of Kym Anderson as reviewer. The known partisanship will always cast a question mark over the credibility of the Independent Review - even before it was submitted.

The perceived bias and the vested interest of the so-called ‘independent reviewer’ in supporting two decades of his own published opinions and analyses should have been sufficient to exclude Kym Anderson from consideration as an ‘independent reviewer’ and, failing that, ought to have been sufficient cause for him to exclude himself.

The views of the Independent Review are reflected in previous publications of the so called ‘independent reviewer’, for example:

Anderson, K., & Nielsen, C. P. (2001). GMOs, Trade Policy, and Welfare in Rich and Poor Countries. In S. Maskus & J. D. Wilson (Eds.), Quantifying the Impact of Technical Barriers to Trade: Can it be Done? Ann Arbor, MI: University of Michigan Press. Anderson, K., & Jackson, L. A. (2004). GM Food Crop Technology: Implications for Sub-Saharan Africa. Centre for Economic Policy Research (CEPR), Discussion Paper No. 4490, 1-29. Anderson, K., Damania, R., & Jackson, L. A. (2004). Trade, Standards, and the Political Economy of Genetically Modified Food. World Bank Policy Research Working Paper, WPS 3395, 1-30. Anderson, K., Jackson, L. A., & Nielsen, C. P. (2005). Genetically Modified Rice Adoption: Implications for Welfare and Poverty Alleviation. Journal of Economic Integration, 20(4), 771-788.

Finding 1: The Independent Review is not independent at all. The Independent Review is written by a vocal and long term advocate of GMOs and GM-crops, and in addition it contains errors of fact from the outset (see Finding 2) and it should be disregarded in its entirety.

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The majority of submissions supported retaining the SA GM Moratorium

The Independent Review states that “Community attitudes to the moratorium were captured in the 216 submissions received by the Reviewer” (Anderson, 2019, p.xii).

Of 216 public submissions, 78% (n=168) were for retaining the existing Moratorium, 18% (n=39) were for scrapping the Moratorium, and 4% (n=8) were undecided (Anderson, 2019, p.xii) (see Figure 1 below).

Of these 216 submissions, only 45 appear on the PIRSA web site (pir.sa.gov.au). Of these selected 45 submissions made available on-the-web, the majority are undated. Of the 45 submissions made available on-the-web, 36% (n=16) appear to be for retaining the Moratorium, 60% (n=27) for scrapping it, and 4% (n=2) are indeterminate. This appears to be a biased selection of the submissions and without any declared rationale for that bias.

Despite the data that the Independent Review reports, the false claim is made therein that: “the majority of submissions … favour the immediate removal of South Australia’s moratorium on GM crop production and transport (Finding 2.3)” (Anderson, 2019, p.xii). This is a false and misleading claim which is entirely inconsistent with the data (see Figure 1 below).

Abandon Moratorium 18% Ambivalent 4%

Retain Moratorium 78%

Figure 1. There were 216 submissions to the Independent Review, of these, 78% (n=168) were for retaining the existing GM Moratorium, 18% (n=39) were for scrapping the GM Moratorium, and 4% (n=8) were undecided (author's graph; data source: Anderson, 2019).

Finding 2: The majority (78%) of submissions supported retaining the existing SA GM Moratorium. The Independent Review falsely reports the contrary.

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There are no GM foods on Australian supermarket shelves

In Australia, food with GM ingredients must be labelled as such. The result is that there are no such food items on Australian supermarket shelves (Figure 2).

This is a reflection of consumer sentiment in Australia - consumers do not want to buy or eat GM foods - they have been characterised as ‘frankenfoods’. It also reflects a recognition by Australian supermarket chains that a GM label on a food item would spell its death knell.

The consequence of this is that markets for GM produce must be sought overseas. GM foods are sold into markets that lack GM-labelling requirements, markets where the consumers are left in the dark regarding the provenance of ingredients. Why would SA consider facilitating such a deceitful trick on foreign consumers? There may be some economic karmic flow-back from pursuing such a route.

Non-GM 100%

Figure 2: The food offerings on Australian supermarket shelves are 100% non-GM.

Finding 3: Australian supermarkets do not stock GM-foods because they are aware that Australian consumers have rejected such ‘frankenfoods’.

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South Australia enjoys a clean and green image

SA enjoys an enviable reputation as a clean and green and smart place to be doing business. It has a reputation that many countries and regions around the world can admire and aspire to (Figure 3).

Figure 3: SA is known around the world for its clean and green and smart image (source: australiachinafriendship.com.au/south-australias-green-environment/).

Finding 4: South Australia enjoys a clean and green and smart image which is important for tourism, trade, investment, education and migration. The GM Moratorium supports the image of clean and green and smart, and scrapping the GM Moratorium would undermine that image and its economic benefits.

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Consumers of the world reject GM foods

There is no consumer demand for GM food. For consumers, GMOs are an unwanted intrusion into their diet and food selections, and GM offerings are to be avoided. This sentiment is not just prevalent amongst Australian consumers.

In the largest study of its kind, 23,000 consumers in 17 countries were quizzed about their food preferences. A consumer voice against GMOs was present in all 17 countries (GfK, 2017) (see Figure 4).

60% 60 Consumers seek GMO-free 49%49% 45%45% 45%45% 45 43%43% 41% 36% 37%37% 33% 31% 32% 30 28%

“GM-free is important” 15

0 UK Italy USA Brazil Spain China Japan Russia France Mexico Canada Belgium Australia Germany Argentina Netherlands South Korea

Figure 4: Percentage of consumers in 17 countries who stated that “GM-free is important” in making their food choices (author's graph; data source: GfK, 2017).

Finding 5: Around the world, there is strong consumer sentiment against GMO food. As a consequence, there are economic price penalties for GM crops and growing what consumers do not want.

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The price penalty for GM canola

The only GM crop that the Independent Review considers for uptake in SA is GM canola (Anderson, 2019).

GM canola attracts a price penalty (see Figure 5). The figures presented in the Independent Review (Fig.10, p.29) are a selection of the available data and are rather oddly attributed as “personal communication” (p.52) despite the prices being in the public domain and published regularly. The price penalty for GM canola is 7.2% (Figure 5). There is a consistent price penalty for WA GM canola, across years and grain depots (Taylor, 2019) (Figure 5).

AU$575 GM canola Albany GM canola Kwinana Non-GM canola Albany Non GM canola Kwinana

AU$550 non-GM canola

AU$525

AU$500

Price per tonne GM canola

AU$475

AU$450 2014/15 2015/16 2016/17 2017/18 2018/19

Figure 5: Average annual price per tonne of GM canola versus non-GM canola for grain delivered in WA (Kwinana and Albany) (author’s graph; data source: Taylor, 2019).

Finding 6: There is a price penalty for growing GM crops. The average price penalty for GM canola in WA is 7.2%.

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Australia is a minor player in GM agriculture

GM agriculture is dominated by just three countries, USA, Brazil and Argentina, which together account for 83% of the world’s GM agriculture hectares. Australia accounts for less than half of one percent of the world’s GM agriculture hectares (0.47%) (ISAAA, 2017). Australia is a very minor player in the world of GM agriculture (Figure 6).

This agrees with the data of the Independent Review which appear as Appendix 1 (Anderson, 2019, p.41).

Australia 0.5%

Rest 5% Pakistan 2% Paraguay 2%% India USA Argentina 6% 13% 42%

Brazil 28%

Figure 6: GM agriculture is concentrated in just three countries, USA, Brazil and Argentina, and Australia is a very minor GMO player (author's graph; data source: ISAAA, 2017).

Finding 7: GM agriculture is concentrated in just three countries, USA, Brazil and Argentina. Australia is a very minor player in the world of GM agriculture.

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Segregation is a failure

The Independent Review in its Finding 3.3 claims that “The experience of GM canola production and marketing in other mainland stages (sic) 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” (Anderson, 2019, p.21). This is wishful thinking.

Segregation of GM and non-GM crops has failed in Western Australia and elsewhere. Considerable evidence was presented to that effect to the WA Parliamentary Inquiry, Mechanisms for compensation for economic loss to farmers in Western Australia caused by contamination by genetically modified material (see: www.parliament.wa.gov.au/parliament/ commit.nsf; Swinbourne, 2019).

The WA Parliamentary Inquiry was convened because of the spectacular failure of GM segregation as witnessed in the Marsh v Baxter case. In that case an organic farm was contaminated with GM canola. The organic farm lost its organic certification because of the contamination. This resulted in economic losses of $85,000 to the organic farm, a figure that was agreed between the parties and which accounted for the price premiums for organic that were forfeited. The legal expenses for this case were in the order of $2 million (Paull, 2015). Such figures are outside the capacity of the average farmer to endure; it was eventually revealed that Monsanto was funding the GM farmer’s legal costs. The Marsh v Baxter case evidenced the failure of GM-segregation and the disproportionality of the damages suffered versus the legal-system costs of pursuing a claim.

Marsh v Baxter is not the only incident in WA where an organic farm has lost its certification due to GM contamination. However, as the WA Parliamentary Inquiry were at pains to point out in their questioning, there is a “chilling” impact of the Marsh v Baxter case in keeping contamination out of the public and legal gaze (www.parliament.wa.gov.au/parliament/ commit.nsf).

Witnesses to the WA Inquiry revealed that due to GM contamination of canola in WA, the response has been to redefine the grain grade of ‘non-GM’ so that, at least in WA, it no longer means ‘GM-free’, as might be expected, but rather it means something less. Since the introduction of GM canola into WA, the grade, ‘non-GM’, has been redefined to allow GM- contamination up to the level of 0.9% GM before it loses its ‘non-GM’ classification.

There is a price penalty in WA of downgrading produce to ‘GM’ of approximately 7.2%, hence this ‘work-around’ of re-defining terms. This ploy also facilitates a GM-contaminated batch of grain in WA being re-birthed as ‘non-GM’ by adding a sufficient dilution of GM-free grain to bring the contamination level down below the contamination threshold of 0.9%.

This is an unsatisfactory ‘work around’. A glass of milk contaminated to 0.9% with, for example, petrol, detergent, arsenic, iron filings or whatever is rather obviously unacceptable.

In Canada, the failure of segregation has meant that almost all canola in Canada is graded as GM. The Canada Canola Council then propagates the alchemic fiction that “canola oil made from GM seed is conventional canola oil” (CCC, 2017).

Finding 8: Segregation of GM and non-GM canola has failed in WA and overseas. This failure has been glossed over in WA by redefining ‘non-GM’ as GM-contaminated to an extent not exceeding 0.9%.

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Glyphosate is carcinogenic

GM Roundup Ready canola is dependent on multiple applications of the herbicide glyphosate. Multiple applications of this herbicide are prescribed to a single crop of GM canola, including a final dose close to harvest time when the crop is swathed (where the head of grain is decapitated from the body of the plant).

Glyphosate is a carcinogen (OEHHA, 2019). Glyphosate does not stay ‘on the farm’. It contaminates water, air, soil, plants and animals. It is ingested by adults and children via various routes including via food and beverages (Cook, 2019) (Figures 7 & 8).

A gardener was recently awarded US$289 million in damages for cancer caused from spraying glyphosate (Bellon, 2018). There are a further 9,300 plaintiffs reportedly seeking redress for glyphosate health damage and with more to come (Bender, 2018). 51 50 43 40 36

20 (ppb) in wines

10 5 5 Glyphosate concentration 0 Merlot Moscato Cab Sauvignon Argentina Organic US Organic Figure 7: Glyphosate in wine (author's graph; data source: Cook, 2019).

50 50

40 31 30 30 27 25 21 20 20 19 (ppb) in beers 10 6

Glyphosate concentration 0 0 Miller Coors Corona Guiness Tsingtao Heineken Budweiser Stella Artois Peak Organic Smith's Organic Figure 8: Glyphosate in beer (author's graph; data source: Cook, 2019).

Finding 9: GM RR canola is glyphosate dependent. Glyphosate is carcinogenic. More glyphosate means more cancer and that means more health costs for SA. Contaminated beer and wine can have negative economic consequences and damage exports. Glyphosate lawsuits can be an economic drain on the SA economy.

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Consumers don’t want pesticides

There is strong global consumer demand for organic food. For consumers, pesticides and GMOs are unwanted intrusions into their diet and food selections. Many consumers are aware that a sure way to avoid GMOs is to buy organic. Organic standards exclude GMOs. Such sentiments are not just prevalent amongst Australian consumers.

In the largest study of its kind, 23,000 consumers in 17 countries were quizzed about their food preferences. A consumer voice for organic and against GMOs was present in all 17 countries (GfK, 2017) (see Figures 4 and 9).

60% 58% 52% 49% 50% 46% 41% 42% 40% 36% 34% 35% 31% 28% 29%29% 30% 26% 27% 24% 22% 20% “Organic is important” 10%

0% UK Italy USA Brazil Spain China Japan Russia France Mexico Canada Belgium Australia Germany Argentina Netherlands South Korea

Figure 9: Percentage of consumers in 17 countries who stated that “Organic is important” in making their food choices (author's graph; data source: GfK, 2017).

Finding 10: Around the world, there is strong consumer sentiment for organic food (and against GM food). There are economic rewards for growing what consumers want.

