AGRICULTURE AND ENVIRONMENT BIOTECHNOLOGY COMMISSION
AEBC/02/10
RESPONSES TO CONSULTATION ON DRAFT REVISED WORK PLAN
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:
- the proposed topics;
- other topics they would wish to draw to our attention;
- possible approaches to AEBC work on each new topic;
- their sense of the relative priorities of the new topics.
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 proposed topics;
- other topics which you would wish to draw to our attention;
- possible approaches to our work on each new topic;
- your sense of the relative priorities of the new topics.
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:
- Animals and biotechnology;
- Liability;
- Advice to Government on a debate about the possible commercialisation of GM crops in the UK;
- Consumer choice - including co-existence and gene flow; and
- Working with Government on baseline research on the environmental impact of different agricultural management regimes.
- Privately and publicly funded research agendas on agricultural and environmental biotechnology;
- The comparative environmental impact or ‘environmental footprint’ of GM and non-GM agricultural regimes, which would be considered in the context of the recently-published four strategy documents for the future of agriculture in England, Scotland, Wales and Northern Ireland;
- Competitiveness, which has synergies with issues around co-existence and gene-flow, being considered by our consumer choice developmental group, and could follow after that study;
- Trans-boundary regulation of potential modern biotechnology developments; and
- Impacts on other countries of UK biotechnology decisions.
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:
- the proposed topics;
- other topics which respondents would wish to draw to our attention;
- possible approaches to our study;
- respondents’ sense of the relative priorities of the subjects for our future work.
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:
- possible changes in consumer attitudes and needs;
- present and future diversity of systems; and
- trade-offs made by consumers.
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 organic and ‘conventional’ intensive farming, rather than potential use of all technologies to achieve environmental policy objectives. There is already some work eg for DEFRA, FOSSE and projects at IACR and IGER, but still work to be done on developing a unified strategic vision of sustainable agriculture. It would be useful if the Commission included consideration of existing processes to assess and regulate new and existing technologies within the framework of developing better agricultural sustainability. Are existing processes adequate for delivering comparative information and regulation, or is there need for fundamental change? If so, what constraints act against change? (Dr Keith Duff, statutory nature conservation agencies)
18. A useful study. The AEBC should include novel management regimes which could result in yield increases and herbicide reduction. The AEBC should use statistics from real world farming experience, not rely heavily on research laboratory results. (Dr Goodman, IT Architecture)
19. High priority. The comparison should take into account studies underway, including FSE work and the DEFRA baseline study, and identify possible further studies. A measurable definition of environmental sustainability is needed, agreed across all stakeholders. NFU support an approach considering ‘smart’ plants and the role of non-food crops. (Elizabeth Hogben, NFU)
20. Support a study, though warning strongly against making pronouncements on hypothetical GM scenarios. The organic category is essential as a dimension separate from non-GM management. (Rudolf Kirst, Hemel Hempstead GM Action Group)
21. A very important study. The situation is complex: GMOs should be seen as just one component of complex systems – for example there is no intrinsic reason why GM crop varieties should not be cultivated using organic principles. Sustainable agriculture has more than an environmental dimension, and the study should be widely framed, to include societal and economic factors. Assessments of environmental impact have to be done on an appropriate scale, eg including headlands and hedgerows as well as fields, and including intensive farming in a few areas allowing reduced areas of cultivation, to allow greater flexibility in managing sensitive habitats. (Martin Livermore, Ascham Associates)
22. An important issue, with equal priority to a study of research, which will have implications for future research agendas; integration across the UK agencies involved will be essential. Other topics on the draft AEBC Work Plan, whilst of importance, seem of secondary priority. The National Listing and Recommended Listing systems for new varieties have a potential role to play - they can influence varietal characteristics considered important, including sustainability. They can also provide a convenient focus for comparison of GM and non-GM varieties. (Dr James Reeves, NIAB)
Competitiveness
23. Proposals for future work on competitiveness and regulatory aspects are particularly welcomed by the Secretary of State for Trade and Industry, the Rt Hon Patricia Hewitt MP. The proposals could benefit from higher priority in the proposed list of AEBC studies, as areas of great significance in facilitating commercialisation of the sector.
