by Dr Peter Trolove
North Rakaia River bed one month after an Ecan aerial/helicopter glyphosate application – ecocide!
At the same time as the New Zealand Environmental Protection Agency (EPA) appears to be reluctantly inching its way to deciding whether glyphosate should be the subject of a hazardous substances risk reassessment, the Environment Canterbury Regional Council, (Ecan), is seeking twenty years consents to use glyphosate, plus two other herbicides, triclopyr, & dicamba, on Canterbury’s waterways.
[The Triclopyr label states: “ECOTOXICITY: very toxic to aquatic organisms. DO NOT spray over, or allow drift over, an aquatic environment”.
Dicamba Hazard Statement: Harmful to aquatic life with lasting effects.]
The Environmental Law Initiative (ELI) has responded to the EPA’s Call for Information, (CFI), raising concerns about the general toxic effects of glyphosate on ecosystems, the deficiency of data on the effect of glyphosate in New Zealand, the role of co-formulations/adjuvants in the toxicity of glyphosate herbicides, the need for information on glyphosate use in practice, the need for robust cost-benefit analysis of glyphosate, and the need for independent science.
The ELI is a registered charitable trust, whose objective is to support the effective protection of Aotearoa’s natural resources and environment.
The New Zealand Federation of Freshwater Anglers has long been concerned about the Environment Canterbury Regional Council’s widespread aerial and land based applications of herbicides, in particular glyphosate formulations, across wide swathes of Canterbury’s river fairways at high applications rates of up to 17L/ha in conjunction with toxic surfactants.
Emails exchanged with the EPA confirm not all glyphosate formulations used by Ecan are approved for this purpose by the EPA under the Hazardous Substance and New Organisms Act.
The evidence against glyphosate is extensive and is the subject of several books detailing corporate fraud, the corruption of science and political corruption, (1,2,3.).
It seems a nonsense that a widely used herbicide that is known to be toxic to freshwater ecosystems, is a probable cause of cancer in humans (4), is a hormone disrupter, whose residues are increasingly found in our food and in our urine, should receive the blessing of environmental protection agencies and food safety authorities because of a “risk-benefit” assessment based on economic parameters.
Due to the $ billions that are earned from the use of glyphosate, this story appears as one of the corruption of science and governments by global agrichemical corporates putting profits before all else.
The New Zealand Environment Protection Agency
Since its inception in 2011, the NZ EPA has not been without controversy.
Formed 1 July 2011, as a Crown agent under the Crown entity model the EPA operates at arm’s length from Ministers. Its independence in decision making is protected by statute and the established governance structures. A letter of expectations is issued annually by responsible Ministers which, in the context of its independence sets out the broad expectations of the Government of the day.
Specific functions are specified in six environmental acts.
It took over the role of the Environmental Risk Management Authority (ERMA) that controlled the introduction of hazardous substances and new organisms.
The stated aim of the ERMA was; “Achieve effective prevention and management of risks to the environment, public health and safety associated with importing or manufacturing hazardous substances and introducing new organisms and their use”.
Under the HSNO Act, the Authority was required to, consider and weigh up the adverse and beneficial effects of a new organism or substance. The detailed decisions of the authority also give give insight into how it has dealt with different aspects of risks, costs, and benefits.
EPA had to defend the appointment of its present CEO, Dr Allan Freeth, a former CEO of Wrightsons, and an ardent supporter of genetic engineering from objections from the Green Party.
The Greens were right to object as glyphosate is the main ingredient of Roundup whose sales and global use grew exponentially after Monsanto developed a suite of “Roundup Ready” genetically modified food crops to maintain and grow market share when Roundup’s patents were due to expire allowing competition from cheaper generic copies.
Dr Rosemary McLeod, a UK medical doctor and tireless campaigner against the use of glyphosate due to concerns about its adverse environmental and human health effects has published in great detail the consequences Monsanto’s game changing strategy has had on the health of impoverished Argentine farm workers. There is an active global band of independent “Rachel Carsons” with professional backgrounds from Europe and America recording their warnings in peer reviewed papers and on public media sites. Monsanto has been successively involved in the development or production of DDT, PCBs, Dioxin, (a contaminant of “Agent Orange”), and glyphosate and has consistently claimed these products were safe. Monsanto invests heavily in countering concerns in the media and through direct lobbying to politicians and government agencies.
Freeth was appointed by the John Key government in 2015.
Minister Nick Smith denied the appointment of Rowarth as Chief Scientist was a political appointment.
Appointments of this nature are to be expected. It is naive to expect “responsible New Zealand Ministers” with their short term focus on remaining in power with one eye on political donations are immune from pressures from the agricultural sector and agrochemical industries.