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Australia leads the world in Organic Agriculture

Australia leads the world in organic agriculture (Paull & Hennig, 2016) (Figure 10). World organic agriculture has been growing at 12% per annum for the past two decades (Figure 11). Australia accounts for 51% of the world’s certified organic hectares (Willer & Lernoud, 2019). GMOs are a threat to organic agriculture, they are the ‘cane toads’ (invasive species) of clean and green agriculture (Paull, 2015, 2018).

Figure 10: World density-equalizing map of global organic agriculture (based on certified organic hectares per country) (Paull & Hennig, 2016). 70,000,000 ha

60,000,000 ha

50,000,000 ha

40,000,000 ha

30,000,000 ha

20,000,000 ha

10,000,000 ha World Certified Organic Agriculture Certified Organic World 0 ha 2011 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2012 2013 2014 2015 2016 2017 2018 2019 02.2000 08.2000

Figure 11: Global organic agriculture has been growing at 12% per annum for the past two decades (year reported) (author’s graph; data sources: Willer & Yussefi, 2000 to Willer & Lernoud, 2019).

Finding 11: Australia is the world leader in organic agriculture and accounts for 51% of the world’s certified organic hectares. This is a great agricultural and economic success story. GMOs put organics at existential and economic risk.

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Australian Organic Agriculture is growing at 22% per annum

In Australia, organic agriculture has been growing at 22% per annum (compounding) for the past five years (Figure 12). It is a great success story. World demand for organics continues to grow and the demand frequently outstrips supply.

China, Russia and India have recognised the value of producing food that consumers want to buy and for which consumers are willing to pay a premium. China has experienced its ‘organic revolution’ (Paull, 2007) and is now a major world exporter of organic food. Russia’s Vladimir Putin has recognised the massive economic, trade and environmental advantages for Russia in converting to organic and banning GMOs (RT, 2014, 2017a, 2017b). India has one whole state converted to 100% organic and at least another eleven states are looking to replicate this achievement (Paull, 2017).

40,000,000 ha

30,000,000 ha

20,000,000 ha

10,000,000 ha Australia Certified Organic Agriculture Australia Certified Organic

0 ha 2011 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2012 2013 2014 2015 2016 2017 2018 2019 2.2000 8.2000

Figure 12: Australia’s organic agriculture has been growing at 22% per annum (compounding) for the past five years (year reported) (author’s graph; data sources: Willer & Yussefi, 2000 to Willer & Lernoud, 2019).

Finding 12: Organic agriculture in Australia is growing at 22% per annum. This is a great agricultural and economic success story. To allow GMOs to put organics at risk for the sake of something that global consumers do not want would be economic stupidity.

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South Australia leads the country in Organic Agriculture

South Australia leads the country in organic agriculture (Paull & Hennig, 2018). Forty percent of Australia’s certified organic hectares is located in SA. The map of organics in Australia is dominated by the SA presence (Figure 13).

For the sake of producing some cheap GM canola it would be stupid to put South Australia’s organics success story at economic risk.

Figure 13: South Australia accounts for 40% of Australia’s organic hectares (Paull & Hennig, 2018).

Finding 13: South Australia leads the country in organic agriculture (based on certified organic hectares). This is a great agricultural and economic success story. Allowing GMOs in SA would put organics at existential and economic risk. That would be economically stupid given that here is a price premium for organic produce and an economic penalty for GMO produce.

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No Social Licence for GMOs

The majority (78%) of submissions to the Independent Review were in favour of maintaining the GM Moratorium. The Independent Review claims that “Community attitudes to the Moratorium were captured in the 216 submissions” and this is not disputed by the present author.

The conclusion to be drawn is that, on the available evidence, there is no social licence for scrapping SA’s existing GM Moratorium. The social licence is for maintaining the present GM Moratorium.

The SA GM Moratorium is consistent with the clean and green and smart image of SA (Figure 14). It would be foolhardy, contentious and socially disruptive to scrap the GM Moratorium, it would create uncertainty for the agriculture and food sector and would precipitate consumer, resident, trade buyer, and visitor push back with the attendant economic forfeits and costs.

SA Clean, Green and Smart

Figure 14: South Australia enjoys a clean and green and smart image.

Finding 14: There is no social licence for GMOs. The SA GM Moratorium is consistent with the clean and green and smart image of SA and warrants being maintained for its social, environmental, health, education, trade and economic benefits.

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Conclusions and findings

The Independent Review fails because it is not ‘independent’ as it claims but is rather a partisan document apparently constructed to support the pre-existing views of its author, views that have already been expressed over the past two decades and are blindly in favour of genetically modified organism crops (GMOs). The opinion of the present reviewer is that the author of the Independent Review ought to have properly stood down for reasons including his vested interest in maintaining and propagating his own long standing pro-GM viewpoints.

The Independent Review fails to report that the vast majority (78%) of submissions are strongly in favour of retaining the existing GM Moratorium in SA (the Independent Review erroneously claims the contrary result which is inconsistent with its own raw data). This front-end failure of the Independent Review casts a cloud over any and all of the claims from thereon, many of which are ambit claims that can not readily (or at all) be checked.

The Independent Review fails to evaluate the broad economic and societal impacts of the subject. Instead, the Independent Review takes a very narrow and blinkered productionist view. The Independent Review fails to acknowledge the fact that consumers of the world do not want GM food. The Independent Review glosses over the fact that GM farmers get hit with a price penalty for their GM produce when they take it to market, and so, despite self-serving multi-national hype , economically they start ‘behind the eight ball’.

The Independent Review makes no attempt to measure the negative economic impacts that scrapping the GM Moratorium would have on the clean and green and smart image of SA. The GM Moratorium is a point of difference for SA, a bragging point for SA, and it is a visible and a tangible validator of SA’s claim to being clean and green and smart.

The Independent Review is a partisan document which falls short of meeting its brief, and its findings deserve to be questioned, scrutinised and ultimately rejected.

The 14 findings of the present review follow:

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Finding 2: The majority (78%) of submissions supported retaining the existing SA GM Moratorium. The Independent Review falsely reports the contrary. Finding 3: Australian supermarkets do not stock GM-foods because they are aware that Australian consumers have rejected such ‘frankenfoods’.

Finding 5: Around the world, there is strong consumer sentiment against GMO food. As a consequence, there are economic price penalties for GM crops and growing what consumers do not want.

Finding 6: There is a price penalty for growing GM crops. The average price penalty for GM canola in WA is 7.2%.

Finding 7: GM agriculture is concentrated in just three countries, USA, Brazil and Argentina. Australia is a very minor player in the world of GM agriculture.

Finding 8: Segregation of GM and non-GM canola has failed in WA. This failure has been glossed over by redefining ‘non-GM’ as GM-contaminated to an extent not exceeding 0.9%.

Finding 10: Around the world, there is strong consumer sentiment for organic food (and against GM food). There are economic rewards for growing what is consumers want.

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References

Anderson, K. (2019). Independent Review of the South Australian GM Food Crop Moratorium. Adelaide: Report to the SA Minister for Primary Industries and Regional Developement. Bellon, T. (2018). Monsanto ordered to pay $289 million in world's first Roundup cancer trial. Reuters, August 11. Bender, R. (2018). Bayer hit by more lawsuits over safety of Roundup weedkiller. The Wall Street Journal, November 13. CCC. (2017). Canola: The Myths Debunked. Winnipeg: Canola Council of Canada (CCC). Cook, K. (2019). Glyphosate in Beer and Wine. Sacramento, CA: California Public Interest Research Group (CALPIRG) Education Fund. GfK. (2017). Decision Factors on What to Eat or Drink: Global GfK Survey (October 2017). London: GfK (Growth from Knowledge). ISAAA. (2017). Pocket K No.16: Biotech Crop Highlights in 2016. Manila: International Service for the Acquisition of Agri-biotech Applications (ISAAA). OEHHA. (2019). Glyphosate. Sacramento, CA: Office of Environmental Health Hazard Assessment (OEHHA), California Environmental Protection Agency (CalEPA). Paull, J. (2007). China's organic revolution. Journal of Organic Systems, 2(1), 1-11. Paull, J. (2015). The threat of genetically modified organisms (GMOs) to organic agriculture: A case study update. Agriculture & Food, 3, 56-63. Paull, J. (2017). Four new strategies to grow the organic agriculture sector. Agrofor International Journal, 2(3), 61-70.

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Paull, J. (2018). Genetically Modified Organisms (GMOs) as Invasive Species. Journal of Environment Protection and Sustainable Development, 4(3), 31-37. Paull, J., & Hennig, B. (2016). Atlas of Organics: Four maps of the world of organic agriculture. Journal of Organics, 3(1), 25-32. Paull, J., & Hennig, B. (2018). Maps of Organic Agriculture in Australia. Journal of Organics, 5(1), 29-39. RT. (2014). Duma seeks moratorium on GMO production in Russia. 26 February. Moscow: rt.com. RT. (2017a). Putin vows to make Russia major supplier of organic food to Asia-Pacific Region. 11 November. Moscow: rt.com. RT. (2017b). Russia looks to become leading organic food exporter as Europe sees future in GMO. 20 September. Moscow: rt.com. Swinbourne, M. (2019). Mechanisms for compensation for economic loss to farmers in Western Australia caused by contamination by genetically modified material. Perth: Standing Committee on Environment and Public Affairs, Parliament of Western Australia. Taylor, L. (2019). Average cash price for Can1 and Cag1 for each port zone (figures supplied). Perth: Daily Grain. Willer, H., & Lernoud, J. (Eds.). (2019). The World of Organic Agriculture: Statistics and Emerging Trends 2019: Frick, Switzerland: Research Institute of Organic Agriculture (FiBL) & Bonn: IFOAM-Organics International. Willer, H., & Yussefi, M. (Eds.). (2000). Organic Agriculture World-Wide: Statistics and Perspectives. Bad Durkheim, Germany: Stiftung Ökologie & Landbau (SÖL).

Dr John Paull March 2019 [email protected]

Submission for: GM Moratorium Report Consultation GPO Box 1671 Adelaide SA 5001 Email: [email protected]

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Davina Smythe

From: Cynthia Helbig Sent: Thursday, 2 July 2020 7:36 PM To: Light Regional Council Subject: Please ensure our region remains a GM-free Crop Zone

Dear Mayor and Councillors,

Please do everything you can to ensure that our Council area remains a GM-free Crop Zone. Losing our region's GM- free status, and reputation for high quality GM-free foods and beverages, will disrupt markets and deny us trade benefits.

I request council to embrace and promote the GM-free Crop Zone review process. Please resolve to:

• consider our council area remaining a GM-free Crop Zone;

• consult everyone in our community - including farmers and food processers;

• apply to the Minister for Primary Industries to remain a GM-free Crop Zone.

South Australia has an enviable reputation for high quality fresh produce, of which GM-free food is an important part.

A wide range of our industries rely on the state's clean, green image to market their products at a premium. Losing the GM crop moratorium risks our image and the economic benefits it provides locally and state-wide.

Most Australians are not comfortable with GM foods as a Swinburne University survey found in 2017.

Shoppers in our key export markets - Europe, Asia and the USA also prefer GM-free foods and beverages. The US grows over 40% per cent of all GM crops in the world but the community strongly opposes GM foods. They favour non-GM labelled products which are now among the fastest growing markets in the USA.

Our council has the opportunity to copy Kangaroo Island. KI remains GM-free to keep earning big premiums for their GM-free grains and beverages, in local and export markets.

A GM-free Crop Zone in our area is a chance too good to miss. Please do your best to ensure our region remains GM- free, for the benefit of everyone in our community.

1 APPENDIX SPECIAL COUNCIL 5.1C-8SEPTEMBER2020 PAGE 75 AGENDA ITEM SPECIAL COUNCIL 5.1.1 SUBMISSION #8

Yours sincerely,

Cynthia Helbig

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2 APPENDIX SPECIAL COUNCIL 5.1C-8SEPTEMBER2020 PAGE 76 AGENDA ITEM SPECIAL COUNCIL 5.1.1 SUBMISSION #10

PO Box 859 • Gawler • South Australia 5118 • Tel/Fax 08 8522 6450

Web: www.foodforest.com.au Email: [email protected]

ABN 32 825 934 985

Date: 4 Aug 2020

MEMO TO: Mayor and CEO

Re: Evidence re Council becoming a Non-Genetically Modified Crop area

x Until the end of September a council can request that the Minister for Primary Industries grant it a ban on the growing of GM crops in its particular area. x In assessing the request the Minister, David Basham, must take the view of the State's GM Advisory Committee into consideration, along with evidence from the council that there would be an advantage, in terms of trade and marketing for the Council area to be designated as a Non-GM crop area'. x It advised that a council would need a 'cogent basis' for not consulting with its community on the GM issue. It also clarified that a consultation would need to include members of the community generally and definitely include farmers, food processors and businesses, including those that may be outside the council area that use significant quantities of crops from the council area. x Data from world markets confirm that the market for Non-GM food and beverages is growing rapidly (>17%) x Surveys of populations worldwide show that most people do not want to consume GM food or beverages. (CSIRO showed only 7% of shoppers 'were unconcerned' about eating GM food), so supermarkets in Australia simply don't stock food labelled GM. x Data presented in the 2020 Department of Primary Industries Gross Margins &Enterprise Planning Guide, virtually a farmers 'bible' in terms of planning crops for the next season, shows clearly that GM Canola is significantly less profitable (in terms of gross margins over 5 years of data) than naturally bred cultivars, right across SA. A study in western Victoria also fund GM varieties had no yield advantage. x SA farmers could have lost $17M if they had all grown GM canola last year as a result of GM varieties' poorer yields and the penalty applied to GM varieties by the grain market. Daily prices on grain markets show certified Non-GM canola is commanding a premium of 12-19% over GM canola. GM seed also comes with agreements to use specific herbicides and charges for technology and stewardship agreements and a royalty on grain produced; all extra imposts on the farmers income. x Kangaroo island farmers are already receiving even higher contracted premiums for their Non-GM canola ($100 per tonne ie 19%) as well as premia for other grains and honey grown in a Non GM environment. x The University of Adelaide report into export opportunities for Non-GM products gives a realistic picture of future world market opportunities in which SA can play a part as one of the world's largest Non-GM land areas, including over 10 million hectares of certified organic land with farms in all regions of the State.

