Inquiry into controlling the spread of cane toads submitted by em

To: the Standing Committee on the Environment and Energy

Re: Inquiry into controlling the spread of cane toads

submitted by email - please confirm receipt

We thank the committee for its interest in this subject and wish to respond to the Terms of Reference below:

The effectiveness of control measures to limit the spread of cane toads in Australia.

Additional support for cane toad population control measures.

The subheadings in our submission are:

What is the frog hospital, briefly Cane toads in FNQ are in severe decline Control of an adaptable pest Some comments on existing strategies What options might be considered to reduce cane toads Appendix one: arguments against the "toad virus GMO" Appendix two: photos of sick cane toads Appendix three: photos of sick, cancerous and malformed frogs

What is the frog hospital, briefly

We are an award-winning frog conservation organisation that specialises in frog health, rescue and recovery, and investigation of the causes of frog decline. We have been operating since August 1998. You might categorise us as 'citizen science'. We include sick toads in our activities because the information they provide is important to better understand our environment.

We have catalogued a very sharp decline in cane toads from the Cairns region of FNQ since the firstsick ones started being found in 2002 during a Fusarium outbreak in the frogs. At the time, we were receiving calls from residents in a wide geographic area who were finding "sick and dead frogs, toads and snakes" on their properties. Extensive lab work eventually narrowed down the problem to a species of Fusarium which is a drought-tolerant soil fungus having about 50 species inits genus (same genus as TR4/Panama disease in bananas). Since then, the situation for cane toads has become exponentially worse.

Cane toads in FNQ are in severe decline

Following the Fusarium outbreak, bacterial infections were frequently found (see appendix two for photos). Emaciated toads were and are frequently seen but any pathogen will cause a toad (or frog) to stop eating. Cyclone Larry (March 2006) introduced cane smut (Ustilago spp.) to the far north. A large outbreak occurred in frogs where every frog in most backyards was killed within three weeks of the cyclone. (The IDEXX lab in Brisbane identified the pathogen in faecal slides as a

Inquiry into controlling the spread of cane toadsSubmission 24

heavy infestation of the yeast Ustilago.) While we were inundated with sick frogs from this event, we were not looking for sick toads but expect by their biology that they would have been affected.

After cyclone Yasi in Feb 2011, problems with protozoa appeared in the frogs which were partially documented by labs including cryptosporidium. Parallel to our seeing this in frogs, the Wildlife Health Australia newsletter carried news items from people working with other wildlife who were finding myxozoan protozoa and others in macropods, etc. Considering the range of animals that suddenly had issues with protozoa and the fact that we were having problems clearing them out of frogs as well, the toads are likely to have them too. There was even a new protozoa (Entamoeba) discovered in sick cane toads from the Territory (refer to Rick Shine's submission).

However, the greatest assault on cane toads came in Jan. 2003 just as the drought was ending. My strong suspicion is that a new chemical hit the market during the drought (Jan 2000 to Dec 2002) but didn't start circulating in the environment until the drought was broken. Whatever this chemicalis (there were over 900 entries in the list we obtained from the APVMA), it has had a strong and permanent impact on frogs and toads. When we would sample the small number of 'toadpoles' we were finding, about half would literally drop dead in the nets. Those that survived the trip home were perfectly healthy and active for 48 hours; then the entire tank would die off in the next 48 hours. Out of over 3,000 toadpoles sampled from ten different Cairns sites, only two individuals survived to metamorph and they were the wrong colour (grey instead of brown). Changes in pigment is a diagnostic of this problem in various frog species as well, especially tree frog species (Litoria caerulea is permanently blue/blue metal and L. gracilenta is permanently yellow).

Hatching failure is also rampant now with both toad and frog eggs. Now that we are located in Mission Beach, we are seeing the same problems here as we did in Cairns. Most of the tadpoles we raised last year had the same bent tails and scoliosis. With recent heavy rain in FNQ, puddles are common. Last year, many puddles had frog tadpoles but no toads. Most of the same puddles this year had neither frogs nor toads. There was only one spoon drain in Wongaling that I found 'toadpoles' this year and I collected about 30 along with some frog tadpoles. After two months, the toadpoles had hardly grown (they are supposed to complete their development in about three weeks). When they finally reached the stage of back legs, they died.