The EPA had to end the tenure of its controversial Chief Scientist, Dr Jacqueline Rowarth, an agricultural commentator with dairy farming interests in the Waikato, after warnings she was damaging trust in the organisation. Rowarth claimed she left on her own accord and that her opinions were always based on scientific evidence, not emotion.
This was not before Freeth’s complaints initiated disciplinary action by Massey University against Dr Mike Joy in response to a disagreement between Rowarth and Joy.
[The muzzling of New Zealand scientists by our politicians is the subject of a book by Shaun Hendy Silencing Science BWB Texts.]
New Zealand’s US counterpart, the US EPA, has an even more controversial recent history with President Donald Trump appointing Scott Pruitt and subsequently Andrew Wheeler to head America’s EPA.
Both lawyers primarily championed the interests of coal, oil, and gas companies extending to the chemical companies peddling pesticides before their appointments. Only a few weeks into the new administration Trump slashed the EPA’s budget and in return for a $ 1 million donation from Dow AgroSciences, overturned the agency’s ban on chlorpyrifos in a move applauded by farmers and agribusiness. Glyhosate appears to have received a free pass in the process.
Chlorpyrifos is acknowledged to cause harm in children’s brain development. (1)
This is a concern as the NZ EPA through inadequate funding and resources relies heavily on overseas and drug company safety data unlike the EU which is able to take a much more independent and precautionary approach. The use of glyphosate is now banned from domestic use in an increasing number of EU countries including Belgium and France.
California and a number of other countries including Norway, Denmark, Sweden, Sri Lanka, Salvador, Brazil and India have banned or restricted the use of glyphosate because of possible links with health problems including cancer. (5). Glyphosate is banned in Vietnam and several countries in the Middle East.
The New Zealand public deserve to know what is happening behind the scenes in this country.
The EPA is not obliged to make its assessments open to public input nor defend its decision making processes.
Both US and NZ EPAs under respective laws must balance risks against benefits, taking into account the economic, social, and environmental costs and benefits of the use of any pesticide/herbicide.
This is bizarre. This is politics. It seems protecting the economic environment is the underlying purpose an EPA.
The US EPA has never properly reviewed glyphosate since it took over pesticides from the US Department of Agriculture in (USDA) 1972 due to most of its employees coming from the USDA where a culture of cooperation and affiliation with ag-related corporations was deeply ingrained and where there were efforts to promote the advantages of pesticides. The USDA’s mission is to support, sustain, and promote the nation’s agricultural industry. (1).
Glyphosate has never been the subject of a reassessment by the NZ EPA since its inception in 2011.
A criticism of the US EPA, apart from being infiltrated by ex Monsanto staff and relying on Monsanto safety data is that the whole approvals process is so narrowly focused on glyphosate alone, not how it affects people, animals, and the environment when it is mixed with other ingredients, as it is in branded herbicide formulas such as Roundup.
“The whole pesticide approval process is so narrowly focused on individual ingredients that no one at the (US) EPA has taken a step back to look at the bigger picture; and when you look at the bigger picture, it’s clear that the agency has created a monster” said Nathan Donley, who holds a doctoral degree in cell and developmental biology. “Pesticide labelsare so permissive without regarding what a pesticide can be mixed, with what and where. The EPA treats mixtures as something to be swept under the table. They pay lip service to it every once and a while, but when it comes to actually doing anything about it, they revert to the decades-old practice of pretending that it doesn’t exist. With the EPA, lack of evidence of harm equals no harm when it comes to mixture toxicity. Its just indefensible” [page 38 WHITE WASH (1).]
Glyphosate whose safety is predicated on blocking the plant specific metabolic shikimate pathway has multiple mechanisms for potential harm. It is a powerful chelating agent binding tightly to metal ions. This can be harmful if glyphosate makes metal ions inaccessible to living cells. Many of the microbes that make up the human microbiome rely on the shikimate pathway.
Researchers in New York found glyphosate and its metabolites AMPA (aminomethlyphosphonic acid) and N-methyl glyphosate occurred widely in the urine of domestic pets. This appears due to a move to “grain free” dog foods where the legumes replacing grain consistently show the highest levels of glyphosate. N-methly glyphosate is considered more carcinogenic than glyphosate.
Dr Stefanie Seneff’s book TOXIC LEGACY (2) explores these concerns to a molecular biological level in animals and humans. She makes plausible links to a plethora of human health problems that have only emerged in recent times (2). Despite glyphosate and AMPA being pervasive in the environment the US EPA no longer includes AMPA residues in calculations when setting safe residues for glyphosate in food.