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Organic production nodes in South Australia

x The $900M meat industry in SA is underpinned by the massive beef and sheep stations in the outback whose products are naturally GM free. Their important export Non-GM status must not be compromised. x SA has a $7.6B tourist industry largely based on fine food and wine. 49% of tourists in SA specifically associate the State with food and wine. Culinary tourists outlay nearly 35-50% of all their expenditure on food and wine experiences. Italy found that the average culinary tourist spent almost EUR 200 per day higher than the EUR 55 per day that the average domestic tourist spent. The Eco-tourism market is growing rapidly and relates strongly to natural food experiences. There is now a sector specifically called 'organic tourism'. The fact that our councils have a commitment to NON-GM food will not be lost on our tourists x Large areas of NON-GM land will lessen the potential for intrusion of GM cultivars through transport, wind and insect pollination, movement of GM seeds in mulch and animal feed etc into vineyards parks, schools, farms and residential areas. They can act as super-weeds as they may be resistant to multiple herbicides and and sully the image of the wine industry, which has specifically banned GM vine varieties and yeasts, lest they do market damage to the > $2B annual income to SA . x Most consumers don’t think of GM in association with wine but they definitely do when it comes to a dining experience and they will almost certainly respond to an assurance that food and wine from your area is badged Non-GM. x It is predicted that the value of properties in Non-GM areas will comparatively rise in comparison with GM areas. Tasmania has been benefitting from this phenomenon with comfortably the highest land prices in Australia. x Local food producers and processors will stand to maintain and grow their markets with Non-GM kudos whether it is for smallgoods, beer, bread or gin. The restaurants in a Non-GM zone will have another discriminator on their side.

APPENDIX SPECIAL COUNCIL 5.1C-8SEPTEMBER2020 PAGE 78 AGENDA ITEM SPECIAL COUNCIL 5.1.1 SUBMISSION #10 x Farmers markets and major events bring visitors to wine areas and should be protected from GM intrusion. x It is predicted that a GM-free region will be of particular advantage to smaller food businesses, vineyards, wineries and farms; more-so than the big players who operate nationally. It will be something for locals to promote in both regional and individual marketing material, labels and websites...why would tourist go to another place when they can visit a GM-free region? x The loss of SA's overall clean, green image and the difficulty of assuring patrons of shops, restaurants and wineries that food is free of GM ingredients would likely cause higher costs and a lack of confidence in potential tourists , unless significant Non-GMCrop regions are declared. x Organic growers with neighbours growing GM may lose certification of all or part of their crops due to the proximity of GM crops. x Particular export markets are now requiring proof of Non-GM and there are now certifying organisations doing Non-GM certification across Australia (but this does put extra costs back onto the producer) x There is no legislation to handle problems caused by the commercial incompatibility of GM and Non-GM crops. The Marsh case in WA found that the organic grower was not entitled to any compensation for proven contamination of his land by a neighbouring crop. It is thus important to establish large contiguous areas of land that are Non-GM. x GM plants have been engineered to be resistant to pests , diseases or herbicides through , but weeds, pathogens and insects are all capable of mutation and, often quite quickly, find their way around the relatively simple mechanisms inserted by GM, because of the constant selective pressure (for adaptation) exerted by monoculture farming. eg Over 60 weeds are now resistant to Roundup x Growers are required to pay high prices for the seed of GM cultivars that have specific resistances or other qualities, but the base cultivar that was chosen to be 'modified', is often maladapted to the specific environmental conditions in which a farmer is growing the crop. Significant other fees also apply x Food businesses wanting to produce Non GM products will find ingredients more difficult to get or more expensive if GM is adopted more widely; on the other hand they will have more market access if they remain Non-GM. x Key users of grain in Australia will not use GM grain in their value adding processes eg San Remo, brewing companies etc x The segregation of GM crops from Non GM crops has been shown to fail regularly overseas and also in Australia. The Kangaroo Island Pure Grain farmers have established their own receival and transport chain to guarantee zero contamination x The Independent Parliamentary review of the release of GM crop cultivars into the environment pointed out more than 20 failures and obstacles in the Regulation of GM crops x The multi-million dollar Non-GM/Organic South Australian meat export market could be compromised by GM 'contamination' as livestock having eaten GM feed are disqualified from Certified Non-GM status in important domestic and export markets (not to mention dairy and grain crops) x More GM cultivars including cereals are planned for release into the environment, potentially threatening the status of South Australia's beer, malt, pasta, biscuits, flour and stockfeed. x There are many regional areas, counties etc that are Non-GM around the world; quite number in Spain, California, Belgium etc, so the business of maintaining a non GM council is a well trodden path. Adelaide Hills council has been Non-GM for some years.

There are serious question marks over the often-quoted Anderson and Mecardo reports which are regarded by most as political documents commissioned by the Government specifically to sell GM to the public and vanquish the calls for caution from medical scientists, grain market professionals, graziers, winemakers, food processors and environmental scientists.

x The conclusions reached are demonstrably wrong using the daily Canola price information available publicly and the PIRSA 2020 Farm Gross Margins publication.

APPENDIX SPECIAL COUNCIL 5.1C-8SEPTEMBER2020 PAGE 79 AGENDA ITEM SPECIAL COUNCIL 5.1.1 SUBMISSION #10 x An important consideration in deciding whether to apply for NON-GM crop area designation is that Kangaroo Island was granted Non GM status on the basis of advantages to trade and marketing. x The remit from the Government to demonstrate trade and marketing figures, by council, would suggest that farmers and food businesses, council by council, live in bubbles, and most metropolitan councils who do not grow crops, have nothing to do with the GM issue, yet they contain the exporters, accountants, chefs, machinery companies etc that make the primary production system work, so surely their councils should claim benefit from the relevant trade and marketing . We live in a sophisticated economic community where people from one council work in another and regularly change places of work and residence. The state has a common wealth which is shared and decisions made in one part of the system affect all the others. If so , how should the money saved by avoiding GM canola last year be accounted for?

Perhaps a blend of 'sharing some of the common wealth with other councils' and 'quantifying the benefits to crop growers and local communities' may provide the best measure. That way the suburban councils that were advantaged by a share of the savings can show reason to become NON-GMcrop areas along with other councils that have more direct contact with creating products of direct value to local growers, food businesses and rural communities I attach the Kangaroo Island letter to show how their council presented its case to stay GM-free

Given that becoming designated as Non-GMGrop area is a once-only opportunity and that there are clearly large trade and market risks for the councils embracing GM (and no quantifiable gains), it seems prudent for your council to apply for Non GM status by the end of September The concept of regions becoming Non-GM, with adjacent councils collaborating to form viable zones, will be considered by the government

I write as an individual, but I am a member of a group concerned about this GM situation. The group comprises Local Government councillors, agricultural technologists and researchers, grain crop experts, a nutritionist, epidemiologist, veterinary surgeon, real estate specialist, chef and people who have a deep knowledge of the history of GM crops in health, economic and community impacts. A number of the group are expert in the field of genetics.

I am happy to expand on the above and send further reference as required. I am also willing to address meetings to clarify this important issue

Yours sincerely

Graham Brookman

Joint Managing Director

0407771985

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APPENDIX SPECIAL COUNCIL 5.1C-8SEPTEMBER2020 PAGE 83 AGENDA ITEM SPECIAL COUNCIL 5.1.1 SUBMISSION #10

Davina Smythe

From: Brookman Food Forest Sent: Thursday, 13 August 2020 1:55 PM To: Craig Doyle Subject: RE: Genetically Modified Crops in the LRC area

ThanksfortheletterCraig Lookingatmarketinfo,RabobankhasjustreleasedareportconfirmingthatNonͲGMremainsthepreferredimport intoEuropeandthatthemarketforNonGMcanolaisexpectedtobeextremelystrongasaresultofrequirements forNonͲGMoilforhumanconsumptionandsustainablebiofuelinthemediumterm.Thismorethansupportsthe PIRSApricefiguresinthe2020GrossMarginspublicationandconfirmsthereasonsfortheconsistentlyhigherdaily grainpricesforNonͲGM. https://www.graincentral.com/uncategorized/australianͲwheatͲcanolaͲpoisedͲtoͲmakeͲupͲeuropeanͲexportͲ shortfallͲrabobank/ ItistimeforanindependenteconomicanalysisifalltheStateGovernmentisrelyingon,arethetradeandmarketing figuresintheAndersonandMecardoreportswhichareirrelevantintoday’smarketplace.Hopefullyagroupof councilscangettherealmarketsituationoutintheopensoinformeddecisionscanbemade cheers grahambrookman From: Craig Doyle [mailto:[email protected]] Sent: Thursday, 13 August 2020 11:58 AM To: [email protected] Subject: Genetically Modified Crops in the LRC area HiGraham, PleasefindattachedcorrespondenceinacknowledgementofandresponsetoyoureͲmailsof10July2020and4 August2020withrespecttotheabovementionedmatter. Bestregards, Craig CraigDoyle|GeneralManagerͲStrategy&Development

Email: [email protected] Phone:0885253200 Mobile:0418895481 Postal: POBox72,KapundaSA5373

Theinformationcontainedinthisemailisintendedonlyfortheuseoftheperson(s)towhomitisaddressedandmaybeconfidentialorcontain privilegedinformation.Ifyouarenottheintendedrecipientyouareherebynotifiedthatanyperusal,use,distribution,copyingordisclosureisstrictly prohibited.Ifyouhavereceivedthisemailinerror,pleaseimmediatelyadviseusbyreturnemailanddeletetheemailwithoutmakingacopy.The LightRegionalCounciladvisesthatinordertocomplywithitsobligationsundertheStateRecordsAct1997andtheFreedomofInformationAct1991, emailmessagessenttoorreceivedmaybemonitoredoraccessedbyCouncilstaffotherthantheintendedrecipient.Norepresentationismadethat theemailoranyattachment(s)isfreeofvirusesorotherdefects.Virusscanningisrecommendedandistheresponsibilityoftherecipient.

1 APPENDIX SPECIAL COUNCIL 5.1C-8SEPTEMBER2020 PAGE 84 AGENDA ITEM SPECIAL COUNCIL 5.1.1 SUBMISSION #12

Davina Smythe

From: Natasha Schubert Sent: Thursday, 23 July 2020 3:39 PM To: Light Regional Council Subject: Please ensure our region remains a GM-free Crop Zone

Dear Mayor and Councillors,

I request council to embrace and promote the GM-free Crop Zone review process. Please resolve to:

• consider our council area remaining a GM-free Crop Zone;

• consult everyone in our community - including farmers and food processers;

• apply to the Minister for Primary Industries to remain a GM-free Crop Zone.

South Australia has an enviable reputation for high quality fresh produce, of which GM-free food is an important part.

Most Australians are not comfortable with GM foods as a Swinburne University survey found in 2017.

Our council has the opportunity to copy Kangaroo Island. KI remains GM-free to keep earning big premiums for their GM-free grains and beverages, in local and export markets.

A GM-free Crop Zone in our area is a chance too good to miss. Please do your best to ensure our region remains GM- free, for the benefit of everyone in our community.

1 APPENDIX SPECIAL COUNCIL 5.1C-8SEPTEMBER2020 PAGE 85 AGENDA ITEM SPECIAL COUNCIL 5.1.1 SUBMISSION #12

Yours sincerely,

Natasha Schubert

______

This email was sent by Natasha Schubert via Do Gooder, a website that allows people to contact you regarding issues they consider important. In accordance with web protocol RFC 3834 we have set the FROM field of this email to our generic no-reply address at [email protected], however Natasha provided an email address ([email protected]) which we included in the REPLY-TO field.

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2 APPENDIX SPECIAL COUNCIL 5.1C-8SEPTEMBER2020 PAGE 86 AGENDA ITEM SPECIAL COUNCIL 5.1.1 SUBMISSION #13 Councilors of the Light Council 23/7/2020

I see the GM issue is up for a decision soon… Some of my thoughts below.

Last year (2019 season) local farmers managed to produce approximately 14 kilograms of cereal grain per millimeter of rainfall that had fallen for the year. Modern farming technology has allowed them to achieve this remarkable feat. Technology’s that includes machinery, pesticides, and new varieties of crop plants bred with the latest techniques. All brought together by farmers who care more for their land than any previous generations could.