Frogs and toads are severely affected by this 'mystery chemical' and malformed ones with zero chance of survival in the wild are now the norm up here. But deformed frogs have also turned up inother states and the pet trade. It is devastating when we receive calls from rescuers in other states who have saved tadpoles from dwindling puddles only to see them distort before metamorphisis anddie. Recently we had a call from someone in VIC who was trying to raise the Endangered Litoria aurea tadpoles - only to have them die from this scoliosis-related problem. Whichever chemical this is, it is genotoxic and teratogenic and it needs to be identified and banned urgently.

note the bend just above the ankle joint - this is diagnostic in several frog species affected

stunted growth, short lifespan, scoliosis- L. caerulea is the most commonly affected species that survives past metamorphosis


Even neoplasias are being found in cane toadsfrom remote areas such as the Kimberley - thisphoto sent to us by the Kimberley Toad Bustersappears to be an osteosarcoma (we know thatbecause the same tumour was documented in afrog from Cairns).

Due to the increased susceptibility of toads toopportunistic pathogens and the sharp decrease insuccessful reproduction, cane toads along the farnorth coast are declining even faster than thefrogs are (and I have described the decline offrogs in the Cairns region at 95% since 1997).The only places that might still have good toadnumbers are those pockets that are upstream ofany human presence. As soon as you are withinor downstream of housing or any other development, chemicals are relied upon as a first response inany and all circumstances and our wildlife is paying the price. In fact, the first malformed specimens came from residential suburbs - not agricultural areas - so the suspect chemical is used inhouseholds and might well be a termiticide.

If the government were to conduct proper research into chemical levels in all wildlife, you would uncover plenty of evidence to start banning these noxious concoctions. You should start with the neonicotinoids and fiprinol. Synthetic pyrethrums are another likely antagonist. The kinds of health problems my organisation has documented were NEVER seen prior to 1996 which is when we believe the first of the neonicotinoids and fiprinol entered the market. Of note is that 1996 is when other serious wildlife health problems suddenly appeared including Lyssavirus in bats and transmissible cancer in Tassie Devils. Is chemical contamination the hidden driver of these pervasive threats? Within a year of the uptake of the neonics, Cairns residents started to find sick and dead White-lipped tree frogs (Litoria infrafrenata) in their yards. We started up our operation the year after and have documented health issues in all species of frogs and the cane toad. When I speak to the public about the loss of cane toads, I emphasise that our environment is now so polluted that even the "can't kill'em cane toads" cannot survive. I should think the government would be interested to know this and investigate.

Control of an adaptable pest

Control of cane toads needs to be tailored to where they are. They occupy many different scenarios such urbanised coasts, agricultural areas and expansive landscapes in wet tropics, dry tropics, arid and temperate zones. Given that cane toads can actually adjust to lower temperatures, they are verycapable of surviving in the southern states. Each of these zones will favour certain strategies over others. Your best approach is to tailor the control method for the local situation. Trapping toadpoles or adults in landscapes seems to be the preferred method while organised volunteer collection in urban areas would be best there. Traps and fencing appears to work best in arid areas but is not as successful in the wet tropics because there is water everywhere and the toads don't need to visit a trap to access it. See the last section of this submission for suggestions.

Here in FNQ where the toad has been resident for 84 years, many native animals have taught themselves how to consume cane toads without ill effect. I have seen kookaburras eat whole cane toads but several species of birds and rats up here also kill and eat body parts of toads while avoiding the paratoid glands. The Keelback snake is often noted as unaffected by toad toxin but I have heard comment that they only eat smaller toads with less toxin so some clarification might be needed on the true situation.


