GM Free Cymru

To the PM: Please vote against the growing of Pioneer 1507 maize in Europe

Date Added to website 18th December

This is the text of a letter sent to the PM and the Deputy PM -- urging them to use sound scientific evidence as a guide on how to vote when this proposal comes before the Agriculture Committee in the spring of 2014. We urge the UK to vote against the proposal and to follow the lead of the EU Environment Committee, which voted
today against the authorisation of this uniquely dangerous maize:

There are a number of very powerful reasons why this GMO maize should be kept out of Europe. We just hope that the Government has enough intelligence to take on board the messages coming from scientists and politicians from many countries -- and that it will take note of the recent EU Court ruling (in the case of the Amflora GMO potato) that EFSA / EC authorisation procedures are deeply defective and in some cases unlawful.

Rt Hon David Cameron MP Prime Minister 10 Downing Street London SW1A 2AA

Rt Hon Nick Clegg MP Deputy Prime Minister Deputy Prime Minister's Office 70 Whitehall London SW1A 2AS

16th December 2013

Dear Prime Minister and Deputy Prime Minister,

Proposal for Pioneer GMO maize 1507 to be cultivated within the EU

In the coming weeks either the Environment Committee or the Agriculture Committee of the EU will be asked to vote on the authorisation of Pioneer GMO maize 1507 for cultivation within the EU. If authorised, this would be the second GMO maize crop to be allowed in open-field plantings within the EU, after MON810 maize.

We urge you to vote against the Commission's proposal in this case, because there are fundamental flaws in the procedure being followed by the EU and because in our view its authorisation would be illegal since EFSA and the Commission have not required the submission of full supporting materials and evidence from Pioneer, as required by the relevant directives (1). As you will be aware, the consent for the GM Amflora Potato was recently annulled by the General Court of the EU because the EC had broken its own laws in issuing consent.

We respectfully draw your attention to the following scientific points:

1. It is accepted by EFSA (in its 2011 revision of its opinion on the cultivation of Pioneer 1507) that this GMO variety can harm non-target insects like butterflies (2). This being the case, at the very least there should have been a proper ecological or environmental impact study submitted by Pioneer; but it has simply refused to do this, and has depended instead on very flawed modelling exercise based largely upon untested assumptions. In these circumstances, it must be assumed that Pioneer accepts that there will be substantial negative environmental effects; and on this basis the application MUST therefore be rejected.

2. Variety 1507 is a complex variety with two main traits -- BT and herbicide tolerance. Unintended combinatorial effects have not been adequately described. It is known that it has unusual gene fragments in the genome which might or might not indicate instability and unintended toxicity. There can also be combinatorial effects from spraying residues and BT toxins which can act as co-stressors. On this basis alone, it should be rejected in the interests of precaution.

3. It has a marker gene that confers tolerance to the highly toxic herbicide glufosinate or Liberty, which features on the Pesticide Action Network Highly Hazardous Pesticides List and has health impacts including brain and neural damage to developing embryos (3). The impacts on the environment of blanket spraying of the crop have not been assessed by EFSA. Glufosinate will be banned from use in Europe in October 2017, but it WILL be used in the cultivation of Pioneer 1507 if it is planted, and residues WILL find their way into the food chain. It would be nonsensical for the EU to be seen to be banning a very dangerous chemical with the one hand and encouraging its extended use with the other. On this basis alone, the only logical course of action is to reject the Pioneer application.

4. As other organizations have pointed out (4), there has been no assessment by EFSA of the impact of the crop on pollinators. Neither has EFSA forced Pioneer to make such an assessment. Again this indicates that -- not for the first time -- EFSA has failed to follow its own guidelines and has therefore acted illegally prior to recommending consent.

5. There has been no risk assessment of the pollen in foodstuffs such as honey. The content of the BT toxin in pollen is very high compared to other genetically engineered plants. In fact, on the pollen issue Pioneer refused to make the modifications to its notification that the Commission had asked following EFSA's recommendations for risk management. Again, if Pioneer cannot be bothered to cooperate with reasonable requests, it does not deserve to obtain a consent in this case or any other case.

6. Pioneer 1507 was developed partly to resist the depradations of the European corn borer, but the toxic insecticide produced (Cry1F) is 350 times more abundant than that produced by Monsanto's MON810 maize – the only other GM crop commercialised in the EU. In addition to the inevitable effects on non-target organisms, experience in the USA and elsewhere shows that "target" insects will adapt and develop immunity after a few years -- and this will result in even greater chemical assaults in association with the growing of the maize crop. This situation is unsustainable and indeed nonsensical. (5)

Turning to political and legal matters, we respectfully draw your attention to a number of matters:

This Government says that it prides itself on its "science-based" approach to GMOs. In this case, we submit that there is NO scientific case for the approval of this maize; the scientific information submitted by the applicants is so weak as to be almost laughable. In addition to these technical / scientific matters relating to the application and assessment process, we ask you to consider the following.

