AEBC/02/10

RESPONSES TO CONSULTATION ON DRAFT REVISED WORK PLAN

Background

1. The Commission published its draft revised Work Plan on 16 April this year, identifying that the time had come for the AEBC to revise its programme of work, in the light of progress on the priorities set out in the first Work Plan, published in January 2001. The draft Work Plan set out a list of possible new topics, and priorities for tackling them. A copy of the draft Work Plan and of the covering letter are at Annex A.

2. The draft Work Plan has been on the AEBC website since April. The secretariat sent it to AEBC stakeholders – individuals and groups - alongside the Horizon Scanning Study of relevant developments in biotechnology, since these informed the Work Plan proposals.

3. The covering letter particularly invited peoples’ views on: Responses to the consultation

4. The responses to the consultation, together with discussion at the July Commission meeting, will inform the final version of the revised Work Plan for the Commission to send to Ministers for approval.

5. This paper draws out the main themes emerging from responses, with details at Annex B, and a list of respondents at Annex C. 21 organisations and individuals have commented. Anyone who would like to see a copy of the responses should contact the AEBC secretariat. Contact details are: Bay 479, 1 Victoria Street, London SW1H 0ET. Telephone 020 7215 6508. Fax 020 7215 0313. e-mail aebc.contact@dti.gsi.gov.uk

Suggested revisions to the Work Plan

6. Comments from stakeholders inevitably suggest a range of priorities, but on balance a number of respondents emphasise the importance of a study of environmental footprints, and of trans-boundary regulation, with a study of research agendas being given on balance a slightly lower priority than these two. The Secretary of State for Trade and Industry encourages AEBC to give a study on competitiveness a high priority. Members will also want to consider the suggestions for additional studies, perhaps for later studies.

7. After discussion with the Chair and Deputy Chair, the secretariat proposes, as a basis for discussion, a revised priority order for studies. The top priority for future AEBC work would be an environmental footprints study, the second priority a study of trans-boundary regulation, and the next priority a study of publicly and privately funded research.

8. Since the AEBC launched the consultation on the revised Work Plan, the Government has announced that it will commission work on the economics of GMs, possibly involving the Performance and Innovation Unit. This would seem likely to cover among other things issues of competitiveness of the agricultural biotechnology industry and of farming in the UK. This suggests that the AEBC should not launch a separate study of competitiveness at this stage but should await the outcome of that work and revisit it as an AEBC topic of work at a later stage.

Timetable; Possible membership of future groups

9. After publication of the animals and biotechnology study in early autumn, the major AEBC work likely to be underway will be on liability and, subject to Government decisions, on the public debate. The consumer choice work is well in hand – with the aim of reporting around spring 2003. The ad hoc group reviewing the DEFRA research will complete its work around the end of 2002. Given the demands of existing and envisaged work, the plan would be to start developmental work on the two new priority areas of work - environmental footprints and transboundary regulation - early in 2003.

10. All AEBC Members are currently actively involved in one or more of the working groups on liability, animals and biotechnology, public attitudes, consumer choice and DEFRA research. Members who have been involved in the earlier horizon scanning and Crops on Trial sub-groups, and who have not subsequently been heavily involved in other group work may want to consider expressing an interest in joining a developmental group for the environmental footprints study or the transboundary regulation study.

Horizon scanning

11. Members will want to know that the secretariat is keeping a note of any correspondence relevant to further AEBC work on horizon scanning, in parallel with inputs specifically on the future Work Plan.

AEBC Secretariat
July 2002

ANNEX A

APRIL 2002 DRAFT REVISED WORK PLAN AND COVERING LETTER

16 April 2002

Dear colleague,

AEBC REVISED WORK PLAN: PUBLIC CONSULTATION

I have pleasure in enclosing the Agriculture and Environment Biotechnology Commission’s (AEBC) draft revised Work Plan. We would welcome your comments on our proposals for future work. I also enclose a copy of the AEBC Horizon Scanning Study of relevant developments in biotechnology which has informed the proposals in the Work Plan.

As you probably know, the AEBC was set up in June 2000 with a remit to provide the UK Government and devolved administrations with independent, strategic advice on developments in biotechnology and their implications for agriculture and the environment. It looks at the broad picture, taking ethical and social issues into account, as well as the science. The AEBC works alongside the Human Genetics Commission (HGC), which advises on how new developments in human genetics impact on people and health care, and the Food Standards Agency (FSA), which is the body responsible for food safety, including GM food. AEBC is committed to working openly and transparently.