24. If competitiveness is studied, the AEBC should examine competitiveness of the UK agriculture industry within a variety of scenarios, rather than examining competitiveness of the biotech industry. (Ben Ayliffe, Greenpeace)
25. Low priority. Unless the Commission genuinely wished to resolve the coexistence issue it would be better not to spend time on this topic; the debate about GM crop isolation distances was sterile and distracting. Long term sustainability of the UK rural environment and landscapes depended absolutely on the competitiveness of agriculture and industries that support agriculture. For agriculture to be competitive in a global context, it had to adopt new technologies (including biotechnology). (Professor Ian Crute, IACR)
26. This should be the last of the AEBC’s priorities. There is little evidence that slow adoption of GM crops is adversely affecting UK investment in biotechnology as a whole. Agricultural biotechnology is a very small sector of the much larger industrial and medical biotechnology industry. Statistical data on the relationships between farming and the food chain, and biotechnological research and development may be difficult to disentangle from industrial and medical data. If it proves not possible to use an objective approach, the Commission may have to rely on gathering stakeholder opinions, which is unlikely to bring anything new to the debate. It is difficult to see how this study could be approached, given the entrenched positions of vested interests, and because many institutions and industries are effectively multinational, and competitiveness in farming is often an economic artefact driven by policies that bear little relationship to domestic and world markets. If there were such a study, the economics of farming and the food chain is a main driver of agricultural practice at field level, impacting on biodiversity, and it would be worthwhile considering what measures would be needed in the UK to make sustainable farming more competitive. The UK statutory conservation agencies have specialist staff, who could help the AEBC with such a study. (Dr Keith Duff, statutory nature conservation agencies)
27. On competitiveness and gene-flow, to note that the Scottish Crop Research Institute are undertaking work on gene flow. (James Grant, a farmer visited by the Farm Scale Evaluations sub-group)
28. High priority, but not with the AEBC’s suggested approach. Work on competitiveness could follow from the AEBC’s consumer choice developmental group consideration of co-existence and gene-flow issues, and the AEBC work on liability will also be relevant. Or work on consumer choice could follow from a broader consideration of gene-flow and competitiveness. AEBC should provide leadership in the issue and consult widely within the farming community. (Elizabeth Hogben, NFU)
29. No support for a study on this topic unless thoroughly reworked. (Rudolf Kirst, Hemel Hempstead GM Action Group)
30. Lower priority than research and environmental footprints studies. (Martin Livermore, Ascham Associates)
Trans-boundary regulation
31. An important issue, given the global nature of trade in GMOs, though a report could be short, and the main findings should be quite obvious: in future, legislation will need to be tightened to limit the adverse environmental impacts of GMOs and to prevent the release of unauthorised GMO varieties. (Ben Ayliffe, Greenpeace)
32. Top priority: the greatest issue is lack of regulatory clarity or certainty, which fits squarely into this topic. A prime example is absence of law on GM impurities in seed. It would be impossible to analyse liability without knowing the law. Unless and until there was clarity, Advanta would prefer to see no approvals for GM crops in Europe. (David Buckeridge, Advanta)
33. An important topic where the Commission should be informed and should inform the political process. (Professor Ian Crute, IACR)
34. A very high priority; timely in the light of recent information on gene stacking and adventitious presence of GM material in conventional and GM seed being traded worldwide. Trans-boundary movement of transgenic organisms have potential to undermine national and international regulations on release of GMOs. Fish and insects are obvious candidates. An immediate issue is inadvertent trans-boundary movement of plants, either as seeds (eg GM grasses in cereal seed batches and GM crops in non-GM batches) or as whole or parts of plants (eg GM trees and ornamental plants). Unauthorised releases (especially in plants that are sexually compatible with native plants and common crops) are high priority. Consideration of how imports could be realistically and economically screened is an important strategic issue to address. The AEBC’s suggested approach seemed sound. A scenario analysis might help consider whether current provisions were sufficient, and what else might be needed. (Dr Keith Duff, statutory nature conservation agencies)