I would like my clients to be able to grow the GM Safflower as is being grown in Victoria. This variety offers another choice of a break crop for rotational and weed/disease management. It also offers the community speciality industrial oil for commercial use which is not extracted from the earth so is more sustainable. For the future there are other technologies coming that I think the farmers of SA should have the choice of benefiting from as they emerge, these include long chain omega 3 oil producing Canola varieties which can replace wild caught sardines as a food resource for farmed Tuna. This should prove to be a benefit for the fishery, the environment and the economy. I'm not such a great supporter of the famous “Roundup Ready”® GM Canola, I think that it will need to have a big up-tic in yield against other varieties to get me interested against the fact that we already have a good proportion of growers with glyphosate resistant ryegrass and maybe Glyphosate resistance in other weeds. This is a problem that could be made worse with the proliferation of RR® canola. There is however a place for Roundup Ready® crops in the farming system to answer other specific problems with other weeds in conjunction with other measures already in use in the current farming methodology.

A recent study conducted by Mercado® has proven the oft quoted “positive economic impacts” of a non-GM production status in this state is unfounded. This supports a multitude of global studies that have been undertaken since the commercial release of the first GM crops over 30 years ago.

Viterra and other receival sites interstate already handle segregation between GM and non GM crops and so far I haven't heard of any problems in GM states but I agree we need to take due care and will need to know in advance of receival sites, segregations and marketing arrangements.

As an agronomist it will be hard to recommend varieties that haven't been tried and tested in SA so far and that we don't know whether we will have a market place for. There is not much time to go for planning for the 2020/2021 season. We also need to get a handle on what GM crops will be on offer to the farmers of SA. With this in mind we need to know an outcome fairly soon so that planning can be put in place for 2021 and training can be undertaken by industry participants such as me to make sure that GM varieties are appropriately managed in the rural sector.

Many other GM crops have shown great social and health benefits in the rest of the world, Golden Rice, BT Cotton, BT potatoes and GM corn. Have a look at the CIMMYT web site (https://www.cimmyt.org/) to learn a bit more about these crops and there benefit to the poor people of the world.

It seems that allowing GM crop production in SA will bring 99+% positives and 1-% negatives.

Regards

Chris Butler (LMCSS) (LMTC) Senior Agronomist Roseworthy Rural Supplies Pty Ltd Roseworthy, SA, 5371 0885 248 111 0428 826 552

APPENDIX SPECIAL COUNCIL 5.1C-8SEPTEMBER2020 PAGE 87 AGENDA ITEM SPECIAL COUNCIL 5.1.1 SUBMISSION #14

Davina Smythe

From: Annette Burmeister Sent: Wednesday, 29 July 2020 3:27 PM To: Light Regional Council Subject: Please ensure our region remains a GM-free Crop Zone

Follow Up Flag: Follow up Flag Status: Flagged

Dear Mayor and Councillors,

I request council to embrace and promote the GM-free Crop Zone review process. Please resolve to:

• consider our council area remaining a GM-free Crop Zone;

• consult everyone in our community - including farmers and food processers;

• apply to the Minister for Primary Industries to remain a GM-free Crop Zone.

South Australia has an enviable reputation for high quality fresh produce, of which GM-free food is an important part.

Most Australians are not comfortable with GM foods as a Swinburne University survey found in 2017.

Our council has the opportunity to copy Kangaroo Island. KI remains GM-free to keep earning big premiums for their GM-free grains and beverages, in local and export markets.

1 APPENDIX SPECIAL COUNCIL 5.1C-8SEPTEMBER2020 PAGE 88 AGENDA ITEM SPECIAL COUNCIL 5.1.1 SUBMISSION #14

A GM-free Crop Zone in our area is a chance too good to miss. Please do your best to ensure our region remains GM- free, for the benefit of everyone in our community.

Yours sincerely,

Annette Burmeister

______

This email was sent by Annette Burmeister via Do Gooder, a website that allows people to contact you regarding issues they consider important. In accordance with web protocol RFC 3834 we have set the FROM field of this email to our generic no-reply address at [email protected], however Annette provided an email address ([email protected]) which we included in the REPLY-TO field.

Please reply to Annette Burmeister at [email protected].

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2 APPENDIX SPECIAL COUNCIL 5.1C-8SEPTEMBER2020 PAGE 89 AGENDA ITEM SPECIAL COUNCIL 5.1.1 SUBMISSION #15

Davina Smythe

From: Stewart Janis Sent: Friday, 14 August 2020 10:32 AM To: Light Regional Council Subject: Re: Genetically Modified Crops in your area - Consultation

OnFri,14Aug2020at10:08am,LightRegionalCouncilwrote: Isupportthefarmingcommunityandthererighttofarmusinggmtechnology

1 APPENDIX SPECIAL COUNCIL 5.1C-8SEPTEMBER2020 PAGE 90 AGENDA ITEM SPECIAL COUNCIL 5.1.1 SUBMISSION #16

Davina Smythe

From: [email protected] Sent: Sunday, 16 August 2020 1:58 PM To: Light Regional Council Subject: GM Crop Debate

POBox3Wasleys5400 16.08.20. ToLightRegionalCouncil AsafarmerintheLightRegionalCouncilareaIamraisingtheissueofGMCrops. Asstatewedesperatelyneedtoembracetechnologytoensureourcontinuedadvancementinagriculture Intheseuncertaintimes.Aswellasforthefuturegenerationstosucceed.Wedon’twantillinformedidealists Todictatethefutureforourchildrenandgrandchildren. AsitisproventobesafeandeconomicallybeneficialtoAgriculture.OnethinghasbeenprovenwithCovid19 Weneedviableagricultureforourfuture. Thankyou. Yourssincerely MalcolmBubner Phone0438254013.

ThisemailhasbeencheckedforvirusesbyAvastantivirussoftware.

www.avast.com

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ͳǣȀȀǤǤǤǤȀ̴̴ȀȀ̴ȀͲͲͳͳȀ͵ͷͷ͹ͷͶȀ̴ ̴ ̴ʹͲͳͺǦ ͳͻ̴ ǤǢͶ ʹǣȀȀǤǤǤȀ̴̴ȀȀ̴ȀͲͲͲͻȀʹ͸ͷͲͺ͸Ȁ ̴ ̴͵̴ʹͲʹͲ̴ͺ͵ͲͶͳ̴͵Ǥ

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3https://pir.sa.gov.au/__data/assets/pdf_file/0011/357608/Gross_Margin_and_Enterprise_Planning_Guide_2020. pdf; pages 10 and 40-47 4 Wine Australia; Barossa Zone Export Report MAT March 2020 5 Ibid

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6 https://www.nielsen.com/us/en/insights/report/2018/unpacking-the-sustainability-landscape/ 7 Ibid 8 https://www.wineaustralia.com/market-insights/united-states 9 Ibid 10 Ibid 11 Wine Australia; Barossa Zone Export Report MAT March 2020 12 https://www.nielsen.com/us/en/insights/report/2018/unpacking-the-sustainability-landscape/ 13 Ibid 14 Ibid 15 Ibid 16 Ibid

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17 https://www.nielsen.com/au/en/insights/article/2019/finding-success-through-sustainability-aus/ 18 https://www.pir.sa.gov.au/__data/assets/pdf_file/0011/355754/Primary_Industries_Scorecard_2018- 19_FINAL.pdf; page 4 19 Ibid; page 7 20 https://pir.sa.gov.au/__data/assets/pdf_file/0009/265086/PIRSA_Grains_A3_2020_83041_3.pdf 21 https://pir.sa.gov.au/food_and_wine/toolkit/grains; para 1 22 https://pir.sa.gov.au/__data/assets/pdf_file/0009/265086/PIRSA_Grains_A3_2020_83041_3.pdf 23 Ibid 24 Ibid ʹͷhttps://www.pir.sa.gov.au/__data/assets/pdf_file/0011/355754/Primary_Industries_Scorecard_2018- 19_FINAL.pdf; page 4

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Davina Smythe

From: Monika Quattrocchi Sent: Thursday, 20 August 2020 12:13 PM To: Monika Quattrocchi Subject: Send to all Councillors and Mayor please-much appreciated. URGENT Attachments: Courier article re GM apples.pdf; monikas organics Gmo v's Non Gmo.doc; 2020Market Briefing for councils final.pdf

AttentionMayorandCouncillors PleaseseeattachmentofourAdelaideHillsareaforGMOͲPleaseengageinresponsetoGovtreGMOstatusofyour region.IbelievethiswillbeoneofthebiggestdecisionsrequiredbyCouncilandanextraordinaryoneatthat,and maybeadecisionyoubelievedoesnotinvolveyou..Thisisnotaroad,abusstop,wastedisposal(albeitimportant issuesalso)–ThisisaffectingourfoodsecurityforSAandsensitivefoodmarkets.WhathappensinSAisentirelyup toyou–regionbyregionͲdoesnotmatteriftherearenofarmsinyourregion.IfyousaynothingͲtheGovtwill declareonyourbehalfGMOacceptable.–YoucandeclareyourregionGMOfreestatus.IfSAgoesGMOwith canolaasyouseeinthearticlethegatesareopen,notonlyapplesandpearsBUTvinesandmuchmuchmoreto becomeGMOovertime.DestroyingourfoodintegrityandcontaminatingthelandwithGMOtoapointofno return.GMO’sarenotrequiredbylawtobelabelledonconsumeroranimalstockfooditems.Youwon’tevenknow youareeatingit.Pleasebepartofthebigpicture–AcollectiveapproachbyallcouncillorsofSAisurgently required. PleasereadAlex’s,Judy’sSimonresponsebelowtotheattachedarticlesenttothecourierͲSaysitall. IT’SYOURDECISION,OURFOODSECURITYISINYOURHANDS. Alexbelow IwasastonishedbythearticleinwhichtheCEOoftheAppleandPearGrowersAssociation wassupportingtheliftingoftheGMmoratorium. Shealsosaidthat"therewasverylittleevidenceforamarketingbenefitforgrowersthat remainGMͲfree." WhydoesshethinkthatTasmaniaiskeepingthewholestateGMͲfree,andissheaware thatTasmaniahasaverylucrativeapplegrowingindustry? ThereisnoevidencethatusingGMtechnologyinordertopatentvarietiesoffoodstaples, reducestheuseofchemicals.Infact,theoppositehashappenedwhenherbicideresistance hasoccurred. ManycountriesoverseasarebanningGMcropsduetocrossͲcontaminationandhealth concerns,andsomethathaveusedthetechnologiesarenowrevertingbacktotraditional practices. WhyisAustraliaalwayssofarbehindandwhydon'twelearnfromothers'mistakes? Thepowerofcorporationsoversomanylevelsofgovernanceinthiscountry,isdeeply concerning.

Judybelow People don’t want to eat GM organisms, so why is the Apple and Pear Growers Association so keen to grow fruit that their consumers don’t want to eat? There are currently no GM solutions to the problems that fruit growers face, and there are non-GM alternatives to the artic apple. Supporting the end of the GM moratorium will mean that farmers can grow GM crops near you that can be sprayed with dicamba without dying. Dicamba is notorious for drifting. In the USA, this resulted in huge damage to fruit trees and vineyards, even some distance away.

1 APPENDIX SPECIAL COUNCIL 5.1C-8SEPTEMBER2020 PAGE 99 AGENDA ITEM SPECIAL COUNCIL 5.1.1 SUBMISSION #18 Simonbelow OntheonehandwehavetheAppleandPearGrowersdoingPomefest,awonderfulideawhichwecanallembrace andhopefullygoto.Thensomeonethinksit'sagoodideatosupportGMmultinationalcorporationswiththeir profitbeforescienceattitudetoourlocalorchardists.I'llkeepbuyinglocalfruitfornowbuthonestly,I'llbuy TasmanianfruitifIhavetoavoidGM,atleastTassiehasthecouragetostandupandstayGMFree.

Regards Monika

Monika's Organics- From my Farm to Your Plate Mob: Monika Fiebig -0416 026 310 Mob: Daniel Quattrocchi- 0422 455 729 E: [email protected] www.monikasorganics.com.au

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APPENDIX SPECIAL COUNCIL 5.1C-8SEPTEMBER2020 PAGE 101 AGENDA ITEM SPECIAL COUNCIL 5.1.1 SUBMISSION #18 Monika Quattrocchi Lot 2 Strachan Road Golden Grove, SA 5125

Telephone: 8289 2877 Mobile: 0416 026 310 ABN: 92513129406 Email: [email protected]

To Mayor and Councillors

Re: Please ensure our region remains a GM-Free Crop Zone

Dear Mayor and Councillors

Why we are against GMOs and in favour of remaining a GM-free Crop Zone. In brief summary I will attempt to explain.

I am a certified organic grower of vegetables, wholesaler and distributer and have been in this industry for 21 years. We brand our items under the “Monikas Organics“ Brand and employ 18 people. We are the leading certified organic operator supplying major supermarkets in SA, WA, Northern Territory and Victoria with certified organic fruits and vegetables.

In the past I was a registered nurse for 23 years and a conventional/chemical grower of vegetables for 3 years so I have a good understanding of the use of human drugs and agricultural chemicals. I have been overseas to the USA, EU and UAE meeting growers and various people within the whole supply chain, specific to Horticulture. It is a known fact that there is a year on year increase in consumer demand for clean, natural foods, no chemicals, high animal welfare and farming methods that care for the environment – for which certified organic farms and food tick all the boxes.

It is a fact not only in South Australia where organics are an important category in major supermarket outlets but also nationally and globally where the demand for organic food is increasing. This is not a fad. It is increased consumer awareness and a hunger for clean natural foods that are not contaminated with synthetic chemicals or genetically manipulated traits that assists us to grow broad acre and vegetable crops with disease resistance and other desirable traits. Even the natural ways of selective breeding are not everlasting as plant diseases mutate and thus crop development processes must continue. Agricultural chemical formulas are constantly changing due to resistance, just as antibiotics are constantly changing due to antibiotic resistance.

