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TITLE:  An Environmental Safety Assessment of Roundup Ready Wheat:
        Risks for Direct Seeding Systems in Western Canada
        Two Comments
SOURCE: Canola Council, Canada
        http://www.canola-council.org/
DATE:   Jul 26, 2003

------------------- archive: http://www.genet-info.org/ -------------------


An Environmental Safety Assessment of Roundup Ready Wheat: Risks for
Direct Seeding Systems in Western Canada
Canola Council Comments

Recently the Canadian Wheat Board released a report "An Environmental
Safety Assessment of Roundup Ready Wheat: Risks for Direct Seeding
Systems in Western Canada" by Dr. Rene Van Acker, et al. This report uses
the experience of Roundup Ready (RR) canola to speculate on the potential
impact of Roundup Ready wheat. In several areas, the authors selectively
chose to exclude information on the RR canola production system,
especially the benefits that growers and the industry have realized due
to the use of transgenic varieties.

Specifically:

- Growers have clearly realized benefits from RR canola and have widely
adopted the technology in western Canada. In 2002, 45% of the canola
acreage in western Canada was RR canola. In a 2001 report commissioned by
the Canola Council of Canada on the "Agronomic and Economic Assessment of
Transgenic Canola", growers reported that the main reasons for choosing
transgenic varieties, including Roundup Ready, were better weed control,
better yield, higher returns and more profit. Growers reported an average
$5.80 in net return for the transgenic varieties compared to
conventional. Revenue was higher due to higher yields, less dockage,
lower herbicide costs and lower tillage costs.

- With the use of transgenic varieties, growers were able to reduce
summer fallow acres and the number of tillage passes on their fields. An
additional 2.6 million acres of canola had fewer tillage passes, thereby
greatly contributing to soil conservation efforts. The reduction in
tillage and other field operations equates to 31 million litres less fuel
used, a savings to growers of $13 million.

- Growers have been managing volunteer canola for many years and with the
introduction of herbicide tolerant canola systems, they have rapidly
changed management practise to minimize canola volunteers through crop
rotations, proper timing of tillage and herbicides. When asked about
managing transgenic canola volunteers, 77% of growers said that
management of canola volunteers was the same or easier than managing
conventional volunteers. Many farmers already add a phenoxy herbicide to
manage weeds that are more difficult to control with Roundup as pre-seed
burn off and therefore do not incur extra costs to manage RR canola
volunteers. The uses of the additional phenoxy herbicide must be weighed
against the 40% reduction in herbicide costs for weed control in
transgenic canola. In addition, the use of transgenic varieties resulted
in a reduction of 6,000 tonnes of herbicide used.

It is important to the canola industry that any information on canola and
the use of herbicide tolerant technology, including RR canola, is
accurately represented and all information is widely available. The
"Agronomic and Economic Assessment of Transgenic Canola" is posted on our
website at http://www.canola-council.org/production/gmo_main.html.

*****


Comments by R. K. Downey on the report: "An Environmental Safety
Assessment of Roundup Ready Wheat: Risks for Direct Seeding Systems in
Western Canada" Written by R. C. Van Acker et al.

The report, authored by R. C. Van Acker, A.L. Brule-Babel and L. F.
Friesen, is highly biased and fails to mention any advantages of Roundup
tolerant crops, particularly the well documented case of transgenic
canolas, that includes RR canola. The report also fails to make clear
that the authors are dealing with a herbicide management issue and not a
biotechnology problem.

The title of the report indicates that it will deal with an
"Environmental Safety Assessment" and concludes that there would be an
environmental risk. However, no evidence is presented that indicates
either RR canola or RR wheat is or would be invasive of natural
ecosystems or cultivated land, in the absence of the specific herbicide.
Thus the environmental risk conclusions of the report are invalid.

The authors fail to mention that the vast majority of canola growers have
elected to grow herbicide-tolerant canola. At least 85% of the canola
grown in western Canada is herbicide-tolerant and 42% of that 85% is sown
to RR varieties. Obviously canola producers see value in the herbicide
traits and are adjusting their herbicide management to deal with canola
volunteers. In driving through the countryside a canola volunteer problem
is not in evidence even though RR canolas have grown for the past 8 years.

The authors completely ignore the environmental and agronomic advantages
associated with transgenic canola, the majority of which is RR. The
survey commissioned by the Canola Council of Canada of 650 growers, half
growing conventional and half growing transgenic canola varieties,
clearly showed environmental as well as the monetary advantages of
herbicide traits such as Roundup. The use of herbicide-tolerant canola
such as RR canola resulted in a reduction of 6000 tonnes of herbicide
applied in the year 2000. This would largely off set any additional use
of phenoxy herbicides to control volunteer canola plants. The use of
transgenic canola in 2000 also resulted in fewer cultivations or tillage
operations, not more, as stated in the Van Acker et al. report. The
Canola Council survey found that 2.5 million acres received at least one
less tillage pass in 2000 because transgenic herbicide-tolerant canola
varieties, such as Roundup Ready, were grown.

There is no mention in the report of the agronomic advantages of having a
weed-cleaning crop such as RR varieties in the middle of the crop rotation.

The authors have incorrectly assumed that the Canadian Seed Growers
Association regulations for the production of pedigree RR wheat varieties
would remain unchanged. However, the breeder of such varieties has the
option of requesting greater isolation or land requirements if deemed
necessary and would almost certainly do so. The CSGA regulations are
minimum requirements not absolutes. Isolation requirements would almost
certainly be increased for conventional wheat varieties should RR wheat
be introduced.

The authors refer in several places to the relatively high level of
unwanted genes found in Certified seed of some canola varieties produced
in the years 2000 and 2001. They have based their calculations and
conclusions on the assumption that such adventitious mixtures will be
present in future years. Such an assumption is wrong! Seed companies
began cleaning up their varieties as soon as the information on
adventitious mixing was made known and detection techniques were
available. Although data on Certified seed lots produced in 2002 are not
available at this time, indications are that the industry has moved
quickly to correct this situation. The authors also failed to note that
the data from both seed lot studies indicated that nearly all the
adventitious presence of unwanted genes had resulted from outcrossing in
breeding nurseries, during the development of the varieties, and not
during the pedigree seed multiplication process. Thus the level of
contamination projected by the authors seriously over estimates the
likelihood of the future adventitious presence of the RR gene in
conventional pedigree seed of both canola and wheat.

The authors have used the term "genetic bridge" to describe gene flow
between plants of the same species. The introduction of such a term is
unsuitable and unacceptable! In genetics the term "bridge" infers the
overcoming of a barrier. Since there is no barrier to gene flow between
wheat plants or among canola plants of the same species, the introduction
of this terminology appears to be an attempt to mislead the public into
thinking that gene flow within a species is something unusual.

In this reviewer's opinion the authors have seriously over stated the
case for gene flow in wheat and painted an unrealistic picture of the
volunteer canola situation. However the authors are correct in saying that:

a) RR wheat at this time would pose a hazard to Canada's European wheat
market and

b) RR wheat would greatly detract from the present advantages of
herbicide-tolerant canola, since canola producers would have to apply an
additional herbicide to their canola crops to control any volunteer RR wheat.

R. K. Downey, O.C., Ph.D., D.Sc., F.A.I.C., F.R.S.C.
President Canoglobe Consulting and
AAFC Research Scientist Emeritus