35. High to medium priority. It could be useful for the AEBC to look at the Convention on Biological Biodiversity and the Cartagena protocol on Biosafety specifically. Such a study should assess both implementation for any potential problems arising from biotechnology, and how implementation allows or prevents access to the benefits of new technologies. The ability of GM plants, animals, micro-organisms and transgenes derived from them, to cross national boundaries is linked to studies on gene flow and contamination. The effectiveness on national and international regulations should be considered in this context. (Elizabeth Hogben, NFU)
36. Theme generally supported. (Rudolf Kirst, Hemel Hempstead GM Action Group)
37. Lower priority than research and environmental footprints studies. Could be combined with a study of impacts on other countries of UK biotechnology decisions, as a study of the implications of EU regulations and policies being different from those of other regions: a largely trade issue. (Martin Livermore, Ascham Associates)
The impact of UK decisions internationally
38. A very broad subject. A study would need more focus. Any report must examine the wide environmental implications of UK decisions on agricultural biotechnology. The AEBC would probably also consider political and market implications, though this would be a difficult task. (Ben Ayliffe, Greenpeace)
39. An important topic where the Commission should be informed and should inform the political process. (Professor Ian Crute, IACR)
40. Not an AEBC priority: a difficult area for the AEBC to consider without detailed knowledge of regulatory systems and socio-economic conditions overseas. It may be more appropriate for the AEBC to flag up this issue with organisations such as OECD, UNESCO or CGIAR. (Dr Keith Duff, statutory nature conservation agencies)
41. There were tremendous potential advantages in GM technology for all countries and in particular for third world countries. It is important to grow GM crops here, not only for our own good, but to demonstrate confidence in their safety to third world countries. (James Grant, farmer)
42. Medium priority. If the AEBC undertakes such a study, it must work closely with other UK and overseas organisations, and provide recommendations to the Department for International Development (DFID), DEFRA and other departments to build on work already being carried out. For example the Biosafety Information Network and Advisory Service (BINAS) of the UN Industrial Development Organisation monitors global developments in regulatory issues in biotechnology, and the Consultative Group on International Agricultural Research (CGIAR) is an international network, looking at issues like biotechnology, sustainable agriculture and intellectual property. (Elizabeth Hogben, NFU)
43. A contentious topic, where study would be premature, hypothetical and not supported. (Rudolf Kirst, Hemel Hempstead GM Action Group)
44. Lower priority than research and environmental footprints studies. (Martin Livermore, Ascham Associates)
Additional topics for the AEBC to consider
Intellectual property right (IPR) regimes
45. Current IPR regimes are an area the AEBC should consider studying. IPRs and issues around appropriation and patenting of genetic resources are highly contentious. This could also form part of a study into public/private research, and cover the ways IPRs influence the availability of information for the regulation of biotechnology, and IPRs’ impact on the breadth and quality of scientific research. Second in the priority list for AEBC studies. (Ben Ayliffe, Greenpeace)
Study of public values and social/ethical concerns towards agricultural biotechnology
46. This would be a valuable study, given the AEBC’s remit, and could include a range of issues such as the ethical concerns people may have with biotechnology and whether people feel that agriculture in the UK needs biotechnology. Third in the priority list for AEBC studies. (Ben Ayliffe, Greenpeace)
Bioremediation
47. It is regrettable the AEBC decided not to examine bioremediation of polluted land. If the environmental benefit from microbial and plant biotechnology in this area were considered uncontroversial, the AEBC might consider expressing this view. (Professor Ian Crute, IACR)
Impact of GM adventitious presence in GM and non-GM seed lots
48. There is an urgent need to address the potential impacts of adventitious presence, both in Europe and globally. This topic could be addressed as part of a trans-boundary study. Various regulatory bodies have indicated willingness to allow low levels of GM adventitious presence in seed lots. This has not been given sufficient strategic consideration. The statutory conservation agencies are deeply concerned that presence of authorised and unauthorised transgenic seeds in both non-GM and GM seed lots will go undetected because of costs and practicalities of testing. This will lead to presence of multiple transformations in seed batches, which could result in unregulated and undetected gene stacking in volunteer plants. Farmers could have difficulty controlling these plants, perhaps having to use practices inimical to sustaining wildlife on farmland, thus undermining policy objectives of increased biodiversity on farmland. (Dr Keith Duff, statutory nature conservation agencies)
Regulation of organisms containing multiple transgenes