So my question I raise with you is – Do you believe GM is the permanent solution to growing food crops that will be forever resistant to pests and diseases and are effectively herbicide tolerant to control weeds?

My answer is NO. Science says NO. There are no silver bullets or permanent answers in cropping systems. By going with the government’s determination to allow GMOs you will take away SA’s point of difference in the export markets for NON-GMO products which give us a competitive advantage in other states and overseas.

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Australia cannot feed the world but we have the capacity to provide premium products at premium prices, as we are servicing niche markets.

GMOs are very unpopular with many consumers, especially in European and some Asian countries where we can get priority access to sell our non-GM canola, grains, honey, and beverages. Kangaroo Island will remain GM-free precisely for this reason and the whole of SA could reap the same benefits if councils around the state also remain GM- free.

The USA has so much GM contamination in food production now that their organic industry has been forced set levels of allowable GM contamination, even though organic farmers do not use GM crops, because GMOs cannot be controlled, contained or segregated effectively. Once you say Yes to GM you can never turn back but we do not know the long-term effects on human health, the environment, markets or trade. The floodgates will be open for the big multinationals to introduce more and more GM crops and foods.

Whoever controls our seeds will control our food. South Australia has a precious point of difference in growing non-GM crops that gives us a marketing and trade edge which we should hold onto.

Holden closed down – Detroit USA owned this – Detroit made an economic decision to shut down in SA. They controlled this industry. They pulled out. What a huge economic loss and job losses. When we no longer control our seeds and our land is contaminated, it will be too late.

Being an organic grower, we make some of our own seeds and have control. We source our seeds from seed savers where we can, as GMO is not allowed at all in Australian organic systems. If you allow GMOs, there is the potential for GM corn, ryegrass, lucerne, apples, pears, grapevines, yeast, soybeans and even wheat to be approved in the future, and the list goes on. These would have dire consequences for our priority access to premium markets and trade.

Toxic crops, Toxic Land Most GM crops are either engineered to resist chemical herbicides, or to produce insecticides themselves. When herbicides are used on resistant crops, over time the weeds develop resistance, leading to the use of even more chemicals. Antibiotics used in animal production, developing superbugs that kill humans, are a similar example. Crops engineered to produce insecticides, on the other hand, produce toxins that are not only harmful to pests but other insects such as butterflies, moth and insect pollinators such as bees. It is well reported our issues and concerns about bee health and populations.

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Corporate Control GM crops are patented, which allows a few multinational companies such as Bayer, Syngenta, Corteva, BASF, and Nufarm to control the entire GM and chemical food chains - from research to breeding to commercialization of seeds. The multinational companies that patent and produce GMO seeds control the majority of the seed market and often also produce herbicides and fertilisers. Patenting genetic material has shifted the balance of economic power towards big business in their aggressive pursuit of profit. CropLife Australia’s sixteen corporate members represent 85 per cent of crop protection and 95 per cent of crop biotechnology products used by Australian farmers. https://www.croplife.org.au/about/our-members/

Environmental risk GMOs are a serious risk to the environment as their seeds travel well beyond fields where they are grown. Cross pollination and repeated spraying over GM crops can also create herbicide resistant “superweeds” that threaten other crops and wild plants. Scientists say GMOs have decimated the Monarch butterfly population In the United States. By the time we find out the long term impacts it could be too late to turn back.

Health and Safety Little is understood yet about the health effects of GMO's but recent studies have shown animals fed with GM containing feed can develop health problems. Safety studies on GM crops can be carried out by the same companies who produce them casting doubt on the quality and bias of data.

Remember when cigarettes were harmless Biotech companies use old “tobacco” science to argue GMOs are harmless or even beneficial to health yet nobody knows the long term effects. There have been reports of links to cancer, reproductive malfunction and digestive disorders. The drug Thalidomide used as a treatment of nausea in the 1950’s among pregnant women resulted in shortening or absence of limbs of many babies. Many drugs and agricultural chemicals have been banned due to health hazards. Yet present GM crops encourage their use. After being promoted as a wonderful chemical and widely used for many purposes, DDT was banned world-wide in 2001 due to the toxic and hazardous effects on human health, fauna and flora. There are many examples of chemicals being promoted as safe though the companies selling them knew they were dangerous, then being banned after being used for many years while profits were reaped and damage was done.

You may be asking why I am referring to issues that are not GMO. Improved technologies we can benefit from BUT sometimes we get it wrong. Sometimes we cross the line in the name of progress and in the name of profits.

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Hunger Multinationals promise that GMO’s will feed the world. But since they began to be grown and marketed two decades ago the number of starving people in the world has only grown, just like the profits of the companies that produced the seeds. In Australia we over produce for our needs and export premium food products into profitable markets. We are on the global map and highly recognised for this. We grow more than enough for our country and export all over the world, where we are known for our clean green farming systems. Please apply to the state government for this region to remain a GM-free Crop Zone so that our business and others like us can continue to supply premium markets and trade in our clean, green certified organic products without potential risks of GMO contamination and destroying our business. Yours sincerely,

Monika Quattrocchi Owner director – Monikas Organics.

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Davina Smythe

From: Julie Newman Sent: Saturday, 22 August 2020 3:23 AM To: [email protected] Subject: Genetically Modified Food Crops Area Attachments: Delivering_Market_Choice_with_GM_canola.pdf

InresponsetorequestsfromSAfarmers,Iamforwardingyourshireacopyofmyresponseforrequestre consultationprocessofCoorongDistrictCouncil–GeneticallyModifiedFoodCropsArea.Pleasecontactmeifyou requirereferencesorfurtherinput.Thankyou. Asalandowner,IreceivedarequestforevidenceofeconomiclossorgainretheMinisterTimWhetstonetryingto forcetheissuetolifttheGMmoratoriainSA. IhavebeenheavilyinvolvedintheGMdebateforover20years,andheavilyinvolvedintoplevelagriculturalpolitics inWAFarmersandGrainsCouncilofAustralia.ItisacomplexissueandIammorethanhappytoprovidefurther informationorreferencesifrequired. Governmentroles:CommonwealthGovernmentonlyassessesrisktohealthandtheenvironment,State Governmentsassessrisktoeconomics.TheMinisterforAgricultureholdstheportfolioforthepublicplantbreeders, sohasavestedinterestinpushingGMcropsinordertoprofitfromthepatentsinvolvedwithGM.Itappears MinisterWhetstoneistryingtopassthebucktotheShiresratherthantakeresponsibilityforhispoordecision.I wouldliketopointoutthatthedriveforGMcropsdoesnotcomefromfarmers,itcomesfromtheplantbreeding sectorwishingtoprofitinternationallyfromattractingcorporateinvestmentallianceswiththeAustralianplant breedinginstitutesthatareheavilyfundedbycompulsoryGRDClevies.BothGRDCandStateSAleviesmeantfor researchanddevelopment,nowfundthefarmlobbygroupswithaclearobjectivetopushtheR&Ddrivetoapprove GMinordertomakemoneyoutoffarmers,notforthem. WAStateEconomicAssessmentwithrecommendationtoretaintheGMmoratoriapriortochangeof Government:AttachedpleasefindacopyoftheWAGovernmentpreparationtoassesseconomics.Thiscross industrycommittee(ofwhichIwasamember)metmonthlyandwasChairedbyMinisterKimChancetodebatethe issuesofGMcanolapriortocommercialrelease.WithachangeofGovernment,thisreportwasignoredbyMinister Redman.Ofimportanceistheunfairliabilityissue,andtherealclaimthatfarmersareliableforanyGM contaminationandrecall.Note:

• “In2001theACCCmadeitclearthataGMͲfreeclaimleftnoroomforambiguityundertheTrade PracticesAct.”“ConfirmationfromtheAustralianCompetitionandConsumerCommissionhasbeen receivedstatingclearlythatnocontaminationwouldbeacceptableinproductusingGMfreeor nonͲGMlabels.”(pg32)

• “FSANZhassuccessfullyprosecutedaNZcompanyformisleadinglabelling.TheAucklandcompany BeanSupremewasfinedwhen0.0088%ofGMsoycontentwasfoundinvegetariansausages labelledaseither“GMͲfree”or“NonͲGM”.”(pg76)

• “GermanyandAustriaaretwoofasmallnumberofEuropeanUnionMemberStatesthathave legislationinplacethatstrictlyregulatepositiveclaimsfornonͲGMproductsandnodetectableGM contentisallowed.”(Pg32)

• CBHdeliverytermsandconditions4.1.10:“NoneoftheGraininadeliveryisageneticallymodified organism(unlessdeclaredinwritingto,andapprovedinwritingby,CBHbeforetheDeliveryenters thesite).”(pg31)

• “Duetothesecontractualobligationsandliabilitiesinvolved,itisessentialforfarmerstoknowthe GMcontentoftheirseedpriortodeliverytoavoidcostsandliabilities.Unfortunately,thereareno quantitivetestsavailableatthedeliverysites.”(pg31) 1 APPENDIX SPECIAL COUNCIL 5.1C-8SEPTEMBER2020 PAGE 110 AGENDA ITEM SPECIAL COUNCIL 5.1.1 SUBMISSION #19 • WHY0.9%THRESHOLD?“Therationaleforestablishingthresholdsisbecauseinadvertentpresence isconsideredunavoidable.”(pg33)

Oncommercialrelease,MonsantorewardedMinisterRedmanbypayingforashareinthepublicIntergrainplant breedingsector,butaccessedtheintellectualproperty,thensolditbacktoWA. KeythreatisGMwheatwhereSAcouldloseallwheatmarketsimmediatelyGMwheatiscommercialised.Itis essentialthatSAfarmersareawarethatliftingthemoratoriainSAismoretodowiththepotentialofbeingthefirst tocommerciallyreleaseGMwheat.ThereasonthatnoGMwheathasbeencommerciallygrownanywhereinthe worldisduetothemajorriskthatmarketssimplystopbuyinganywheatfromanyareathatisatriskof contamination.OnlyafewplantsthatescapedtrialsinUScostmillionsofdollarsinlostmarkets.Wheatisdifferent toGMcanolaasoilescapeslabellingbutmarketsdemandazerotolerancetoGMwheatorbarleyasapositivetest requiresaconsumerͲrejectedGMlabel.QuotefromSAReport:“Canolaisarelativelyminorcropinthisstate, however.Moresignificanteconomicallyarewheat,barley,pulsesandevenhay,nottomentiongrassesforpasture grazing,horticulturalcrops,andwinegrapes.Hencethebenefitsofremovingthestate’sGMmoratoriummaybefar greaterthanjustthosefromcanolaasnewGMvarietiesofothercrops(andpasturegrasses)ofrelevancetoSouth AustraliaaredevelopedandapprovedbytheOGTR(Finding4.7).(RefKymAnderson“IndependentReviewofthe SouthAustralianGMFoodCropMoratorium”,aReporttotheSAMinisterforPrimaryIndustriesandRegional Development,March2019.pgxvi).IftherewasabenefitinGMwheat,othercountrieswouldnotberefusingto accepttheeconomicriskassociatedwithit. WhatisGM?ItisasinglegenetechnologyandonlyinvolvesthetransferofafewgenesaddedtoanonͲGMplant DNAofaround100,000genes.Afterbillionsofdollarsofresearchoverthelast3decades,ithasachievedverylittle. ThemaintraitgrowncommerciallyissimplyresistancetoglyphosatethatcanbeachievedeasilybynonͲGMmeans asourweedsaredevelopingthistraitwithoutuswantingthemto. GMcanolabenefit?RoundupReadycanolaonlyhasthetraittomakethenonͲGMplantresistanttoglyphosate fromthe2Ͳ6leafstageoftheplant.ItdoesnotcontrolthemainweedsinAustraliathatgerminateafterthe6leaf stage.Canadianfarmershavetheircropsandweedssuppressedundersnowuntilitmeltssoisverydifferentto Australianconditions.Additionalchemicalsarerequiredtobeaddedpost6leafstage,plustocontrolthe subsequentgerminationsofglyphosateresistantcanola.Australianfarmershavelearntbyexperiencethatyields arenotimproved,inspiteofapromiseof30%increaseinyieldpriortocommercialrelease.Manyhaveexperienced loweryields.Themainfarmersthatgrowit,dosoastheyhaveresistanceissues,buttheOGTRaccepted Monsanto’sriskmanagementthatthesefarmerswouldnotbepermittedtogrowRoundupReadyastheyhavea highriskofweedsdevelopingresistancetoGlyphosate. Additionalcostsinclude:highseedcostsandinabilitytouseownseed,highendpointroyalties,extrachemicalsfor unwantedglyphosatetolerantvolunteercontrol,extradistanceforrestrictionsforstorageandhandling,extratime fortraining,contracts,reviewsetc. EvidenceforliftingtheGMmoratoriaisflawed:MinisterTimWhetstonereliedonmisleadinginformationprovided byKymAnderson“IndependentReviewoftheSouthAustralianGMFoodCropMoratorium”,aReporttotheSA MinisterforPrimaryIndustriesandRegionalDevelopment,March2019.Thisreportwaswithheldfromthegeneral public,butIhaverecentlyobtainedahardcopydirectly.Thisreportincorrectlyclaimedanflawedunbelievable $38/haadvantageforGMRoundupReadycanola(pgxii). PricePenaltyassociatedwithGMcanolaorGMcontaminatedcanola:TheSAreportclaimedonly5.2%price premiumfornonͲGM.Pgxiiiandxiv.However,pricepenaltiesforGMcanolahavefarexceededthatinWA. Attached,pleasefind“CBHcanolapremium”showing$50/tonnein2011.The2020pricepenaltiesassociatedwith GMcanolahasaveragedalmost$100/tonne(FarmWeekly). Thereisnoyieldbenefit:Theonly“benefit”ofGMRoundupReadycanolaisadifferentweedcontrol,notyield. Note,thatthetrialsinvestigatedbytheWAparliamentaryadvisorycommittee,foundthenonͲGMvarietiesdidnot receivetheweedcontrolthattheyshouldhavewhichwouldhaveskewedtheresults.TheSAreportclaimedayield benefitbasedona10%increasewhichisseriouslyflawedas,ratherthantakerealfarmingstats,itcomparedaGM yieldsinatrialinVictoria,withtheaverageyieldofnonͲGMvarietiesinSA.“ThegapinyieldsbetweenTTandRR

