Sub Groups

Note these minutes represent the views of the sub-group and those who made representations not the full AEBC

Introduction

1. Six members of the group: Dave Carmichael, Phil Dale, Rosie Hails, Jeff Maxwell, Sue Mayer and Justine Thornton (convenor) met in Inverness at the invitation of the Highland Council, to hear views on the Farm Scale-Evaluations from local organisations. They were accompanied by Judith Harris (AEBC secretariat) and Kate Cutler (AEBC press office).

2. Over fifty members of the public accepted the group's invitation to observe the session . Those present will be aware that the session was taped. However, owing to technical problems, only a partial transcript is available. We do not propose to publish this partial transcript as that would be unfair to those whose contribution was not recorded.

3. On the afternoon of the same day members of the group visited a local farm on which an FSE was taking place. Three members (Justine Thornton, Phil Dale, Jeff Maxwell) also had discussions with pupils of the Fortrose Academy.

4. SUMMARY OF POINTS MADE TO THE GROUP BY THE HIGHLAND COUNCIL

David Green (Convenor), Dr Michael Foxley (Chair of the Land and Environment Committee), David Alston (Councillor for the Black Isle)

• Highland Council is a unitary authority whose 80 members are mostly independent. It aims to work in an open and democratic way and to keep decision making at the lowest practical level to allow for maximum local input.
• The natural environment of the Highland region must be maintained as a long-term asset. The balance between scientific development, the environment and tourism is a delicate one. Crofting and farming are critical to the local economy.
• There is a spectrum of views within the region as regards the merits of gm crops but a general level of extreme concern about the lack of consultation on FSEs, particularly the one that was taking place locally. This is evidenced by the large numbers attending the first public meeting on the subject [circa 400].
• Democratically elected bodies such as Highland Council have a role to play in the consultation process; information should be given in advance and in plain English; timescales should allow for comment and debate and concerns expressed should be properly considered. Political questions should be answered by politicians not civil servants.
• Highland Council had opted to use the planning process as this allowed for local democratic input into decision making on FSEs. Although their arguments had not been accepted by the courts, the process continues to provide a role model with all the essential elements.
• There is little evidence of local support for herbicide tolerant gm crops or that their use results in better targeting or lower herbicide usage. Plans for monitoring the local trial appeared to be 'grossly inadequate'. It should be halted pending a resolution of concerns about this and other issues.
• More generally industry needed to offer better information on technological developments and to seek a concordat with interested parties rather than imposing their introduction.

5. FURTHER POINTS MADE IN RESPONSE TO QUESTIONS FROM GROUP MEMBERS

• The Council's preferred consultation method would use the planning process (or something akin to it); would allow for much more local consultation; be inclusive not exclusive and would take account of local economic interests.
• There should be a full policy debate before FSE sites were chosen.

6. SUMMARY OF POINTS MADE TO THE GROUP BY SCOTTISH NATURAL HERITAGE (SNH)

Jeff Watson (Director of Strategy and Operation, North Area)

• SNH's role in relation to the FSEs concerned nature conservation.
• The need to assess the effect of the use of herbicide tolerant gm crops on biodiversity is accepted but FSEs would only be of value if they include provision for comprehensive scientific monitoring.
• SNH does not support the commercial release of gm ht crops at the present time and will do so only when it has been demonstrated that this will not lead to any change in use or management of land or water which has an adverse effect on the natural environment.
• The three main concerns about the current FSEs are

  the focus is on the field and its margin with only minimum assessment of the effect on adjoining land;

  no account is taken of decomposition organisms;

  geneflow is not a core element.

• Genuine public consultation requires early, clear and comprehensive information and a longer timescale for response. Factors such as the high quality of the local natural environment should be taken into account.

7. FURTHER POINTS MADE IN RESPONSE TO QUESTIONS FROM GROUP MEMBERS

• SNH has an executive board whose twelve members include the Chairs of three area advisory boards. It was the role of the executive board to make representations to Scottish Ministers and it had done so on FSEs.
• SNH would confine any direct policy inputs to biodiversity issues but might also recommend that views should be sought from a wider audience or on other issues.