The Commission has made good progress on the priorities set out in its first Work Plan, published in January 2001. We published our first report, Crops on Trial, about the Government’s Farm Scale Evaluations of genetically modified crops, in September 2001. As part of its response the Government has asked the Commission to provide further advice by the end of April 2002 on how and when a public debate on the issue of possible commercialisation of GM crops might be initiated. We are working to this timetable. We plan to publish our second report, on animals and biotechnology, this summer.

The time has come to revise our programme of work. The attached Work Plan sets out a list of possible new topics and priorities for tackling them. We would welcome your views on: The Horizon Scanning Study sets out the wide range of work underway in biotechnology research, particularly genetic modification, and highlights developments of possible agricultural and environmental significance. We undertook the study primarily to help develop our new Work Plan. AEBC will review the study periodically and is keen to receive, alongside the responses to the consultation, any information on possible future biotechnology developments of which we should be aware.

We plan to consider comments at our July 2002 meeting which will be held in public in London on 17-18 July, and to finalise the Work Plan proposals before submitting them to Ministers. It would be very helpful therefore if comments could reach the Secretariat by Tuesday 9 July 2002. Details of where to send comments are included in the Work Plan. The Work Plan and Horizon Scanning Study are also available on our website, www.aebc.gov.uk. If you are aware of others who would like to be involved in this consultation, please let us or them know. We look forward to hearing from you.

Yours sincerely,

Professor Malcolm Grant
AEBC Chair

AGRICULTURE AND ENVIRONMENT BIOTECHNOLOGY COMMISSION

DRAFT OF A NEW AEBC WORK PLAN

1. When the Agriculture and Environment Biotechnology Commission (AEBC) was established in June 2000, one of our first tasks was to draw up a Work Plan. We consulted widely on our proposed priorities and approaches, and then submitted the revised plan in January 2001 to Ministers in the UK Government and the devolved administrations. The Work Plan was welcomed and endorsed by Ministers. The AEBC’s terms of reference and membership at Annexes B and C.

2. The Work Plan proposed three primary areas of study: a case-study of decision-making on the Farm-Scale Evaluations of GM crops; animals and biotechnology; and horizon scanning. It also proposed the commencement of initial work on consumer choice and public attitudes; bioremediation, and liability.

3. The Commission has made good progress in taking forward that work. Annex A summarises progress so far. The first major stream of work culminated in the publication of ‘Crops on Trial’ in September 2001, the Commission’s case study of decision-making in the Farm-Scale Evaluations (FSEs). As part of its response, Government has asked for our advice on how and when to promote an effective debate on possible commercialisation in the United Kingdom of the GM crops in the FSEs, and how to make best use of the results of the debate, which has led to a new stream of work on a tight timetable. This new request has been incorporated in our programme of work.

4. We also plan to publish a report on animals and biotechnology in summer 2002 and on liability around the end of 2002. An horizon scanning review has also now been completed. The study of consumer choice will move from developmental to mainstream status upon publication of our animals and biotechnology report.

5. We have pursued methods of open working. Commission meetings are open to the public, and minutes of those meetings, together with minutes of sub-group meetings and related papers, including working drafts of reports, are accessible from our web page.

6. We are now considering plans for our next tranche of work, and this paper proposes a revised and updated Work Plan to cover the next phase of the Commission’s activities.

Next steps towards a new Work Plan

7. Our remit is to provide Government with independent strategic advice on developments in biotechnology which impact on agriculture and the environment. We have freedom to determine our own Work Plan, subject to wide consultation, and subject also to responding to any specific request to us from Government for advice on particular issues. An example of this is the request for advice on a public debate about possible commercialisation of GM crops.

8. The primary purpose of the horizon scanning exercise to identify relevant developments in modern biotechnology was to assist in identifying priorities for future AEBC work. A number of issues emerged from the exercise and discussions around it as potential areas for further study. Several have synergies with work we already have in hand.

9. Our resources are limited, and this is a real constraint on our ambitions. We are therefore seeking views not only on proposed studies, but also on the priority which our respondents attach to them.

10. Our initial proposals are as follows:

(1) Privately funded and publicly funded research

11. The balance between publicly and privately funded research into agricultural and environmental biotechnology in terms of delivering 'public goods' is a recurrent theme both in AEBC studies and elsewhere. 'Crops on Trial records some of our concerns on this point, as does our draft report on animals and biotechnology report. Issues around the ownership and control of the technology, in particular the consequences of a shift from public to private control over research agendas and intellectual property, were also themes which emerged from the horizon scanning scenarios consultation.