2 APPENDIX SPECIAL COUNCIL 5.1C-8SEPTEMBER2020 PAGE 111 AGENDA ITEM SPECIAL COUNCIL 5.1.1 SUBMISSION #19 canolaintheWimmeraregionofVictoriaduring2013Ͳ2017was10%(1.35vs1.5tonnesperhectare).However,in SouthAustraliatheaverageyieldfornonͲGMcanolaovertheperiodsincethemoratoriumwasimposedin2003is just1.20tonnes/hectare,makingthegapbetweenitandRR20%.Whenthatisassumed,thedifferencebetween thegrossmarginsforTTandRRbecomes$113/hectare,orthreetimesthebasecaseof$38.Thesecomparisons illustratethesensitivityofthegrossmargindifferencestoyieldgapassumptions.”Pgxiv. Afeebleattemptwasmadetoexplainwhysofewfarmersgrowit,butavoidedmarketissues“Seexiiifor explanationthatAustralianuptakehasbeenpoorbecausewehavehybridsthatincreaseyields,pluspricepenalty associatedwithGM.“Aswell,priceshavebeenslightlylowerforGMthannonͲGMcanolavarieties,yieldscurrently arenotmuchabovethebestofnonͲGMvarieties,thetechnologyaccessfeeforGMseedisconsideredbysome farmerstobehighandgrowersarewaryoftoomuchdependenceonRoundupandsoprefernottoplantRoundup Readycanolaineveryrotation.”Pgxiii Researchinterests,notfarmerinterests:Somequotesrevealingtheadvantageistotheplantbreeder,notthe farmer:FarmerfundedGRDChasfundedmillionsofdollarsonGMtodateandmoreisobviouslyrequired.Quote fromSAreport“Withoutapathtomarket,evenpublicresearchfunderssuchastheGrainsResearchand DevelopmentCorporation(GRDC)willnotinvestinpreͲcommercialresearch.”Pgxiii WhatbenefitforGM?TheSAreportevenclaimedapricepremiumforGM.“WeretheomegaͲ3varietyofGM canolatobecomeavailablefor2019plantingandtoattractahigherprice,theestimatedgrowmargindifference maybecomeconsiderablygreater:itrisestoabout$95/hectareiftheO3priceweretomatchthatfornonͲGM canola,andto$134/haifO3attractedapricepremiumof5%overnonͲGMcanola.Thesecomparisonsillustratethe sensitivityofthegrossmargindifferencestopriceassumptions.”Pgxiv CaseStudy:OmegaͲ3GMcanolahasbeentoutedasthemajorbenefitachievedinGMcanolatodate.Australian farmersaretheprimaryfunders(throughcompulsorylevies)ofGRDCwhoinitiallypaidover$8mtoproducethis GMcanolawithanexpectationtobeavailabletoAustralianfarmersin2017/18.Afurther$4,963,024.80waspaid byGRDCin2017foraCSIROOmega3canolacollaborativeresearchproject.(Ref:ListofGRDCfunding: https://grdc.com.au/__data/assets/pdf_file/0028/367642/RDͲandͲEͲoverͲ100kͲAugustͲFYͲ2017Ͳ18.pdf).Theresult wastheresearchsectorpartneringwithNuseedstomarketthecanola.Whereisit?ItisnotgrowninAustraliaorby thefarmersthatpaidforitsdevelopment.ItisgrownbyAmericanfarmersandNuseedshavebigplanstoprofit fromCanadianfarmersasitiscommerciallyreleased.https://nuseed.com/au/omegaͲ3/.Plantbreedersare certainlyputtingtheirinterestswellaheadoffarmersinterests. FarmLobbyGroups:FarmerssignificantlyfundGRDCplusStateleviestosupportResearchandDevelopmentbut theseleviesareusedtofundfarmlobbygroupsthatareinalliancewiththeplantbreedingsector.Thisisagainstthe legalrequirementofleviesandshouldbecorrected. Furtherreferencescanbesupplied.SAReportquotesfrom:KymAnderson,ReporttotheSAMinisterforPrimary IndustriesandRegionalDevelopment,“IndependentReviewoftheSouthAustralianGMFoodCropMoratorium, March2019”.ObtainedbymailfromHonTimWhetstoneMP,MinisterforPrimaryIndustriesandRegional Development,17thJune,2020. Pleasedonothesitatetocallmeasthisdebateisdifficulttosummariseinashortdocument. Regards, JulieNewman Phone0427711644

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An industry report prepared under the Single Vision Grains Australia process

>>>Delivering market choice with GM canola

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APPENDIX SPECIAL COUNCIL 5.1C-8SEPTEMBER2020 PAGE 114 AGENDA ITEM SPECIAL COUNCIL 5.1.1 SUBMISSION #19 <<< Executive Summary

The Australian grains industry has the capacity to deliver and manage the commercial introduction of Genetically Modiﬁed (GM) canola.

The principles underpinning the canola, and is now ready to commercialisation of GM canola incorporate approved GM are that it will be introduced in a varieties into the supply chain. manner that: The industry considers that the commercialisation of approved > Maintains or enhances trade GM canola should proceed in Australian canola without further delay. > Enables market choice along Major Australian grains industry the supply chain stakeholders have agreed that > Is open and transparent Australia is now ready to adopt GM canola, and are committed > Provides conﬁdence to all as demonstrated by their stakeholders, particularly to endorsement of this document to customers, consumers and deliver market choice. governments. Accordingly, the Australian grains The capacity for implementation industry urges governments to will be provided by industry recognise the grains industry’s stewardship programs, ability and commitment, and to commercial practises, support the commercialisation of processes and protocols which approved GM canola in Australia. address the marketing and technical requirements, the import/export processes and the supply chain mechanisms. These measures will provide the necessary certainty and conﬁdence to supply chain participants, consumers and governments that GM canola and its products will be managed to meet market and customer requirements. Importantly, these measures will also provide market choice. Two types of herbicide tolerant GM canola were approved by the Gene Technology Regulator in Australia in 2003, however, commercialisation has been prevented through the implementation of moratoria by state governments. Since this time, the Australian grains industry has reviewed the market requirements for GM

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<<< Introduction

There is broad recognition within the Australian grains industry that gene technology has the potential to play a major role in meeting the demands of food, feed and industrial consumers and that the industry requires competitive access to this technology in which it has made a signiﬁcant investment.

The environmental, economic and The capacity to deliver social benefits provided by GM market choice is built on the crops, and the need to meet the comprehensive and world-class rapidly increasing international protocols and processes that demand for food, feed, fuel already operate in the Australian and fibre, have resulted in their grains industry to enable incorporation into a range of grains and grain products to farming systems and supply chains meet regulatory and customer to consumers around the world. specifications, and provide confidence to consumers In 2006, 10.3 million farmers in and governments. 22 countries grew GM crops. By 2015, this is expected to The principles underpinning the increase to 20 million farmers in 40 commercialisation of GM canola countries. Corn, soybean, cotton are that it will be introduced in a and canola comprise the top four manner that: GM commodities globally. Over 85 > Maintains or enhances trade per cent of the Canadian canola in Australian canola crop is now sown to GM varieties and these have been marketed > Enables market choice along successfully for over a decade. the supply chain Since the advent of state-based > Is open and transparent moratoria in 2003, the Australian > Provides confidence to all grains supply chain has stakeholders, particularly to examined and identified supply customers, consumers and chain management processes to governments. manage GM canola. This document outlines the grains Current industry stakeholder industry’s capacity to deliver attitudes, requirements, technical and manage the commercial processes and commercial introduction of GM canola. preparedness were identified as part of a grains industry project undertaken by Single Vision Grains Australia (SVGA) during 2006-07. Analysis found that the majority of stakeholders support the introduction of GM canola, and are ready to manage its commercialisation. This position was reinforced along the supply chain including technology developers, the seed industry, farmers, transport organisations, handling and storage facility operators, marketers and processors.

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APPENDIX SPECIAL COUNCIL 5.1C-8SEPTEMBER2020 PAGE 117 AGENDA ITEM SPECIAL COUNCIL 5.1.1 SUBMISSION #19 >>> Market choice – the requirements

The grains industry has assessed the market requirements for GM canola prior to commercialisation proceeding.

There are three key elements in In addition, five market choice the delivery of market choice: criteria have been developed to evaluate GM canola against, to > the ability of any supply chain provide assurance that the GM participant to source product canola meets the requirements that meets a pre-determined for market choice: set of specifications > GM canola varieties approved > the ability of any supply chain by the Office of the Gene participant to supply product Technology Regulator that meets a pre-determined set of specifications > Market segments and supply chain logistics identified to > the ability of any supply gain understanding of their chain participant to manage requirements their area of the production, processing, manufacturing > Approval for food and feed and delivery of product to importation and consumption a pre-determined set of in customer countries specifications. identified The work undertaken through > Adventitious presence (AP) SVGA confirms the grains thresholds for the unintended industry supply chain’s ability presence of approved GM to deliver these market choice events, both in Australia requirements through the and in importing countries combination of commercial for contractual or labelling protocols, processes and purposes, are established (if practices that are either already required) in place, or are ready to be put in > Supply chain ability to place (Attachment 1). provide product traceability, The implementation of these verification and contingency supply chain systems provide plans. the capacity for industry to maintain or enhance trade in Australian grains and their products, and operate in an open and transparent manner. They will also provide confidence to all stakeholders, particularly to customers, consumers and governments.

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APPENDIX SPECIAL COUNCIL 5.1C-8SEPTEMBER2020 PAGE 118 AGENDA ITEM SPECIAL COUNCIL 5.1.1 SUBMISSION #19 <<< GM canola – meeting the criteria

The Australian grains industry has assessed the two types of approved GM canola varieties against the market choice criteria, and as they are met, agrees that planning for the commercialisation of the approved GM canola varieties can commence for the 2008 planting season.

Approved GM canola will be another product within the grains MARKET CHOICE CRITERIA – GM CANOLA industry supply chain that will Step Action Status be managed according to pre- determined customer and/or Australian regulatory approval gained regulatory speciﬁcations. 1 GM canola varieties were approved by the OGTR in 2003 9 In recent years, the Australian grains industry has demonstrated Market requirements identiﬁed its capacity to manage canola, 2 Need for segregation to meet the various requirements 9 including GM canola, to meet of domestic and international consumers customer and consumer Threshold levels established demands. Two examples are: • Australian AP thresholds have been established for > Specialist varieties - the the presence of GM traits in canola at 0.5% for seed canola industry supply chain 3 (Australian Seed Federation) and 0.9% for grain in Australia already routinely (NACMA CSO1 Canola standard) 9 produces and handles specialist canola varieties • AP thresholds established in key trading partners, and products, for example such as Japan (5%) and Europe (0.9%) – for high oleic and erucic canola. contractual or labelling purposes These products are kept Importing market approvals in place separate from other specialist 4 GM canola varieties have approvals in key importing and conventional canola countries 9 varieties to maintain their integrity and market value Supply chain processes to meet market requirements of both segregations. The 5 Protocols available to segregate throughout the supply chain (Attachment I) 9 industry has developed and now manages the supply chain infrastructure and handling systems that ensure > GM canola importation - the identity preservation of Australian canola processors the varieties from producer to imported GM canola from processor and consumer, with Canada in December 2006, no impact on other supply to overcome domestic chain participants. shortages. This GM canola was handled through the existing canola industry supply chain infrastructure, from port to processor and consumer. The requirements of all market participants (both canola oil and meal) were met and the effectiveness of the supply chain in providing choice and access was demonstrated.

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APPENDIX SPECIAL COUNCIL 5.1C-8SEPTEMBER2020 PAGE 119 AGENDA ITEM SPECIAL COUNCIL 5.1.1 SUBMISSION #19 >>> Industry ability to deliver market choice

Globally, agricultural commodities are being increasingly differentiated in response to a range of drivers – product safety, consumer preference, product traits, process traits, and government regulation.