Some comments on existing strategies

bashing: There has been a perverse humour about nasty ways to get rid of cane toads but society is finally getting turned off by the sheer volume of violence, abuse, cruelty and disrespect that is woven into human behaviour. People are developing more compassionate attitudes. Our site includes a page on disposal in the cane toad section and we have photos there of a toad that was viciously attacked by some sadistic bastard and then let go to die slowly. We discourage the public from all violence against animals including pests. All animals can suffer (even plants have been documented to communicate when they are injured).

CO2: Organised toad busts obviously need to dispose of large amounts of toads but the reality is that garbage bins piled with toads are not being killed by CO2 gas but rather by crushing and suffocating those not on the top of the pile - which is not humane. If however, a special trailer was made with trays that slide in and out of an internal rack, this would allow rows of toads to be placedinside and then the unit could be gassed by a built-in system. Toads could then be easily disposed of to a specific end-purpose (see suggestions section) by removing the tray and tipping.

toad busting: While it is great to have public participation to collect toads, a lot more pre-event education needs to happen to make sure people do not collect frogs instead and are not putting suffocating toads in garbage bags or other unacceptable actions before they get to the 'base camp'. This also needs to be a regular activity to actually clear the toads and not just the 'odd' event every so many years.

pithing/decapitating: Only to be used by professionals who can be accurate the first time.

freezing: We do NOT recommend this to anyone unless the toads have been chilled first. Direct freezing is not just inhumane - it is protracted torture. Just take anything out of the freezer and try to hold it for as long as you can - the pain will prevent you from holding that item for more than 30 seconds! Imagine having that item tied to your hand for a couple hours. Chilling must be used first.Here is our own procedure for culling toads - not that we bother anymore with any collection since toads here have become so thin on the ground. In contrast, we actually find the cane toad to be a good sentinel to alert us to frog problems.

1) collect toads and put into plastic boxes with air holes; we only put in as many as will cover the floor (no overcrowding)

2) dissolve a tablet of panadol (or panadeine) in a 400 ml jar of water3) pour the dissolved pain relief into the container of toads and leave them in a quiet corner for

an hour to absorb the medication4) place the container in the fridge for overnight; by morning, the toads are comatose/torpid 5) move the container to the freezer for at least a couple days before burying or putting in the

bin the morning of collection6) wearing gloves, wash the plastic container out for re-use

trapping of adults or tadpoles in purpose-built traps: We have not used any of these traps as we prefer manual collection but the descriptions I've read describe them as functional. So long as they are specific to toads and don't catch or minimally catch non-target species, we can support their use.

Dettol: We do NOT recommend this to anyone. Dettol does not kill toads outright but merely paralyses them by 'short circuiting' their central nervous system. The toad actually takes up to 24 hours to suffocate.

"Hopstop" (aerosol product): We understand this to be a reformulated version of Dettol and is apparently based on the same chemical (Xylene - which is an irritant to asthmatics). You need to bewithin 30cm to spray the toad which is actively fleeing so most of the chemical product ends up on the ground. Since we don't know the environmental implications of that and the company did not respond to our questions when we tried to ask, we do NOT recommend Hopstop.


"Croaked" (product): While it is refreshing to see a product based on a more natural substance (clove oil), this product is a threat to waterways because clove oil can kill fish. From the Croaked product label:

"CAUTION: DO NOT spray directly on humans, pets, exposed foods, water, food preparation areas or food utensils.DANGEROUS TO FISH. DO NOT spray on, or within, 1 metre of fishponds or waterways, particularly under windy conditions, to avoid contamination from spray drift. Toxic to aquatic life. DO NOT allow chemical containers or spray to get into drains, sewers, streams or ponds.Avoid spraying desirable grass or plants. May cause yellowing of plants. Plants generally recover.DO NOT use this container for any other purpose"

Why has the APVMA registered such a product for public use? If it is bad for fish, it will almost certainly be bad for frogs; and since it has to be sprayed with 30cm of a toad that is running away from you, most of the product will end up in the environment - not on the target. We will not recommend this product to the public.