In 2001 I was completing an extramural MBA in Christchurch. I was surprised when a classmate, a young army officer from Burnham Army Camp who specialized in logistics, told me he would be missing classes for a couple of weeks to attend a high level army conference in Washington DC.
I asked how a country the size of America could possibly benefit from inviting a junior NZ army officer to such a conference. His reply was sobering. He explained the US Army, constrained by constitutional checks and balances, used New Zealand as a testing ground for ideas that could never see daylight in America.
New Zealand does not have a formal constitution and unbridled power is held by the Prime Minster.
Geoffrey Palmer gave a detailed account of this state of affairs in his 1989 book Unbridled Power in which he noted that during the Cold War laws could be drafted and passed in almost no time at all, “the fastest law in the west”. (6).
In Canterbury we got a taste of this when John Key passed the Environment Canterbury (Temporary Commissioners) and Improved Water Management Act 2010 under urgency compromising Canterbury’s largely pristine freshwater in order to increase GDP.
To achieve this Key simply disenfranchised Canterbury ratepayers by replacing elected Canterbury regional councillors with his appointed commissioners enabled by this constitutionally repugnant Act which also targeted Canterbury’s Water Conservation Orders. Exactly the sort of tyranny a carefully drafted constitution would have prevented.
The Environment Canterbury Regional Council (Ecan) retains an arrogant culture acting as if it is above the law despite returning to full democracy in November 2019.
Canterbury ratepayers have learned to their cost that “independent commissioners” are no protection from government abuse(s).
With the reins of power recently passed to Christopher Luxton, (sponsored by John Key), New Zealand’s natural environment would seem set of another round of undemocratic destructive short term economic exploitation.
https://www.newsroom.co.nz/warning-over-looming-water-battleThe NZFFA’s issue with Ecan’s use of glyphosate on Canterbury’s waterways
Both immediate past presidents of the NZFFA have raised LGOIMA requests with Ecan relating to the widespread use of herbicides, in particular glyphosate formulations, after witnessing the consequences of Ecan’s ongoing defoliation of Canterbury’s braided river fairways.
Such river works are needed when excessive water abstraction for irrigation results in the invasion of woody plants in the river fairways and compromises the transport of river gravels.
The NZFFA’s probing has revealed very high application rates are used, together with apparent non compliance with Ecan’s own consents regarding the use of this herbicide, both in terms of safety and use of non approved formulations.
The label dose of the formulation used clearly states “Toxic to aquatic life with long lasting effects. This product must not be applied directly into or onto water”Glyphosate and the destruction of the Rakaia River’s recreational fisheries
Living at the mouth of the Rakaia River, I have observed, and recorded, the long term destruction of the soil ecology within the braid beds, and well as the build up of fine sediment released from defoliated islands in the river fairway which has smothered aquatic life in the lower river.
This is very likely to have been a contributing factor in the dramatic decline in the once abundant populations of the IC UN Red Listed Endangered native fish, Stokell’s smelt.
Following the rapid disappearance of the massive seasonal runs of smelt, large shoals of well conditioned sea trout no longer enter the coastal braids of the Rakaia River.
Similarly the Rakaia River is no longer the major salmon fishery it once was.
The complex ecology of Canterbury’s large braided rivers, defined by ever changing water clarity and high volume variable flows is not well understood because it is so difficult to study.
Irrigation hearings and consent conditions have relied on models and “expert” opinion in lieu of any real understanding. Decisions have been based on incomplete, unreliable and inadequate evidence.
While the primary causes for the loss of the Rakaia River’s recreational fisheries are likely to be connected to increased irrigation abstraction and the failure of Ecan to ensure effective fish screens are in place, it is almost certain that Ecan’s widespread and indiscriminate use of glyphosate on the river’s fairways is a contributing factor.
New Zealand salmon authority, Dr Martin Unwin, noted that juvenile salmon migrating from nursery streams near the headwaters of the Rakaia River rely primarily on terrestrial insects as their food source as they pass through the inhospitable reaches of the middle and lower parts of this ionic braided river. They also need some vegetation for cover and deep slow flowing backwater pools in which to grow to sizes that ensure good survival rates when they enter the sea.
Defoliating the river fairway with herbicide by Ecan’s river engineers destroys the terrestrial food sources used by juvenile salmon while at the same time destroys the trees and larger vegetation that help form the deeper slower flowing holes, essential habitat where young salmon can pause and grow.
Large sea trout that once migrated to the headwaters to spawn are no longer as abundant as they were prior to Ean’s issuing of recent irrigation consents. (Observations of a professional Rakaia River fishing guide).