The Australian grains industry’s specifications and regulatory Australian Oilseeds Federation supply chains are flexible and requirements at critical points codes of practice, the NACMA have the required capacity for along the supply chain. professional development (training existing or new processes to: and accreditation) program and The quality management other support programs. > enable GM grains to co-exist procedures in place vary from formal systems such as those Commercial contractual > use a semi-integrated system, based on Hazard Analysis arrangements underpin or Critical Control Point (HACCP) supply chain operations and > provide separate supply and International Organization management. NACMA contracts chains and infrastructure. of Standardization (ISO) through and trade rules are the accepted to proprietary systems, industry and recognised basis for The grains supply chain already codes of practices and best facilitating commercial grain has protocols, processes and agricultural or manufacturing trading activity. The NACMA practices available to deliver practice. The focus on quality contracts and trade rules will market choice. Currently, these management through the be utilised in the trading of processes are applied in the supply chain ensures that GM canola. In addition, there growing, transporting, marketing the requirements of suppliers are established contractual and processing of special and receivers are understood procedures between storage malting barley, noodle wheat, and met, and form part of the and handling operators and canola, sunflower and maize verification process. marketers, between transport varieties in Australia. An agreed operators and industry and comprehensive dataset of The industry has a range of participants, and in relation to measurable standards to specify stewardship programs and codes GM canola there will be contracts varietal quality characteristics and of practice or conduct in place between technology developers, parameters is applied along the or which can be introduced for seed companies and growers. supply chain as the basis of trade. commercial production of GM These contractual arrangements canola. These enable sharing The supply chain management articulate the responsibilities of relevant information and processes are driven by and obligations of the respective consultation for the seamless standards, quality management parties and provide a basis for movement of product into and procedures, stewardship recourse in the event of non- along the supply chain and, programs and commercial compliance or breach of contract. where and when appropriate, the contractual arrangements. management of non-compliance. These support the trade of Examples of these include the grain to meet pre-determined Australian Seed Federation and industry standards, customer

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APPENDIX SPECIAL COUNCIL 5.1C-8SEPTEMBER2020 PAGE 120 AGENDA ITEM SPECIAL COUNCIL 5.1.1 SUBMISSION #19 <<< Market choice – strong industry support

The Australian grains industry has relied on the adoption of innovation to secure its global competitiveness. The industry needs access to technology to remain at the forefront.

GM crops have been grown for The Australian grain industry is over a decade around the world ready to move ahead with the and numerous studies have commercialisation of the two proven the beneﬁts derived from types of approved GM canola these new varieties along and without further delay. beyond grain supply chains. The industry urges governments The Australian grain industry’s to recognise the grains industry’s estimated gross value of ability and commitment, and to production in 2005-06 was support the commercialisation of $8,613 million from 43,042,000 the approved GM canola tonnes of summer and winter in Australia. crops. Australia has a strong global reputation of delivering quality grain products that meet customer speciﬁcations and a solid track-record of ensuring that the requirements of both domestic and export customers are met. The industry recognises that not all supply chain participants may choose to adopt GM canola, and hence, the supply chain must be in a position to offer and provide choice at all times in order to maximise opportunities for all supply chain participants.

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APPENDIX SPECIAL COUNCIL 5.1C-8SEPTEMBER2020 PAGE 122 AGENDA ITEM SPECIAL COUNCIL 5.1.1 SUBMISSION #19 <<< Grains industry endorsement

Mr Michael Iwaniw Mr Rob Hall Mr Tom Keene Managing Director, General Manager - BioScience Managing Director, ABB Bayer CropScience Graincorp

Mr Lyndon Pfeffer Mr Robert Green Mr Dan Mangelsdorf Agforce Grains President General Manager - Commercial Chairman, Strategy and Business Development, Grain Growers Association Cargill

Mr Joe Di Leo Mr Imre Mencshelyi Mr Peter Reading Managing Director, Chief Executive Ofﬁcer, Managing Director, Allied Mills CBH Grains Research and Development Corporation

Mr Robert Green Ms Paula Matthewson Mr Graeme Lukey Chairman, Chief Executive Ofﬁcer, Executive Director, Australian Oilseeds Federation CropLife Australia Flour Millers’ Council of Australia

Mr Chris Melham Mr Murray Jones Mr Jose Manuel Madero Chief Executive Ofﬁcer, President, Managing Director, Australian Seed Federation Grains Council of Australia Monsanto Australia Limited

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Mr Geoff Honey Mr Keith Glasson Chief Executive Ofﬁcer, Managing Director, NACMA Pioneer Hi-Bred Australia Pty Ltd

Mr Jock Laurie Mr Chris Morkane President, Group GM Director, NSW Farmers’ Association Riverland Oilseeds

Mr Doug Rathbone Mr Brett Roberts Managing Director, Chair, Nufarm Limited Grains Council, South Australian Farmers’ Federation

Mr Chris Bazley Mr Simon Ramsay Managing Director, President, Paciﬁc Seeds Pty Ltd Victorian Farmers’ Federation

Mr Leon Bradley Mr Derek Clauson Chairman, President, PGA Western Graingrowers Grains Section, WA Farmers’

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APPENDIX SPECIAL COUNCIL 5.1C-8SEPTEMBER2020 PAGE 124 AGENDA ITEM SPECIAL COUNCIL 5.1.1 SUBMISSION #19 <<< Other endorsements

The following organisations are not direct members of the grains supply chain, however, they recognise that the Australian grain industry is ready to move ahead with the commercialisation of approved GM canola and support market choice.

Professor John Lovett Mr Dick Wells Mr Ben Fargher Chairman Chief Executive Ofﬁcer Chief Executive Ofﬁcer Agrifood Awareness Australia Limited Australian Food and Grocery Council National Farmers’ Federation

Dr Anna Lavelle Chief Executive Ofﬁcer AusBiotech

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<<< Attachment 1

A summary of the Australian grain industry protocols and processes. For further detail refer to “Principles for process management of grain within the Australian supply chain - a guide for industry in an environment where GM and non-GM grain is marketed”.

TECHNOLOGY AND VARIETY DEVELOPMENT

Objective: To develop and supply approved varieties of GM canola

Activity managed: Protocols met: Processes:

Genetic purity of • Ofﬁce of Gene Technology Regulator, • Activity complies with OGTR licence and breeders’ varieties Licence for Dealings Involving an Intentional requirements 1,2 and cultivar descrip- Release of GMs into the Environment • Imported material covered by AQIS declaration tion • Internal Quality Assurance Systems and and meets industry standards, is approved Identity Preservation procedures2 by the OGTR and it does not contain any • Australian Seed Federation National Code of unapproved events Practice for Seed Labelling and Marketing3 • Testing occurs depending on origin of materials

Assessing new varieties • OGTR license requirements1,2 • Traits are researched and assessed against for Australian conditions • Agricultural Pesticides and Veterinary standards and release of variety to Medicines Authority Act, approval to use • Comply with APVMA and label requirements seed growers herbicide4

Intellectual Property • Granting of technology license from technology • Commercial license agreement developer to a seed company licensee • Activities comply with legislative • Commonwealth of Australia Plant Breeder’s requirements Rights Act 19945 • Commonwealth of Australia Patents Act 19906

SEED INCREASE

Objective: To increase seed stocks of selected approved GM canola varieties from technology developers, conduct ﬁeld-trial evaluation and deliver proven variety seed to commercial seed-growers to increase seed for sale

Activity managed: Protocols met: Processes:

Breeding of seed in • OGTR licenses are required for breeding • Varieties and their characteristics are identiﬁed nurseries nurseries and labelled, products from nurseries do not • Breeder supervises nursery enter the commercial grain trade • Documented procedures and actions • Field trials are contained in small plots, harvested seed screened • All actions according to documented procedure

National variety trials• Testing for GM status of each seedlot entering • Varieties that have passed all tests are trials8 in previous breeder seed generation distributed to NVT for evaluation • The national variety trial framework is used • Varieties grown are identiﬁed and labelled • Varieties are grown under ASF Best Practice • Harvested seed disposed of according to Guidelines7 protocols • Documented procedures to maintain product integrity

Variety commercialisation• Varieties are grown under ASF Best • Varieties and stock are identiﬁed, labelled Practice Guidelines7 and tested for GM status • Each lot of breeder’s seed to be • Inventory control commercialised is tested for GM status • Market approval granted

Basic (foundation) seed • Varieties grown under ASF Best Practice • Grower may need to comply with contractual increase Guidelines7 arrangement with Technology Provider • Each lot of grower line of basic (foundation) • Varieties are identified, labelled, tested and seed traceable via limited generation system accompanied by a test certificate to confirm to breeder seed of confirmed GM status their GM status • Documented procedures to maintain product • Inventory control integrity • All actions according to documented procedure

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ON-FARM PRODUCTION

Objective: To grow and deliver canola to the range of market speciﬁcations

Activity managed: Protocols: Processes:

Purchasing, receiving, • Contractual agreement between seed • Grain growers may operate under storing and treating company (technology licensee) and grower contractual terms and conditions prior to seed prior to planting may be required which cover: gaining access to GM seed • Commercial terms — Regulatory requirements (OGTR and • Grain growers use crop and field APVMA) management plans as basis of crop — Technology requirements (eg crop and planning, management and operations field management plans, stewardship protocols) • The ASF code of practice for seed labelling • Seed is accompanied by a label statement of and marketing, the ASF seed certification GM status, origin and quality; seed stored to scheme3,7 maintain identity and integrity • The ASF national code of practice for seed • Seed treatments as required treatments9 • All actions according to documented • Documented procedures to maintain procedure product integrity

Planting seed• Contractual agreement between seed • Crop planting in compliance with any crop company and grower and ﬁeld management plans or contractual • Documented procedures and actions arrangements • All actions according to documented procedure

Crop Management • Contractual agreement between seed • Crop production in compliance with any crop company and grower and ﬁeld management plans or contractual • Quality systems, and legislative and market arrangements requirements • Crop management complies with quality, • Documented procedures and actions regulatory and market requirements where applicable, including monitoring • All actions according to documented procedure

Harvest • Contractual agreement between seed • Harvest planned and conducted in company and grower compliance with crop and ﬁeld management • Harvesting, transport and storage plans and stewardship protocols equipment to standard; contractors • Equipment inspection and clean-down; controlled contractors provide attestation to • Documented procedures and actions compliance; grain samples kept where relevant; stock control • All actions according to documented procedure

Delivery to storage • Customer, NACMA and AOF standards 10,11 • Harvested grain quality to customer • Vendor declarations10 standards • Contractual agreement between seed • Complete vendor declaration and instruction company and grower documentation; grower monitors contractors • Documented procedures and actions • Delivery to storage in compliance with crop and ﬁeld management plans • All actions according to documented procedure

14<<< Delivering market choice with GM canola

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ACCUMULATION & STORAGE

Objective: To accumulate, sample, classify and store grain delivered by growers according to industry standards

Activity managed: Protocols: Processes:

Grain receival, storage • Receival points for canola • BHC and private storage agents notify industry of and consolidation declared at pre-harvest meetings canola receival points and delivery requirements as held by bulk handling companies part of standard practice; prior to receival, storage (BHC) & private storage agents operators confirm canola storage requirements and and via media and direct mail capacity with end-users campaigns • Standard industry practices for delivery and handling • Receival agent storage and • Receival depot operator checks documentation of handling agreement each delivery parcel; consistent declaration through • Vendor declaration industry • Grain classified to NACMA, AOF • Sampling, testing and classification to AOF and buyer standards10, 11 standards and buyer requirements at receival; samplers and handlers trained in and comply with receival procedures and standards according to QA guidelines • Grain receival, segregation, storage, movement, stock control and documentation according to classification • Grain stored per industry and NACMA, AOF, BHC, private storage agent and standards and QA procedures12 end-buyer standards and requirements • Clean-down procedures to industry standards and requirements where required • Sampling and testing may occur in storage and on out-turn • Documentation attesting to quality and integrity • Documented procedures and of grain provided to transporters for end-buyer actions assurance; records maintained

GRAIN OUT-TURN

Objective: To out-load canola from storage facilities and transport it to domestic and/or export markets

Activity managed: Protocols: Processes:

Grain parcel •Inventory control • Documented procedures and QA systems used to meet identiﬁcation and procedures and QA customer order by identifying and physically inspecting management pre- systems12 grain, managing movement of grain parcels within storage loading facility, obtaining and retaining samples, supervising loading, providing documentation attesting to grain parcel quality, status and integrity. Documentation travels with the grain • Standard industry practices for delivery and handling of the correct product as per commercial contract

Grain loading to road • Inventory control • Grain delivery and external transport equipment to or rail transport procedures and QA required standard and cleanliness prior to loading of grain; systems12 documentation of grain parcel quantity, quality standards and GM status provided to transport operator and accompanies parcel to buyer, records kept. Contractors operate as per storage operator requirements. • Agreements between storage agent and purchaser/owner • Freight agreements followed by transporter; use of dedicated units as required • Transport operators follow guidelines and provide documentation attesting to inspection, cleaning and use of transport units as required

Grain receival •Receival at domestic • Grain is received at buyer storage or export terminal and buyer storages and export either consolidated or identity preserved as per user, market, terminals per contract and shipper procedural and contractual requirements

Delivering market choice with GM canola >>>15

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MARKETING

Objective: To supply contracted canola or canola products to domestic or export markets to meet speciﬁcations

Activity managed: Protocols: Processes:

Domestic marketing • Trading contracts eg NACMA • Compliance with customer contract terms and contracts (food and feed) conditions and market and regulatory requirements • FSANZ13 - food labelling • Sampling and testing may occur requirements • Terms and conditions comply with regulations

Export marketing • Trading contracts (food and feed) • Compliance with customer contract terms and conditions; and market and regulatory requirements — includes all importing country regulatory requirements — independent inspection assessment may occur • AQIS regulations14 • Compliance with AQIS quarantine and phytosanitary requirements

END PRODUCT MANUFACTURE

Objective: To ensure canola products are processed and manufactured to meet the needs of human, stockfeed and industrial end-users. Processed and manufactured products are packaged and distributed to the marketplace as required.