biocontrols (CRISPR, toad-specific rhabdias lungworm, daughterless tech, gmo viruses, any self-replicating agent): Society has a fascination with any kind of 'new technology' but I would describethat by using that old saying, "curiosity killed the cat". Aside from the ethical considerations (we are not gods and have no right to play with the 'fabric of life'), new technology usually creates new and overly complicated problems. It's a hook that lures the uninformed to take a bite and become dependent (like wireless communication, for example) but the downsides when that technology goes wrong are often irreversible. The original release of the cane toad was itself a 'biological control' that has created a massive problem that has already wasted millions of dollars and is not even stabilised.

My view is that NO biocontrol can be considered while the government has NO idea of the big picture. Declines are now widespread across many taxa and chemicals are undeniably involved. However the government does not support any toxicological research streams and some researchers who want to go down that line have had to resort to crowdfunding to pay for it. The incredible sea turtle toxo program from last year needed WWF to support it. Because of this obvious lack of official interest in testing all wildlife declines and disease situations for chemical involvement, the government therefore is missing out on critical knowledge and is not making fully informed decisions on matters which could impact wildlife. Meanwhile species continue to decline and academics scratch their heads in bewilderment. (Examples: birds with PB&FD; tassie devils with transmissable cancer; sea turtles with papillomas; viral transmission in bats that did not exist prior to 1996; FNQ frogs with cancer, opportunistic pathogens and malformations (see appendix three); cane toads with Entamoeba, vanishing insects and bee die-offs, large fish kills, etc.) Into such a "pea soup" of pathogens growing stronger and the immune systems of unintentional targets getting weaker - comes this notion of using GMO viruses and other "tweaked" biologics that can very easily backfire and wipe out the wrong targets. We are opposed to any controls based on modified pathogens being used in the environment until the influence of sub-lethal doses of chemicals on biodiversity is fully understood. This is especially so when a GMO intended for toads might backfire and wipe out an already severely compromised frog population (see appendix one for comments on "virus wars" that are created since pathogens - natural or engineered - do not respect national borders).

What options might be considered to reduce cane toads

People too often want to have a 'silver bullet' approach to everything to make life easier (provide an excuse for laziness) so that we can spend more time in front of the TV while the problem magically fixes itself. But the reality is that sometimes we just have to roll up our sleeves and do things manually. What options does our group suggest?

• In urban areas, 'people power' is the most applicable. When you look at the impact groups of people have achieved in their own regions over a short period, 'people power' is proven towork but it is only temporarily effective unless it is maintained over time. This is difficult


when you are working with volunteers. A coordinated program with paid staff (the 'toad team') would build on what volunteers have done and this might be facilitated by regular 'road shows' where regional toad busting can be properly coordinated and the volunteer participants properly educated.

• Disposal of toads needs to be value-added. Mentioned earlier under the comments on CO2 was the idea of a special trailer which contains racks and slide out trays. Once euthanaised, the toads should be put to some beneficial purpose. There have been proposals for fertilisers, use of their leather, or export to China for herbal medicine but these haven't cometo fruition. Some R&D should be applied to this problem. Why is it we can further a high-tech response but it seems to be so difficult to find a simple manual solution?

• The 'toad team' can also function as extension officers to agriculture and other acreage owners. There are ways those land users can make strides to protect their water resources from toads or use trapping methods to selectively reduce them but they need guidance and support to follow through.

• Landscapes and arid country could be targeted by the adult and tadpole traps described in other submissions.

• More public education is needed to ensure that the unwanted toad is eliminated humanely orprevented from breeding in backyards. This would be another part of the job description forthe 'toad team'. Keeping in mind that young people now have devices seemingly growing out of their hands or attached to their ears, perhaps a mobile app can be developed which offers suggestions for toad removal for various settings and demonstrates the key features ofhow to tell a frog and toad apart at all life stages.