49. Strategic issues arise about the way in which regulatory systems deal with possible consequences, as more transgenic traits are inserted into main crop varieties worldwide, and potentially into other organisms. If a number of traits are inserted individually into different varieties of a crop, subsequent hybridisation may produce plants with different risks from the parents. The Commission could consider how regulatory authorities should approach this issue strategically. Regulation of ‘cumulative’ transgenic traits may become a key future issue, and regulatory authorities are not consistent in approaches. There is insufficient information available to enable sound judgements to be made about potential risks to the environment from GMOs with multiple transgenic traits. (Dr Keith Duff)
Impact of biotechnology on consumer image of agriculture
50. A subject to emerge as key in public debate on biotechnology, especially in Scotland and Wales. Local producers may see the introduction of GM crops as jeopardising the consumer image of their production environment, which is perceived by consumers as a pristine environment – a similar issue to organic production relative to biotechnology. The consumer choice group might already be addressing the issue. The statutory nature conservation agencies would like it to have higher priority. (Dr Keith Duff)
Other biotechnologies
51. The AEBC could have more focus on biotechnologies that do not necessarily involve genetic modification, in particular how the advances in genomics, proteomics and bioinformatics might impact on agriculture and the environment. (Elizabeth Hogben, NFU)
Non-food crops
52. The AEBC could consider the role of biotechnology in developing alternative crop uses, particularly non-food uses of benefit to the environment, such as starch polymers for biodegradable packaging. The AEBC could contribute towards implementation of the Policy Commission on the Future of Food and Farming’s recommendations for a non-food crop strategy. (Elizabeth Hogben)
Scrutiny of the regulatory processes in the UK and worldwide.
53. Regulatory aspects are an important part of the AEBC’s terms of reference. The Commission should scrutinise current regulatory processes from national Listing, to ACRE’s safety certificates, from EU regulations to US Regulations. A factual area, essential in understanding the background of transgenic biotechnology. (Rudolf Kirst, Hemel Hempstead GM Action Group)
Transgenic biotechnology in the context of politics, global business interests and mainstream research
54. An essential, though difficult, evidence based topic, to provide historic context for the AEBC’s work. (Rudolf Kirst)
Transgenic biotechnology examining the research-based safety aspect in relation to the cautionary principle
55. Essential, as strategic advice from the AEBC depends for its validity on sound evidence and science-based projections, balanced by the cautionary principle. (Rudolf Kirst)
Critical scrutiny of the validity of the claims made by transgenic biotechnology
56. A critical scrutiny needs to be tackled, based on evidence worldwide and based on the nature of the biological processes. (Rudolf Kirst)
Adjusting regulatory processes to new technologies
57. The traditional regulations are inadequate to deal with the novel dimensions of transgenic biotechnology, an entirely new technique. (Rudolf Kirst)
Transgenic biotechnology and the potential and actual harm inherent on many levels
58. The AEBC has discussed the term ‘harm’ at an earlier stage, but having a sub-group on this now seems to have been dropped. (Rudolf Kirst)
Need for GM free zones in the world and in Britain to ensure GM uncontaminated food supply
59. Customers need the choice to eat GM uncontaminated food, and large areas free from GM crops are required. The UK has to play a part in this for economic reasons. (Rudolf Kirst)
General comments
60. It is important to allow the general public to be involved in framing questions around the general areas the AEBC will explore. (Ben Ayliffe, Greenpeace)
61. The Royal Society is concerned about the breadth of scope of proposed topics and ongoing studies; more detailed terms of reference are needed. Terms of reference of the ongoing liability study are unclear, and since liability is being considered in Europe during development of the new Directive on Environmental Liability, it is important not to duplicate work already being carried out in this area. The Royal Society welcomes the recommendation in Crops on Trial and the subsequent AEBC advice to Government for a public debate on commercialisation of GM crops. The debates about values and beliefs should be set against a background of scientific facts and uncertainties. The Royal Society looks forward to publication of the AEBC report on animals and biotechnology, and hopes that in the longer term the AEBC will consider a public debate on GM animals along similar lines to that proposed on GM crops, again informed by sound science. (Dr Josephine Craig, the Royal Society)