12. One of the main recommendations from an OECD Conference ‘New Biotechnology Food and Crops’ chaired by Lord Selborne in Bangkok in July 2001 was "the need for high quality, accessible, relevant science throughout the world", noting that “several speakers drew attention to the decline in publicly funded research, and the increasing dependence that society has on research data that might not be considered impartial. More publicly funded research would provide greater confidence and might be easier to channel into regions for which no financial return on the research investment can be expected".

13. We propose that we should undertake a study of this issue in so far as it affects agriculture and the environment. It might include a review of the research agendas of the major private interests and those with public funding to develop a better understanding of where priorities lie. The study might consider in what ways the identifiable shift from publicly funded research to privately funded research in agricultural and environmental biotechnology affects what is researched, including the social and ethical implications. We might do this through a study and a Commission-run public debate.

(2) ‘Environmental footprints’

14. We are interested to consider comparative impacts on the environment of different GM and non-GM crop management regimes: the ‘environmental footprint’ of different regimes. Several respondents to the horizon scanning scenarios consultation commented that both GM and non-GM techniques could be directed towards the goals of sustainable agricultural production, provided those goals were clearly articulated. They suggested that a system for assessing the relative sustainability of all new crop varieties and the systems within which they are grown was needed, and not only for GM crops. This seems to us to be a useful subject for AEBC to consider. It would take account of the baseline research commissioned by DEFRA on environmental impacts of crop and livestock production systems.

15. An environmental footprint study could include an examination of the implications of management of pests and diseases which affect crops and livestock in GM and non-GM systems, including the impact of herbicide tolerance on crop rotation patterns. It might also provide a framework for assessing the very different benefits and risks around herbicide tolerance, insect, fungal, bacterial and stress resistance and look at the emerging issues around developments such as ‘smart’ plants. A further related area is that of diffuse long-term impacts on the environment of GM and non-GM agricultural management systems.

16. As part of this study, AEBC could also consider the way in which the several recently published reports on the future of agriculture in the different parts of the United Kingdom might inform decisions on the role of new biotechnologies within agriculture. The dimensions of greatest relevance would be projections of or aspirations for long-term patterns of land use; the role of alternative, particularly non-food, crops; how far the countries concerned are aiming to be self-sufficient in food production; and priorities for environmental protection. The four reports are the Policy Commission on the Future of Food and Farming report, "Farming and Food - A Sustainable Future"(England) www.cabinet-office.gov.uk/farming, "A Forward Strategy for Scottish Agriculture", www.scotland.gov.uk), "Vision for the future of the agri-food industry" in Northern Ireland www.dardni.gov.uk "Farming for the Future" (Wales) www.wales.gov.uk. These reports would be a useful starting point for the consideration of biotechnology in the environmental footprints study.

(3) Competitiveness

17. Competitiveness of the biotechnology and farming industries in the United Kingdom emerged as a theme in the horizon scanning group’s consultation in summer 2001 about possible scenarios for the future of uptake of genetic modification in agriculture . This theme links with issues for the consumer choice study (see Annex A) and we propose to start developmental work on it after a report on consumer choice is completed.

18. The principal industries in the scope of the study would be farming and the rest of the food chain; agricultural and environmental biotechnology companies; and associated research and development institutions. We would evaluate the impact on their competitiveness of decisions made about the development and commercialisation of agricultural and environmental biotechnology in the UK, taking into account the positions of the European Union and the World Trade Organisation.

(4) Trans-boundary regulation

19. The Commission is interested to examine the potential for trans-boundary effects from modern biotechnology developments, looking initially at how well regulations as they stand at present can be implemented. Other countries may release and commercialise GM plants and animals that might not be given consent under European regulations, but nonetheless have the ability to cross national boundaries. Fish and insects are the most obvious examples. International regulations will be needed to deal with any potential problems. The AEBC animals and biotechnology study has flagged up this issue, which is likely to remain significant. In advance of launching work on this issue, AEBC will keep a close watch on developments.

(5) The impact of UK decisions internationally

20. Finally, the Commission proposes to consider the impact of United Kingdom and European Union decisions about the development and implementation of agricultural and environmental biotechnology elsewhere in the world. Relevant aspects include capacity building for risk assessment and risk management; protocols for the on-the-ground management of biotechnology developments; how relevant specific developments in the UK and Europe are to other countries; who benefits from the developments; and how the developments are regulated. This could be a subject either for AEBC or for organisations with a more explicit international focus.