• The Australian government has laid out a red carpet for GMO's and presumably CRISPR butthis is NOT in accordance with the 'precautionary principle' when it comes to environmentaland human safety and needs to be put on indefinite hold until we fully understand how chemicals are undermining all declining species in this country and driving pathogen evolution and resistance.

• Earlier work was done to send researchers to the cane toads' origin to look for the ways its population is kept in check. This approach might need some fresh eyes to look at the detailsof the environment in their natural home. Something has been missed by the earlier team that might still be discovered. However, knowing the answer might not provide a solution toour situation here as we would not want to import any more exotic species.

The committee is welcome to contact me if you would like any further elaboration or for more information about the severe decline of the cane toad from the wet tropics. Thank you for conducting this review.

Sincerely,Deborah Pergolottiwinner: Cassowary Award, Centenary MedalFounding President of Frog Safe, Inc.


Appendix One

From the Frog Safe, Inc. website, Cane Toad sectionThis page presents arguments against one type of genetically engineered approach to eliminate canetoads using "technology". Academics can put forward convincing project applications to explain how such-and-such project will solve all our problems -but all of these proposals need to be evaluated for true risk and ethical considerations such as, "do we have the right to play God with thefoundations of lifeforms"? There are points made in this page that will be relevant to many other 'engineered' approaches proposed for cane toad control and elimination.

The "Toad Virus GMO" Project (Commonwealth level)When Kevin Rudd became Prime Minister in 2007, a review took place of many scientific projects and several were cancelled. One of the cancelled projects was the toad virus GMO project. While there were probably economic reasons for this, we must loudly applaud this action. On first glance, voters might gasp at the seeming abandonment of an effort to control toads - but this was one project which really was too risky to ever contemplate. Our original arguments against this project remain here on this page so that you can understand why high-tech genetic engineering is NOT the way to get rid of this pest.

If you believe the Australian TV show '60 Minutes', this project is the 'silver bullet' that will magically remove all cane toads from the Australian environment. However, this is an illusion and there is a genuine risk that the disease being genetically engineered might become a pest itself . . . . to Australian frogs, reptiles and fish. In fact, it will not be possible to contain the virus within Australia so being in the US or Europe or Asia isn't going to afford any protection to your cold blooded wildlife either. Why do we feel so strongly against this project? We'll be glad to tell you!

Back in the 1980's and 1990's, the Australian government funded a variety of projects and studies which were meant to collect information that might be useful towards eradicating the cane toad from Australia. One of the projects involved sending some Australian ecologists to the toad's original sources (Venezuela and Brazil) to determine if there was a specific reason why the toad was not a pest in its native habitat. Aside from some parasites, nothing much was found that would explain what was keeping toad numbers in check. But Australian researchers did learn that there were ranaviruses/iridoviruses there and some of these were transported back to Australia where they are stored at the Animal Health Lab in Geelong.

Another of the projects which received copious funding at that time was to genetically engineer one of these Venezuelan ranaviruses into something which would kill toads and not kill frogs. We have been provided with a small stack of documents and we do know that the government decided to abandon the work in 1996 after they discovered that an Australian frog (the White-lipped tree frog, Litoria infrafrenata) could be easily killed by the GMO virus (GMO = genetically modified organism) they created.

Thinking 'that was the end of that', it came as a surprise to us to learn that a new, five year project at a cost of AUD $3.5 million was in well in progress and this project was back to using the same old virus drawing board - modifying a ranavirus (iridovirus) that was going to stop toads from metamorphosing while not causing disease in Australian frogs. This work is different from the previous virus tampering because the virus is not being used as a 'kill mechanism' itself but rather as a transport unit for a toad gene that has been modified to malfunction.

The chosen gene they've isolated in the toad is the one responsible for triggering a tadpole to metamorph and this gene was identified in the toad genome towards the end of 2003. The next intended step is to find a way to removethe ability of the virus to cause disease (this is called 'attenuating the virus' - (if indeed that is actually possible) and then to get the virus' DNA to accept and carry the modified toad gene. According to their plan, the virus will still reproduce itself with its passenger gene and spread in the environment but it won't cause disease. If we understand correctly, the virus is meant to merely deposit the toad gene in the body and, if the body is a toad, the modified gene will infect and/or replace the original gene already in the toad's DNA. Then the mutated gene is what will be reproduced and passed on to the offspring (toadpoles) and prevent metamorphosis. If it passes to a frog, in theory the toad gene won't do anything because it is a toad gene and the frogs don't have this same gene inthem.


We are grateful that the Rudd government cancelled this project and feel this approach should never be contemplated again, especially when Australian frogs AND the cane toad are already in decline in this country andnot attracting the sort of research that should be taking place.

A) Exposure to a virus can cause the target animal to mount an immune response and generate antibodies to that virus instead of getting sick (this is how flu shots work - by exposing a person to low levels of a virus to trigger them into generating antibodies). Antibodies to ranaviruses have already been found in Australian cane toads which means that those individuals have been exposed to a ranavirus here in Australia and they have put up a resistance to it.

• So the first concern is that there are already virus problems here in Australia that have never even been isolated and characterised and the government wants to deliberately introduce another one.

• The virus they want to modify is a ranavirus and they already know that toads are capable of generating antibodies to it. The myxomatosis virus they released is not effective against rabbits in wetter parts of Australia because it turns out that there already was a myxomatosis virus present in the wild and the rabbits had developed an immunity to it; when the 'modified' virus arrived in those areas, it didn't work (Surely the authorities knew that there already was a rabbit virus here before they released another one?)

• The third problem is that ranaviruses are a threat to all cold blooded animals including frogs, fish and reptiles. The last time they 'played with' a ranavirus, they proved it could kill frogs and yet they persist in chasing a ranavirus as the first, last and only choice for this work.

B) Viruses are very fluid in nature and they change and adapt readily to environmental conditions and stresses. New strains of flu appear all the time - SARS had a new strain shortly after it was discovered and new human and animal virus problems are in the news regularly. Influenza A also has multiple strains (pathogenic and non-pathogenic). Some virus groups also skip over to different taxa when they mutate - Mad Cow disease only attacked cows until a new strain emerged that specifically targets humans called Crutzfeld Jacob new var..

There are two types of viruses: RNA and DNA. The Bohle Iridovirus (an Australian endemic) has been chosen formanipulation and it is a DNA virus. DNA viruses take a bit more nudging to mutate but they still can change. The bottom line is that no matter how much testing the government does on non-target species (and there are an awful lot of them to test - 220+ frog species, 200+ freshwater fish, all the snakes, skinks, geckos, turtles, etc.) before thisvirus is released, the government can never guarantee that the GM virus won't mutate once it is released into the wild.

C) During the field trials for two other pathogenic viruses that were engineered/released in Australia, those being myxomatosis (known as Rabbit Viral Haemorrhagic Disease (RVHD) overseas) and calicivirus (distinguished as RCV or Rabbit Calicivirus overseas because of the number of calicivirus strains overseas that attack specific animals such as reptiles, humans, etc.) the virus being tested 'escaped' into the wild during both field trials. Our President has raised the question about improved security during field trials and clean up and contingency plans incase of an escaped pathogen on repeated occasions and has never received an answer other than "but we've learned so much since then". We do not understand how any field trial can be conducted using a volatile, environmental pathogen in the wild in the absence of any containment plans.

D) The planet is a living organism (GAIA) with circulating water and air systems as well as a lot of people and cargo movement. It would be physically impossible to contain a virus within Australia's borders. It is only a matterof time as to how long it would take for a virus to get from here to somewhere else. And a virus, being able to mutate according to changing environments, is sure to start adapting once it arrives somewhere different. The Australian government doesn't want rabbits here, for example, but that doesn't mean that other countries feel the same way. We have received reports of expensive efforts being made by the US, Spanish and Mexican governments to get rid of calici and/or myxomatosis (RVHD) because they DON'T want these viruses to wipe out their rabbits. For any country to introduce viruses to kill imported animals only leads to a "virus war" with the countries where those animals came from and the countries who welcome the importation of those animals.

Even if viruses were more stable, pathogens which are foreign to the areas they reach are more deadly because theanimals have not evolved in conjunction with those diseases. For example, a virus that evolved in the Congo might cause incidental death rates to the animals that evolved with it in the Congo, but the same virus would be capable of massive death rates to the animals in Canada, or Thailand or Europe. Likewise, if the Congo started to import foxes or some other trade animal which is not normally found in the Congo, those imported animals would


have no resistance to the local Congo diseases. The virus to be modified against cane toads (Bohle) is an Australian native and endemic virus so one could logically expect that if that GMO reached Europe, Asia or the Americas, toad species there will have no resistance at all to it and casualties would be high. There are endangeredspecies of toads in these areas which already have threats to struggle against - a foreign virus could well wipe them out.

E) The sort of engineering that is being experimented with is a venture into new ground. We're not going to get involved in the philosophical or religous aspects of 'playing God' with the genetic fabric of life or creating new ways of destroying life. But the idea of introducing genes from one animal into others where they don't belong is aconcern to many people. How do these researchers know what will actually happen when an outside gene is introduced to a foreign organism?

F) Our Founding President attended the CSIRO workshop on biological cane toad control in February 2004 and the information which was shared at that meeting can only be viewed as proof that the GMO virus will NEVER work. This is why:

• The ranavirus they have chosen to work with is Bohle Iridovirus which is endemic to Australia. This is most likely the virus that cane toads here currently have antibodies to, so all the toads innoculated with antibodies already will be immune to the GMO virus.

• Bohle has a temperature threshold! It is disabled at 34 degrees C and killed off at 42 degrees C. This means that it will be practically useless against toads in the entire Top End of Australia so another control mechanism will need to be found for the northern third of the country.

• It is a desired criterion for biological control methods to be designed to phase themselves out as their target is eliminated which is not at all the case here. Once the GMO virus is out there, it will always be out there (even if there are no more toads) unless it is killed off by high temperatures.

• A native virus is being used as the control mechanism and that virus is going to be weakened (attenuated) to the extent that it is incapable of causing disease -- but the GMO version is going to be released into the same areas that the wild type, original virus already lives. The ecologists at the meeting expressed the view that the attenuated (GMO) virus would not reproduce or spread properly since it was going to be in direct competition with its stronger, original self. Another worry was that the wild type and modified viruses could combine (see next point).

• Another lovely thing that viruses can do besides mutate is to recombine (this is not the same as recombinant) with other viruses to create entirely new ones. We know that cane toads are already dying here from a suite of problems that still have not been formally identified, so the notion of just dumping a new virus into what is already a disease "bouillabaise" is a really bad idea that can have unpredictable results. There can be no consideration of releasing a new virus into the environment until they have done a full survey of diseases which are already killing frogs and toads around the country. [Additional comment: there is already extensive chemical and metals contamination right around this country and this will be playing a major role in disease problems in native wildlife and introduced species. Until this contamination is fully surveyed and connected to species declines, no genetically engineered organisms should be pursued at all.]

We fully understand that the toad is pest in Australia and if you read through our other pages in this site, you will see that we promote targeted, humane disposal of this pest. But our opinion is that viruses are just too volatile to be playing with in a lab and then expecting that they are going to remain static and immobile in the wild. We are also dismayed that so much money is being dumped into this god-of-the-genepool approach that our genuine problems of diseases wiping out frogs (and toads) are again being completely ignored.


Appendix Two

Photos of sick cane toads from FNQ(this is a separate file)

Appendix Three

(this is a separate file)Please note that due to the lateness of this submission and the committee's interest in our fastest possible turnaround time, we are providing the document that we presented to the previous Threatened Species Commissioner. Note that our contact details have changed. If you have a way of blocking those out before publication, that would be appreciated.





Inquiry into controlling the spread of cane toads submitted by em

Documents