It seems that Ecan sees the Rakaia River primarily as a ready source of irrigation water, a ready made irrigation canal, and a storm water drain in times of flood. It is not willing to recognise the Rakaia River as a complex integrated environment on a catchment wide scale from the Alps to the sea.
Despite having successfully fought for a National Water Conservation Order for the Rakaia River in recognition of its once outstanding fisheries and recreational fisheries, anglers have been the biggest losers from Ecan’s single focus on maximizing the amount of irrigated land in Central Canterbury.
Ecan’s discomfort in their clear disregard of the Rakaia NWCO is evidenced by Ecan currently seeking a Declaration in the Environment Court that it is not accountable for giving effect to the Rakaia River National Conservation Order (1988).
Ecan’s attempts to blame the harm its (mis)management has caused to the Rakaia River on global warming and “probable events at sea” are not worthy of serious consideration.
Ecan has issued over 27,000 consents and continues to issue between 1500 to 2200 a year.
It has increased its spending on consents by a further $3.5 million this year.
It has only been able to monitor around 1500 consents “with a particular focus on the Rakaia River”? (The Press Oct 3, 2023. Rakaia Anglers Group meeting with Ecan 2023).
Consents do little to protect the environment, they simply absolve the user/polluter from common law liability.
There is vast amount of scientific evidence regarding the probable mechanisms by which glyphosate, (a chelating agent, antibiotic, and herbicide), may cause harm to humans and the environment.
MIT senior research scientist, Dr Stefanie Seneff’s book, TOXIC LEGACY (2) is a good introduction to this subject.
A jury in a superior court in California awarded massive damages against Monsanto in a claim by a groundsman whose health was destroyed after accidental contamination with concentrated Roundup, a common formulation of glyphosate. The jury did so not because direct causation was proved beyond reasonable doubt, but because the claimant’s lawyers where able to show beyond any doubt, the fraudulent lengths Monsanto went to to present their product as safe despite the company’s own evidence to the contrary. (3).
Agrichemicals are in widespread use globally and in New Zealand. Chemical residues can now be found in humans, animals, land, and water. Thanks to the efforts of Monsanto and complacency, food safety authorities have not been monitoring for glyphosate residues in food.
As a probable cause of cancer it is fair to ask why is this herbicide allowed in our food and water?
The EPA has an important role in protecting environmental and human health.
Ecan has an equally important role in protecting our freshwater at source.
Can we rely on such organisations who use risk assessments where economic benefits are weighed against human and environmental harm? A practice embedded in many New Zealand Ministries and local government entities.
Both the US and NZ EPAs are not independent of politicians and the professional lobbyists paid to influence politicians.
Both Government and regional government have no meaningful accountability enshrined in New Zealand law. (There are Constitutional Conventions and National Policy Statements but there are no proscribed penalties when these are ignored).
New Zealand’s central and local government politicians simply have to negotiate ill informed voters every three years through “controlling the story”.
Widely used hazardous substances such as glyphosate require greater expertise and independent scientific evaluation by recognized experts from the “hard disciplines” free from political interference at a national level.
Consents for region wide use of hazardous chemicals by regional councils should have independent evaluation.
The stakes are too high to be otherwise.
Opinion piece by;
Dr Peter Trolove BVSc MSc MBA
1. WHITE WASH The Story of a Weed Killer, Cancer, and the Corruption of Science. Carey Gillam. Pub. Island Press, Washington DC, 2017.
2. TOXIC LEGACY How the Weedkiller Glyphosate is Destroying our Health and the Environment. Stephanie Seneff
3. The Monsanto Papers, Deadly Secrets, Corporate Corruption, and One Man’s Search for Justice.
Pub. Island Press.
4. IARC Monograph on Glyphosate – World Health Organization, 1 March 2016.
5. New Zealand Medical Journal Vol. 131, No.1472: 23 March 2018. “Carcinogencity of glyphosate: why is New Zealand’s EPA lost in the Weeds?”
6. Unbridled Power: An interpretation of New Zealand’s Constitution. Geoffrey W. R. Palmer 2nd Ed. Oxford University Press, 1987.
7. Journal of Agricultural Water Management. Unintended consequences to groundwater from improved irrigation efficiency: Lessons from the Hinds-Rangitata Plain, New Zealand. William E. Dench, Leanne K. Morgan. 2020
Lower Hinds River bed. Dry and brown due to over allocation of water for irrigation and defoliation with glyphosate. While the Hinds River is a typical seasonally intermittent river, this reach of the river retained year round flows in past years. Irrigation has lowered the aquifer in the Rangitata Hinds plains area by up to 17 meters since 2008. (7).