Professor Christopher Pollock CBE

Chair, ACRE

c/o ACRE secretariat

3rd Floor

Ashdown House

123 Victoria Street

London SW1E 6DE

 

September 2004

 

 

 

 

 

 

 

 

OPEN LETTER TO GOVERNMENT AND ACRE ON THE WIDER ISSUES RAISED BY THE FARM SCALE EVALUATIONS

 

 

The Agriculture and Environment Biotechnology Commission’s (AEBC’s) first report[1] evaluated the role of the Farm Scale Evaluations (FSEs) in the regulatory process. In its advice to Government on the FSE results[2], the Advisory Committee on Releases to the Environment (ACRE) noted that “the FSEs also have implications for agriculture in general, and may feed into a wider discussion concerning environmental impacts of agricultural practices”. ACRE has established a subgroup to examine these wider implications.

 

This open letter sets out some questions raised by the AEBC in its recent deliberations that we feel might be useful for ACRE, as part of the work of their subgroup, and for Government, in their consideration of the wider agricultural issues raised by the FSEs.

 

EC Directive 2001/18 obliges Member States to avoid “adverse effects” arising from the release of GM organisms into the environment. As part of the risk assessment for new GMO events in crops, the Directive requires the identification and evaluation of possible adverse effects of “the specific cultivation, management and harvesting techniques” associated with the particular GM crop. The assessment is made by comparison with an equivalent non-GM crop variety, used in a corresponding agricultural context, on a case-by-case basis for each GM variety.

 

Using this comparative approach, the results of the FSEs highlighted issues that have implications for both GM and non-GM crops and the management practices associated with them.  For example:

 

• It is the individual crop/trait combination that is being judged, not the whole system, and yet it is hard to isolate the environmental impact of a crop from the system in which it is grown. For example, it may be that we need to consider environmental impact throughout the whole rotation.

 

• The analysis of environmental impacts in the FSEs was limited by the parameters measured and what could be directly inferred from them. ACRE acknowledged this in their advice.

 

• There seems to be a tacit assumption in the Directive and the guidance that the status quo represented by the non-modified crop is the baseline against which impact should be evaluated. While data is readily available to allow evaluation on this basis, it is a somewhat arbitrary baseline to use, and also one that may change with time (indeed it is known that the biodiversity associated with many conventional crops is declining year-on-year). There is nothing to guarantee that this is the most appropriate baseline to meet policy goals for farming systems that are less damaging to farmland wildlife; for example, the FSEs showed that the differences between crops were greater than the differences between a GM and non-GM version of the same crop.

 

• Environmental impact does not necessarily translate into adverse effects, because of the possibility of trading risks against benefits. For example, higher yields due to efficient weed control within the crop could be traded against wider, managed non-crop margins. How such trade-offs could be made is a difficult question, but one that needs to be explored, including whether possible approaches are practicable and whether compliance can be assured.

 

• Different crop management strategies could give different results for the same crop. Recent research suggests that the flexibility that GM herbicide tolerant systems may offer could be exploited to refine management strategies that favour biodiversity without sacrificing yield[3].

 

• There is at present no requirement to assess non-GM crops for their ‘adverse effects’ or environmental impacts.

 

These issues suggest a number of questions that the ACRE subgroup might want to consider:

 

• Does the statistical significance demonstrated in the FSEs translate into ecological significance and ultimately ‘harm’ in a robust way?  How far is the latter a value judgement as much as a scientific, consideration?  What is the basis of any value judgement?

 

• Could this work be done in ways other than through FSE-type experiments? With hindsight, did the FSEs ask the right questions? Would the results have been replicated without the constraints of the “Part B” license[4]? If the primary focus were on potential indirect effects, then alternative experimental designs might have asked, “Which management system would maximize yield and meet certain biodiversity targets (while remaining easy to administer for farmers)?”

 

• How widely drawn should be the considerations for assessing ‘harm’?  Is a wider canvas than that used by ACRE to judge the first round of the commercialisation applications possible under the terms of the Directive? For instance:
  • How far is it possible to rethink the standards for environmental risk assessment using whole farm systems?
  • Could other, non-conventional farming systems, such as organic or precision agriculture, be a more appropriate yardstick for environmental harm?
  • As well as effects on biodiversity, should indirect environmental effects such as fuel and agrochemical savings from new crop systems be brought into the frame, and benefits weighed against risks? 

o       Are other possible comparative assessment systems available and what are their relative merits? Who would undertake them, and who should determine the criteria to use?

 

They also raise questions relevant to the Government’s considerations of the wider environmental impacts of agriculture:

 

·        What systems can be used to consider the varying environmental impacts of different conventional crops and different management systems for the same crop?

 

·        What objectives should be set for biodiversity, and the environmental impact of farming overall? How should other, socio-economic dimensions of sustainability be considered alongside these objectives? Is it practical to set targets for biodiversity, considering its complexity, or should future improvements in agricultural biodiversity be driven principally by the pragmatic introduction of practices known to be more favourable to wildlife?

 

·        What stakeholder input would be needed to set these objectives in a robust way?  Does the public debate on GM offer any lessons, positive or negative, for how this might be done?

 

·        What new structures within Government will be needed to help meet these objectives?

 

·        What further research might be needed to inform decisions? Should all crops and/or crop systems, past and future, be subject to assessment along the lines of the FSEs?

 

·        Although this would require revision of the EU regulations, should other ways of regulating GM and new non-GM crops, which would avoid or minimise some of the anomalies of the current system, at least be considered (e.g. the Canadian model[5])?

 

This letter also goes to the Ministers to whom we report: Margaret Beckett, Secretary of State for Environment, Food and Rural Affairs; Patricia Hewitt, Secretary of State for Trade and Industry; Allan Wilson (Scottish Executive); Carwyn Jones (Welsh Assembly Government) and Angela Smith (Northern Ireland Office).

 

We hope that these points prove constructive and useful both for ACRE and for Government in their future consideration of the wider implications of the FSEs, and would be very happy to contribute further to ACRE’s work in this area.

 

Yours sincerely

 

 

 

 

 

Professor Malcolm Grant

AEBC Chairman