Initial proposals for our Work Plan

21. Bringing these strands together, our proposals are to complete the work we have underway (see Annex A) on: 22. Our initial proposals for five areas of possible future work, which we suggest might be tackled in the order shown, are: 23. The Commission aims to focus on no more than two main areas of work at any one time, though to work concurrently on the initial development of the other subject areas to prepare for their becoming main workstreams. When the work on animals and biotechnology is completed this year, consumer choice will replace it as one of the two main workstreams; and when we issue our report on liability, the first of the new possible topics will replace it as a major area of work. This means that the first of the future studies is unlikely to become a major area before early 2003, and the second by the middle of 2003, although we may be able to start initial developmental work on one or more of the new topics before those times.

24. This list of potential future work topics encompasses a substantial set of issues, and is one that may well be added to during consultation, so we shall have to prioritise between studies. We would welcome respondents’ views on:

  1. the proposed topics;
  2. other topics which respondents would wish to draw to our attention;
  3. possible approaches to our study;
  4. respondents’ sense of the relative priorities of the subjects for our future work.
Contact us

25. We would welcome your views on this draft revised Work Plan. For us to be able to consider comments at our July 2002 meeting, which will be held in public in London on 17-18 July, and then to finalise the Work Plan proposals and submit them to Ministers, we would be grateful for comments to reach us by 9 July.

26. You can send comments by e-mail, fax, or post. Please send them to:

e-mail: aebc.contact@dti.gsi.gov.uk
post: AEBC Secretariat, Bay 479, 1 Victoria Street, London,
SW1H 0ET.
Fax: 020 7215 0313

 AEBC
April 2002

ANNEX A

Progress on work underway

Areas of work identified in our original Work Plan

1. The sub-group on strategic decision-making in biotechnology completed its work in 2001, which culminated in the Commission’s report Crops on Trial.

2. The horizon scanning study of emerging biotechnology developments with implications for agriculture and the environment has been completed. It was designed to help the full Commission to keep up to date with possible developments influencing our subject area. The study has been a basis for assessing our priorities for future work to include in the Work Plan, and is being distributed alongside this draft Work Plan. We would expect to periodically update the study in the light of future developments.

3. The study of animals and biotechnology is well advanced, and the Commission expects to report to Government this summer.

4. The liability developmental group became a full sub-group in September 2001 and AEBC aims to report to Government on this main area of work around the end of 2002. The study will be relevant to Government decision-making on possible commercialisation of any genetically modified crops, and for European Commission proposals for a Directive on environmental liability, which were published in January 2002.

5. Bioremediation has been included in the horizon scanning study, and the Commission has decided not take it forward as a separate substantive area in the proposed workplan.

6. Consumer choice and public attitudes work has been separated into two distinct work-streams.

7. The public attitudes developmental group is taking forward the request from Government to provide further advice by the end of April 2002 on how and when a public debate about possible commercialisation of GM crops might be initiated. This subject will be discussed at an additional AEBC meeting on 18 April 2002 in London, which will be open to the public.

8. The consumer choice developmental group will take as its starting point these questions:

How important to people is the diversity of agricultural production systems in the UK and their co-existence with GM technology? How would co-existence be practicable? In considering these questions, the working group will take into account: Consumer choice will become one of the two main workstreams (along with liability) following completion of the animals and biotechnology report.

Other work

9. Crops on Trial’ recommended an independent baseline review of information that will need to be considered in addition to the results from the FSEs. The Department for Environment, Food and Rural Affairs (DEFRA) is now commissioning literature reviews of research on the environmental impact of GM and non-GM agricultural management regimes, with input from the AEBC.

[ANNEX B gives AEBC Terms of reference]

[ANNEX C lists AEBC members]

ANNEX B: SUMMARY OF RESPONSES TO THE AEBC’S DRAFT WORK PLAN CONSULTATION

(In alphabetical order of respondents’ names, with Ministerial responses at the beginning of relevant sections.)

Priority themes identified by AEBC - listed in the provisional order in the April draft Work Plan.

Privately funded and publicly funded research

1. Strongly supported, top priority. The AEBC should also consider what does not get researched as a result of the shift from public to private control over research agendas. It would be worthwhile considering the issue of ‘independent science’: what this means given the increasing corporate control over research, and what should be done if the public cannot get it. The AEBC should consider evidence that a wider network of corporate interests exists in research funding, from recent reporting about genetic contamination of maize in Mexico. (Ben Ayliffe, Greenpeace) 2. Second priority, after transboundary regulation. There are real opportunities for fruitful collaboration between public and private sector, and areas of biotechnology that could not be the subject of private research for pure commercial reasons, but very important to society at large. (David Buckeridge, Director of Advanta seeds) 3. There are a number of misconceptions about the objectives of and relationship between different types of research. It would be worthwhile the AEBC considering a comparative study with another area with a clear interface between science and technology in the public and private sector (eg electronics, pharmaceuticals, agrochemicals). (Professor Ian Crute, Director of the Institute of Arable Crops Research (IACR))