First, the Commission is seeking to establish a new principle whereby it authorises GMO varieties for cultivation in Europe under a "fast track" procedure (largely in order to satisfy the Americans and the WTO) while "relinquishing" powers to the member states to bring in national or regional bans if they so wish (6). This is disingenuous and quite unworkable -- as many other EU laws would be broken in the process, leading to endless litigation and a chaotic situation both in agriculture and in the marketing of GMO food products across national borders. Poorly tested and unwanted products, which might well also be dangerous to health, must NEVER be authorised in the EU simply to satisfy the demands of the biotechnology industry or foreign trade organizations. The health of European citizens must be paramount at all times.

Second, the Commission pretends that it has no option, following the court judgment of 26 September in favour of Pioneer, other than to issue a consent to the maize 1507 applicant. That is incorrect. The court found in favour of Pioneer (7) simply because the EC had taken far too long to come to a decision on an application first made in 2001. It should have given either a consent or a refusal many years ago. The EC should, in response to that court ruling, have made an immediate recommendation for REFUSAL on the grounds specified above in points 1 - 6. EFSA does not issue consents. The EC issues consents after consultation, and it is at liberty at any time to either refuse or accept the advice of EFSA if it feels that it is out of date or in some way scientifically inadequate. In the recent court verdict, the EC was heavily criticised for basing the Amflora GM potato consent upon inadequate and out0-dayed information, and for avoiding iuts own strict procedures (8).

Third, we urge you to be mindful, in deciding in which direction to cast the UK vote on this matter, of the ongoing antipathy towards GMO crop cultivation in the UK. Pioneer maize 1507 is not needed, and nobody wants it. It will not fill a new or old market niche for a maize of this type (9). It will not bring any benefits to consumers or farmers. In other words, on any cost / benefit analysis you choose to undertake, there is no reason for the UK to assist in the provision of a consent at the European level.

And finally, we understand from all of our contacts within the UK that the Westminster government is highly unlikely to obtain the backing of the devolved administrations of either Scotland or Wales for a "yes" vote on 13th December. Have you asked those administrations for their views? We do not know what the attitude of the administration in Northern Ireland might be. It seems to us that on many occasions in the past the UK Government has acted against the wishes of the devolved administrations when votes relating to GMO approvals / refusals have been cast in Europe; and we urge you on this occasion to be much more sensitive to the wishes of your partners in the "GMO Concordat" which -- we assume -- was set up in a spirit of cooperation and consensus.

Please will you therefore vote "NO" when this proposal comes before the relevant Committee? We look forward to receiving your confirmation of this action, in the interests of the people of the United kingdom.

Yours sincerely,


Dr Brian John
for GM-Free Cymru


(1) The EC has not assessed the environmental impacts of the herbicide tolerance, as required by European legislation, presenting the maize as only targeting the European Corn Borer. But, in the original application (C/ES/01/01 SNIF, 2001) the applicant clearly stated that herbicide tolerance was one of the aims of the crop. "Corn plants possessing this tolerance can be directly sprayed after emergence with glufosinate-ammonium herbicides, allowing for broad spectrum weed control without herbicide damage to the maize plant. Benefits to the farmer include convenient and effective weed control that ultimately enhances yield potential for the maize." (Dow AgroSciences 2007:2)
See also Parliamentary Question (not yet answered)

(2) EFSA GMO Panel, 2011. "Scientific Opinion updating the evaluation of the
environmental risk assessment and risk management recommendations on insect
resistant genetically modified maize 1507 for cultivation", EFSA Journal 9:2429

(3) Watanabe, T. and T. Iwase, Development and dymorphogenic effects of glufosinate
ammonium on mouse embryos in culture. Teratogenesis carcinogenesis and mutagenesis,
1996, Vol. 16, No. 6, pp. 287-299.


(5) EFSA Journal 2429: 1-73.
"The 32 ng/mg dry weight of Cry1F protein in pollen of maize 1507 is about 350 times
the Cry1Ab protein content expressed in maize MON 810 pollen."

(6) European Commission, 6 November 2013. "GMO: Commission asks Council to agree on
its proposal to grant Member States more subsidiarity on cultivation"

(7) JUDGMENT OF THE GENERAL COURT (Seventh Chamber), 26 September 2013 (*)
(Approximation of laws – Deliberate release into the environment of genetically
modified organisms – Authorisation procedure for placing on the market – Failure by
the Commission to submit a draft decision to the Council – Action for failure to

(8) The EU General Court decision to annull the consent for the GM Amflora Potato: