GM Free Cymru Response to ACRE Consultation
Press release 3rd May 2006 from GM Free Cymru
Consultation on the ACRE report on “Managing the Footprint of Agriculture: Towards a Comparative Assessment of Risks and Benefits for Novel Agricultural Systems” Wider Issues Subgroup
http://www.defra.gov.uk/environment/acre/fsewiderissues/index.htm
Consultation Response -- deadline 9th June 2006
We note that this report was announced and was made available for consultation on 17th March, at the height of the Curitiba meetings and the fuss about terminator technology, with the invaluable help of Fiona Fox and the Science Media Centre. News management at its best! Although we were not included in the list of consultees, no doubt because of an oversight on your part, we are happy to respond to the document in question.
1. It seems to us that the purpose of the Report is to suggest that GM crops are not really any more harmful then any other "novel" crops, and that they are over-regulated by comparison with other crops. ACRE would clearly like to see the current tight regulation, under the terms of Directive 2001/18/EC, replaced by some sort of cost/benefit analysis. The document describes something called a "Comparative Sustainability Assessment" (CSA) which, if adopted by the Government and applied to all novel crops, will no doubt keep the ACRE secretariat and committee members gainfully employed. We are totally opposed to any attempt to undermine or dilute the importance of Directive 2001/18/EC in the assessment and regulation of GM crops; no matter what ACRE may feel, these crops are different in kind to all other crops, and are associated with a unique set of environmental and health dangers. The uncertainties associated with GM safety and environmental impacts were flagged up by the EC in its "defence case" in the recent WTO trade dispute with the USA, at the same time as the Commission was cynically issuing consents for new GMO releases into the environment and assuring the public that every single approved GM variety had been proved to be entirely safe. In summary, we do not feel that GM varieties are "over-regulated"; on the contrary, the case of the GM peas in Australia has shown all too clearly that the regulatory process in Europe (and that includes the UK) is far too lax.
2. The report mentions that there is too much concentration in the regulatory approvals process on the negative or harmful effects associated with GM varieties, and not enough opportunity for the regulators (including ACRE) to assess any benefits arising from GM crop plantings. We find this a bit rich, to put it mildly, since the whole approvals process is designed to facilitate (a) the submission of favourable or supporting evidence by the GM corporations applying for consent, and (b) to assist applicants in obtaining consent as smoothly as possible. It does not seem to have occurred to ACRE that this process is itself corrupt, since it is based upon "advocacy science" commissioned and carefully selected by the applicant corporations, and since the science is in many cases non-replicable since the corporations will not allow "independent scientists" access to their plants and seed stocks. The recent case in which Monsanto shut off supplies of MON810 seeds to Hungarian researchers (when they started to find uncomfortable evidence of environmental damage) illustrates this perfectly. In our view there is far too much emphasis on the beneficial effects of GM crop plantings already, and until there is greater objectivity in the science surrounding the approvals process, we would be absolutely opposed to any move designed to give ACRE a role in flagging up the benefits of GM crops or otherwise promoting their benefits to a sceptical public.
3. In our view there must be no dilution of the Environmental Risk Assessment Process associated with applications that fall under Directive 2001/18/EC. In fact, the process should be tighter, with ERAs undertaken by genuinely independent research teams and paid for by the applicants for consent. These applicants should have no role in choosing the consultants. We are aware that EFSA is attempting to push the idea of ERAs being undertaken in future by accredited bodies which have a sufficient capacity and competence for the work. That immediately starts alarm bells ringing. We foresee that the "best" bids (ie those which can be counted upon not to cause too much trouble) might well come from the advisory committees (like ACRE) or Environmental Ministries of those EU countries which traditional vote for approvals and back up the "opinions" published by EFSA. That would be to add another layer of corruption to a system which is already corrupt -- and this is apparently something which has already been noticed by many of the Environment Ministers of the EU.
4. There is a certain smugness in the Report relating to the conduct of the FSEs and the results that came from them. We are aware that ACRE advised that the field trials of GM sugar beet and GM oilseed rape demonstrated environmental harm compared with their non-GM counterparts, and that it advised that GM maize would not result in adverse impacts "if managed as in the FSEs". We are also aware that there are differential and harmful effects on wildlife associated with all conventional (and especially high-input) farming systems and crop management regimes. But we have criticized the FSEs as being highly flawed, and as you will be aware we do not believe that the null hypothesis was adequately tested in any of the trials because management procedures were manipulated and did not replicate real farming conditions. Also, the most meaningful comparisons (with organic or low-input farming regimes) were not effectively made. The wording in your report is carefully crafted to give the impression that some GM crops may be slightly harmful, but other conventional crops are even more harmful. That again skates over the crucial point that GM crops (for example those containing Bt toxins) are UNIQUELY DANGEROUS AND UNIQUELY UNPREDICTABLE IN THEIR LONG-TERM EFFECTS.
5. We applaud the involvement of ACRE in work designed to more accurately define harm, and in the work looking into pesticide effects. However, we are concerned that ACRE might seek (as EFSA is doing) to redefine the word "harm" to mean precisely what you wan it to mean, so that it becomes "significant ecological damage" or some such thing, with fuzzy (and very convenient) greyness surrounding the whole term. There are plenty of cost-benefit analyses going on already, and we want ACRE to concentrate on protecting the public and the environment from damage. Let others (including the seed merchants and the NFU) flag up the supposed benefits of GM crops if they want to.
6. We are not at all happy with the Illustrative examples included in the document, and ACRE bias towards GM varieties is all too clearly seen. Here are two quotes: On Bt cotton: "Compared to cotton sprayed with insecticides, Bt cotton has major benefits in terms of the environment, yield security, and human health. The environmental disbenefits appear marginal by comparison." On Bt maize: "The use of Bt maize has provided farmers with more security and higher yields. A large body of research on the effects of Bt maize on not-target arthropods has not shown any ecologically significant negative impacts in the field." Those statements are both travesties, and we cannot understand why they were not modified by ACRE committee members during the editing process on this document. At the very least, the "conclusions" should give greater weight to the appalling evidence now coming out of Europe, India and Australia which shows that Bt varieties are capable of inducing toxic shock in mammals, allergic reactions among humans, and a great deal of harm (and we use that term advisedly) to soils and the environment generally.
In conclusion, we have fundamental disagreements with ACRE on a wide range of issues, and we would be opposed to any role being given to ACRE which would give that body opportunities to flag up the supposed benefits of GM crop plantings in the UK and Europe.
We may submit further comments on this document before the deadline of 9th June 2006. If you require a fully referenced version of this submission, please let us know.
Yours sincerely,
Dr Brian John GM Free Cymru
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The ACRE sub-group currently has the following terms of reference:
To advise ACRE on the wider implications of the farm-scale evaluation (FSE) results with respect to the deliberate release of genetically modified organisms into the environment. To advise on the implications of the FSE for the scientific assessment of the environmental impact of agriculture generally, including advice on the appropriate objectives for environmental protection in farmland including the baselines against which the risks of the deliberate release of genetically modified should be compared. To advise on the assessment of adverse effects with respect to agricultural management (building on the work of previous ACRE sub-groups) in a way that is consistent with government objectives for enhancing farmland biodiversity. To advise on the extent to which the assessment of indirect environmental benefits is relevant in the assessment of GM crops. To advise on issues arising from the use of comparative risk assessment methods in assessing indirect management effects of GM crops (building on the work of previous ACRE sub-groups). To advise ACRE and ministers of any discrepancies in regulation that hamper the assessment of GM and other crops and management practices. To advise ACRE on any new research needs to address the wider implications of the FSEs.