4. A series of relevant meetings are planned in autumn 2002 on the commercialisation of scientific research. (Information given by Duncan Dallas, Café Scientifique)

5. Decline in publicly funded research in agricultural and environmental technologies in general is a key issue in developing more sustainable agriculture. It is unlikely that private funding would aim at public goods such as more non–crop biodiversity and less water pollution. This could change if Government made more sustainable agriculture more profitable by incentives and regulation. A major review of research agendas would be welcome. Identification of links between funding sources and research priorities would be useful in understanding drivers of research and development in agricultural and environmental technologies, including biotechnology. The AEBC should also look at how changes in agricultural policy could attract more private investment into research on sustainable agricultural methods, and it could open a dialogue with some multinational agricultural companies. This topic is considered slightly lower priority than an environmental footprints study. (Dr Keith Duff, The British statutory conservation agencies)

6. Low priority. The Curry Commission has proposed a Priorities Board to set the agenda for public research on farming and food matters, and the NFU supports openness about the agenda for publicly funded research. Biotechnology is one part of a wider debate on public funding of research on food, agricultural, environmental and rural issues. Market forces are the main drivers for commercial research; both these and biotechnology companies are international in scale. NFU strongly questions the value of attempting to analyse research agendas and priorities of the major private interests, without a clear strategy for how to use such information, if indeed it can be obtained. The information will be difficult to obtain as information on current research projects will be commercially sensitive and confidential. (Elizabeth Hogben, NFU)

7. Agree this study should be first priority. (Rudolf Kirst, Hemel Hempstead GM Action Group)

8. An important topic, deserving high priority. Work on this should include the possibility of public funding of ring-fenced projects in industrial research centres. (Martin Livermore, Ascham Associates)

9. An important issue in relation to control and public confidence, with impacts on commercial competitivity. The approach could be strengthened by a a study of the degree to which UK public research agendas are integrated across the funding bodies, and what mechanisms are used to monitor and mange this in the public interest. It should include UK public research spend to maximise benefit from the EU research Framework Programmes, and the extent to which integrated UK public research strategy could influence EU research strategy, aimed at maximising benefit and value addition. (Dr James Reeves, NIAB)

10. There is great importance in having research data which is impartial, from publicly funded research, for making decisions in all walks of life. Where there is even a suspicion that evidence was not produced impartially, it is likely to be devalued in the public mind; recommendations may be tainted if associated with suspect evidence. (Harold Stephens, a Planning Inspector).

The comparative environmental impact or ‘environmental footprint’ of GM and non-GM agricultural regimes

11. The top priority, which could make a significant contribution to the debate on coexistence and help provide a firmer basis for making judgements about the environmental impact of different agricultural regimes. (Mike German OBE AM, Deputy First Minister, Welsh Assembly Government)

12. Low priority. The key to environmental footprints is, and will remain, the Common Agricultural Policy, and an AEBC report will not alter that. A regulatory mire, which is of little benefit for a study. (Ben Ayliffe, Greenpeace)

13. Third priority, after transboundary regulation and research. This might show some surprises, with GM crops in the right conditions proving more environmentally friendly than other systems. A number of aspects were identified for the study to include. (David Buckeridge, Advanta Seeds)

14. High priority: welcome and should take priority in the AEBC work programme. The Royal Society 1998 report GM crops for food use recommended an over-arching body such as the AEBC and said this body should consider the effects of GM crops in comparison with effects of current agricultural practices in general on ecosystems and the environment. Lack of comparison has bedevilled debate in this area, and the study will be important for informing the public debate. (Dr Josephine Craig, the Royal Society)

15. The proposal is laudable and important, but a monumental task: data is lacking or inadequate. Such a study should have a tight focus, with two, or at the most three, key environmental factors: fossil fuel use (and associated carbon cycling); nitrogen use efficiency; water quality and water use efficiency. (Professor Ian Crute, IACR)

16. A study should include aquacultural regimes, as GM fish may be approved in the USA. There should be a review of DNA vaccines and their potential to cause genetic modification in mammals, birds and fish. (Dr Cunningham, FRS Marine Laboratory)

17. Top priority, with slightly higher priority than a study of research. The approach the AEBC suggested should enable the Commission to place new technologies within the current debate on the sustainability of agricultural practices. For too long this has centred on competition between orga