Activity managed: Protocols: Processes:

Product acquisition, • Trading contracts (food and feed) • Customer contract terms and conditions processing and • FSANZ13 - food labelling requirements • Sampling and testing may occur manufacturing, • Internal quality systems • Terms and conditions comply with regulation packaging • All processing, manufacturing, labelling and • AOF Code of Practice for the Bulk packaging processes followed to meet customer Transport of Vegetable Oilseeds, and regulatory requirements Meals and Hulls by Road and Rail and • Product is transported as per standards industry AOF Code of Practice for the Cleaning guidelines of Containers and List of Prohibited Immediate Prior Loads15

References: 1. Gene Technology Act 2000 (and its Regulations 2001) 2. Canola Industry Stewardship Principles, Gene Technology Grains Committee, 2003 3. Australian Seed Federation national code of practice for seed labelling and marketing, 2005 4. Agricultural Pesticides and Veterinary Medicines Authority Act, 1992 5. Commonwealth of Australia Plant Breeder’s Rights Act 1994 6. Commonwealth of Australia Patents Act 1990 7. Australian Seed Federation best practice guidelines for management of AP in canola Varieties, June 2006; and Seed Certiﬁcation Scheme 8. Australian Seed Federation, seed testing protocols for AP in canola, 2003 9. Australian Seed Federation, code of practice for use of seed treatments, 2005 10. National Agricultural Commodities and Marketing Association, commodity standards and declarations, 2007 11. Australian Oilseeds Federation, standards manual, 2007 12. Segregating GM and non-GM grain in the Australian Grain Storage System, CSIRO, 2004 13. Food Standards Australia New Zealand Act, 1991, FSANZ Food Standards Code, 2007 14. Australian Quarantine and Inspection Service, Exporting Regulations, 2007 15. AOF Code of Practice for the Bulk Transport of Vegetable Oilseeds, Meals and Hulls by Road and Rail, and AOF Code of Practice for the Cleaning of Containers and List of Prohibited Immediate Prior Loads 2005; AOF Trading Standards 2007

16<<< Delivering market choice with GM canola

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APPENDIX SPECIAL COUNCIL 5.1C-8SEPTEMBER2020 PAGE 131 AGENDA ITEM SPECIAL COUNCIL 5.1.1 SUBMISSION #19 APPENDIX SPECIAL AGENDA COUNCIL ITEM SPECIAL 5.1C-8SEPTEMBER2020 COUNCIL

PF070776CanolaBook_Delivering.indd July 2007 PAGE 5.1.1 132 SUBMISSION #20

21st August 2020

Mr Craig Doyle via email: [email protected] General Manager, Strategy & Development Light Regional Council Re: Request for Consultation about Genetically Modified Crops in Light Regional Council Area Dear Craig, I am the owner of Arbutus Hospitality, trading as Appellation restaurant, The Louise accommodation and three75 bar and kitchen, located at 375 Seppeltsfield Road, Marananga, in the Light Regional Council area. As such, I am interested to provide this submission to council during this time while your elected members consider requesting from the state government to continue the region as one that does not permit genetically modified crops. Over the past several years, we have observed the growing appeal of the Barossa area for interstate and international visitors, who travel here in order to experience the unique wine and food culinary offerings that many local businesses, such as ours, have brought to market in the past decade. Indeed, in calendar 2019, more than 48 per cent of our guests had travelled from locations outside Australia, drawn to the region because of its culinary reputation. We know this because our guests tell us this, and because the travel trade that we work with around the world have come to learn that their clients are effusive about the memory of their time in the Barossa, learning about and consuming the wines of our region and savouring the foods of our region. These guests frequently purchase their first premium Australian wine while visiting cellar doors while here, and subsequently become repeat purchasers of ample quantities of Barossa wines via mail order once they have returned home. This export business is a strong backbone of the overall regional economy. It is our belief, that these guests are choosing the Barossa over any of the other Australian wine regions for their visitation due in no small measure to the reputation of the brand “Barossa” and the hard earned reputation for its attributes of purity, quality and integrity. Integral to these attributes is the easily communicated story about the connection to land and climate, crop raising practices that eliminate (or at least minimise) chemicals and the policy that none of our region’s vines, nor it fruits, vegetables, herbs and feedstocks are genetically modified. If there were to be the introduction of genetically modified farming in the region, these unique attributes of the Barossa would be lost forever. This is a genie that cannot be put back in the bottle once it begins. And, this would forever diminish the market appeal of brand Barossa as a very special tourism destination.

APPENDIX SPECIAL COUNCIL 5.1C-8SEPTEMBER2020 PAGE 133 AGENDA ITEM SPECIAL COUNCIL 5.1.1 SUBMISSION #20 The opportunity to block GM farming practice is of substantial economic importance to the future of the vibrant tourism industry in our region. We therefore encourage Light Council to appeal to the appropriate state authority to not include our region in a planned statewide relaxation of the prohibition of genetically modified farming, thereby retaining the current policy that has helped create the globally recognised attributes of purity, quality and integrity of the Barossa brand. Regards,

James R. Carreker Owner and Managing Director Arbutus Hospitality 375 Seppeltsfield Road, Marananga SA 5355 [email protected] Copy: Councillor Simon Zeller Mayor Bill O’Brien CEO Brian Carr Tourism Barossa Chair Jon Durden

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APPENDIX SPECIAL COUNCIL 5.1C-8SEPTEMBER2020 PAGE 135 AGENDA ITEM SPECIAL COUNCIL 5.1.1 SURVEY ATTACHMENTS (BROOKMAN_THE FOOD FOREST)

Date: 20 July 2020

MEMO TO: SA Vignerons & Winemakers

I write with compelling evidence that the wine industry and council areas generally will be advantaged in trade and marketing by becoming 'Non-GM Crop areas'. I hope that you can spare a few minutes to scan this doc and write to your local council urging it to apply-for Non GM designation as soon as feasible. x Data from world markets confirm that the market for Non-GM food and beverages is growing at >16% pa x Surveys worldwide show that most people do not want to consume GM food or beverages (A CSIRO survey showed only 7% of shoppers 'were unconcerned' about eating GM food). x GM crops in your area and SA generally would sully the image of the wine industry, worth > $2B annually to SA. x Most consumers of wine are unaware of the wine industry's self-imposed ban on GM inputs. There would be a market advantage in promoting wine as coming from Non-GM Zones, as well as excluding GM vines and yeasts. This is a market advantage for a whole BRANDED Non-GM region. x The intrusion of GM pastures or canola, through wind and insect pollination, and GM seeds spilled by transport, in mulch and animal feed, are examples of environmental contamination that could create superweeds in vineyards (eg Roundup Ready canola or rye grass). x Vine growers who use sheep in vineyard management would be unable to sell sheep, meat or wool to organic or discriminating markets if there was a GM component in what they eat x Most consumers don’t associate GM crops with wine but an assurance that food and wine from your area is Non-GM would give a marketing edge. x Tasmania has seen property values increase (now double mainland values for farmland), in part because of its complete freedom from GM crops. It is expected SA regions electing to be GM-Crop-free will see values firm. x Local food producers and processors will maintain and grow their markets with Non-GM kudos for smallgoods, beer, bread or gin. Restaurants and cellar doors in Non-GM Crop Zones will have another marketing advantage on their side. x Farmers markets and major events bring visitors to wine areas and should be protected from GM intrusion. (eg The Adelaide Farmers market has a Non GM policy) x A Non-GM region will be of particular advantage to smaller food businesses, vineyards, wineries and farms. Promoting your products as GM-free in social media, marketing materials, labels and websites will attract tourists to visit your GM-free region. x Whilst the Australian Grape and Wine Council diplomatically distances itself from the Non-GMO issue, it goes to great length to point out that "Winegrapes are not traded as a homogeneous commodity and the $/tonne price received by grape growers is determined by a wide variety of factors. The location of the vineyard and quality of the grapes are significant determinants of price, while other factors such as distance to the winery and contract arrangements can also have an influence'. It leaves open the issues of wine value to the consumer and the marketing chain and the roles of well established niche markets. x Non-GM Crop regions will value-add to SA's overall clean, green image and being able to assure patrons of shops, restaurants and wineries that food and beverages are made with Non-GM ingredients will build confidence among potential tourists. Why would tourists visit a GM region if they can visit a GM-free region?

APPENDIX SPECIAL COUNCIL 5.1C-8SEPTEMBER2020 PAGE 136 AGENDA ITEM SPECIAL COUNCIL 5.1.1 SURVEY ATTACHMENTS (BROOKMAN_THE FOOD FOREST) x Organic growers with neighbours growing GM crops may lose certification of all or part of their land due to the proximity of GMOs. At 14M hectares, SA has by far the largest area of certified organic land in Australia (the Australian industry generates >$2.6B) x For semi-rural councils, the potential for invasion of farms, parks and gardens by GM Crop genes through insect or wind pollination is a real issue, so the larger the Non-GM area the better. x There are many regional areas, counties etc that are Non-GM around the world; quite number in Spain, California, Belgium etc, so the business of maintaining a non GM council is a well trodden path. In 2004, the residents of Mendocino county, California voted to become the first GMO-free county in the United States in an initiative that was supported by many of the county's largest wineries and has been dubbed 'California's GM-free Wine Mecca'.

x FOR THOSE OF YOU WHO COMBINE VINES AND FARMING , CURRENT GRAIN GROWING ECONOMICS SHOW THAT THE GM CROPS CURRENTLY AVALABLE IN SA ARE LESS PROFITABLE THAN NON-GM Varieties x Data presented in the 2020 Department of Primary Industries Gross Margins &Enterprise Planning Guide, virtually a farmers 'bible' in terms of planning crops for the next season, shows clearly that GM Canola is significantly less profitable (in terms of Gross margins over 5 years of data) than naturally bred cultivars, on all regions across the State. x Farmers growing Non-GM canola continue to receive a substantial premium for Non-GM canola on Kangaroo Island. KI Pure Grain has its own facilities at Pt Adelaide, in part to avoid possible contamination. x Actual market reports for the sale of canola from Australian ports show that Non-GM canola provides constant premia over GM canola, sometimes rising to almost $100 per tonne. A significant percentage of Australia's billion dollar canola crop is exported to Europe under the International Sustainability and Carbon Certification (ISCC) scheme and the EU prefers Non-GM canola, giving Australia an edge over a key competitor, Canada, which principally grows GM canola. x The University of Adelaide report into export opportunities for Non-GM products indicates rapid future growth for NON-GM crops x The Anderson Report and Mercado Report commissioned by the current government has major conflicting data and statements that made it difficult to compare data and have been refuted as a believable document in a detailed analysis by Dr John Paull. x It is certainly known that Australia benefits massively through the export of Non-GM canola, a significant quantity of which comes from SA, attracting a premium. x Key users of grain in Australia will not use GM grain in their value adding processes, eg San Remo, brewing companies etc x The segregation of GM crops from Non GM crops has been shown to fail regularly overseas and also in Australia. The Kangaroo Island Pure Grain farmers have established their own receival and transport chain to guarantee zero contamination x The Independent Parliamentary review of the release of GM crop cultivars into the environment pointed out more than 20 failures and obstacles in the Regulation of GM crops x The multi-million dollar Non-GM/Organic South Australian beef export market could be compromised by GM 'contamination' as livestock having eaten GM feed are disqualified from certified Organic and Non GM status in important domestic and some export markets (not to mention dairy and grain crops) x More GM cultivars including cereals are planned for release into the environment, potentially threatening the status of South Australia's beer, pasta, biscuits, flour and stockfeed. x The above points do not take into account other negative impacts of GM crops in human and animal health - see GM 'Myths and truths edition2' which also covers the effects on the environment including soil biology and water resources (including potable water) x A good website for basic research into the advantages of being a Non-GM area is https://non- gmoreport.com

APPENDIX SPECIAL COUNCIL 5.1C-8SEPTEMBER2020 PAGE 137 AGENDA ITEM SPECIAL COUNCIL 5.1.1 SURVEY ATTACHMENTS (BROOKMAN_THE FOOD FOREST) Given that becoming designated as Non-GM Crop area is a once-only opportunity and that there are clearly large trade and market risks for the councils embracing GM (and no quantifiable gains), it seems prudent for your council to apply for Non-GM status by the end of September The concept of regions becoming Non-GM, with adjacent councils collaborating to form viable zones, will be considered by the government

I urge you to write/email formally to your council about the matter of Non-GM Crop areas stating your concerns and evidence/ beliefs that it would be prudent for the Council(s)to apply for Non-GM Crop Zone status. You are welcome to use points and references from the above information.

I am happy to expand on the above and send further references as required. I am also willing to address meetings to clarify this important issue.

Yours sincerely

Graham Brookman

Joint Managing Director

0407771985

PO Box 859 • Gawler • South Australia 5118 • Tel/Fax 08 8522 6450

Web: www.foodforest.com.au Email: [email protected]

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