62. NERC have sent information on their strategic and scientific priorities in ‘Science for a sustainable future, 2002-2007’, April 2002, which was based on extensive consultation. One of the key priority areas, ‘Sustainable Economies’ will include the impact of new farming systems, such as GM foods, on environmental sustainability. NERC is funding a programme of research on ‘Biocontrol’, targeted at biotechnology development, the development of novel pest and disease control strategies and the environmental impacts of GMOs and potentially invasive species. NERC has funded two major thematic programmes on ‘Ecological Dynamics and Genes’, developing new molecular and genetic techniques to address ecological problems, and ‘Environmental Genomics’ to use genomic knowledge and technology for a better understanding of ecosystem structure and function. These complement the basic and strategic research into GM crop biotechnology supported by the BBSRC. NERC research centres are involved in Farm Scale Evaluation studies of GM maize and sugar beet. (Caroline Fenwick, Natural Environment Research Council)
63. Not enough is known; GM crops should not be grown. (Ian Harris)
64. During the consumer choice study, the AEBC will need to maintain close liaison with the Food Standards Agency. (Sue Hattersley, Food Standards Agency)
65. The AEBC has made good progress with the complex issues in its first Work Plan, and in particular Crops on Trial is an important contribution to the debate. The NFU looks forward to the report on liability. The NFU supports the AEBC approach to openness; it encourages the AEBC to seek new or more effective means of providing high quality factual information on issues in its remit and communicating to the nation as a whole; it urges the AEBC to publish responses to consultation and the final opinion of the Commission as a result of the consultation. The AEBC has a key role in leadership and encouraging biotechnology development that impacts positively on agriculture and the environment, and a responsibility to identify uncertainties and concerns, and recommend appropriate Government action (including suggestions for future research). (Elizabeth Hogben, NFU)
66. The Chardon LL public hearing is a goldmine for references, papers and presentations. The AEBC should clarify whether its consideration focuses on biotechnology generally or on transgenesis, should not tend to move away from substantive issues into hypothetical ones, and should not stray into the area of commercial bias. Opportunities for the public to voice their points of view have been heavily curtailed in recent AEBC meetings, which is a pity as the diversity of ideas raised was of value. Evidence taking has been very useful when panel membership has been balanced, but membership has often been unevenly matched. The AEBC appears rather close to DEFRA – it is regrettable that the AEBC now reports to DEFRA Ministers, whereas it originally reported to a Minister at the Cabinet Office. (Rudolf Kirst, Hemel Hempstead GM Action Group)
67. The areas and priorities proposed by the AEBC seem reasonable and should be pursued urgently. As well as advising Government, it is important that AEBC findings are made widely available in the media to promote informed debate on the new biotechnologies. The poultry industry is aware of potential benefits from biotechnology. These include reduction in herbicide and pesticide use, improving the nutritional value of raw materials to improve their digestibility and nutritional value for poultry, and improved resistance of chicken to disease. There is a lack of credible scientific debate putting forward the balance in the argument to allow informed choice by consumers, about the safety of the technology to consumers, the benefits or otherwise to the environment of introducing GM products, and the relative costs of food produced with and without biotechnology. There is a very real risk that the UK and European agricultural and food industries become uncompetitive if GM is adopted by competitors but not accepted in Europe due to lack of informed debate. Producing non GM feed will become difficult and expensive if Brazil legalises the planting of GM soya, as seems imminent. The industry needs to know the way forward because of the long lead times. (John Sloss, Northern Ireland Poultry Federation.)
ANNEX C
List of respondents
Ben Ayliffe for Greenpeace
David Buckeridge, Director, Advanta BV
Josephine Craig for the Royal Society
Professor Ian Crute, Director, Institute of Arable Crops Research
Dr Carey Cunningham, FRS Marine Laboratory
Duncan Dallas, Café Scientifique
Dr Keith Duff, Chief Scientist, English Nature, for the British statutory nature conservation agencies
Caroline Fenwick for Terrestrial and Freshwater Sciences team, Natural Environment Research Council (NERC)
Mike German OBE AM, Deputy First Minister and Minister for Rural Development and Wales Abroad, Welsh Assembly Government
Dr David Goodman, IT Architecture
James Grant, Roskill
Ian Harris
Sue Hattersley for the Food Standards Agency
Rt Hon Patricia Hewitt MP, Secretary of State for Trade and Industry
Elizabeth Hogben for National Farmers Union
Rudolf Kirst, Hemel Hempstead GM Action Group
Martin Livermore, Ascham Associates
Dr James Reeves for NIAB
John Sloss, Moy Park Ltd, for Northern Ireland Poultry Federation
Harold Stephens, Planning Inspector
Dr Telford, Director of Public Health