8. SUMMARY OF POINTS MADE TO THE GROUP BY THE SCOTTISH ENVIRONMENTAL PROTECTION AGENCY (SEPA)

Tom Inglis (Manager, Pollution Prevention and Control)

• SEPA carries out similar functions to the Environment Agency (EA) but works to slightly different legislation. Broadly speaking it has two roles: regulation and influencing/persuasion.
• Its locus in respect of GM crops is limited and focuses mainly on the aquatic environment. In the specific case of the current FSEs its principle relevant powers relate to the discharge [of the herbicide] into local watercourses and not to the GMO release itself.
• EA but not SEPA had been a party to the Advisory Committee on Pesticides' (ACP's) decision to authorise the use of the herbicide used in the FSEs outwith its normal terms and conditions. SEPA had not had the opportunity to consider the particular conditions relevant to Scottish FSE sites (eg increased water run off during the winter). In consequence, it had had no opportunity to monitor (or advise the operator to monitor) the potential effects on local groundwater.
• SEPA also has powers to control waste disposal but these do not currently extend to agricultural waste and do not therefore include FSE crop residues.
• SEPA would support the calls for more consultation before FSEs are allowed to take place. At present its statutory powers relate to 'post event' prosecutions. Opportunity to consider the implications of proposals would allow input aimed at preventing the occurrence of problems.

9. FURTHER POINTS MADE IN RESPONSE TO QUESTIONS FROM GROUP MEMBERS

• The original authorisations for the herbicide in question related to different seasonal use. In the case of FSEs it would be used in winter when soils were bare and likely to be saturated. Groundwater movement would be different.
• SEPA had not had an opportunity to make input to the new assessment and had not been consulted by the Scottish Executive prior to the announcement of the FSEs. If it had been asked and in the light of the experimental nature of the evaluations it would have requested increased monitoring.
• SEPA did not see a case for being consulted on all herbicide use but should have an opportunity to comment on novel products or use outwith previously authorised conditions.
• In general terms its role could be more effective if there were a requirement to provide SEPA with advance information rather than just allowing the Agency a reactive role.

10. SUMMARY OF POINTS MADE TO THE GROUP BY HIGHLAND AND ISLAND GM CONCERN

Kenny Taylor (Chair) Jo Hunt (member), Bryan Beattie (Director)

(note: H&I GM concern had also sent written comments to the group in advance of the meeting)

• The opportunity to put views to the AEBC group is welcome but why is the debate only now being held? H&I GM Concern fully supports previous speakers' comments about the consultation process. Procedures had been inadequate. Local organisations could not be expected to produce a scientific case at 14 days notice.
• Current regulatory mechanisms are inadequate and unable to cope with the speed of change as evidenced by current Nature and New Scientist articles on the human genome.
• The concept of substantial equivalence is unrealistic in this context. GM crops should not be released in advance of completion of testing.
• Dominance of the research agenda by private companies mitigates against adoption of the precautionary principle.
• Introduction of GM crops against a background of consumer resistance and falling world markets does not make sense. Neither does introduction into the 'clean' Highland environment by way of an FSE. The current trial is at the wrong time and in the wrong place.
• The site chosen on the Black Isle is unsuitable and poses dangers for the Munlochy Bay Special Area of Conservation. Reduced weeds will result in fewer farmland birds and the herbicide used would kill 20-40% of soil fungi and adversely affect water quality.
• The consequences of geneflow and the agronomic and economic affect on the farming pattern in the Highlands have not been taken into account. The potential for contamination of organic crops has been ignored or dismissed.
• H&I GM concern would propose 5 key tests for GM crops:

  demonstrably safe;

  useful products for which there is a demand;

  locally beneficial and not disruptive to the local farm economy;

  seed/chemical companies to accept liability for any harm caused by their product;

  assessed via the planning process as publicly acceptable.

• The process of assessment should be holistic, not just limited to scientific issues and allow for democratic debate.

11. FURTHER POINTS MADE IN RESPONSE TO QUESTIONS FROM GROUP MEMBERS

• AEBC had not made the statement on geneflow attributed to the Commission in the H&I GM Concern paper and presentation.
• Debate is necessary to avoid a situation where one individual could, in effect, make decisions on behalf of the community.
• History - eg of pesticide usage - shows that monitoring and regulation of technology did not always keep up.
• More research is needed to answer common sense questions such as: 'What effect will this have on my children?
• The public would like to trust Government to make assessments but BSE and other issues has lead to a crisis of confidence. UK (or Scotland) should follow the lead of Germany and Nebraska and S Dakota in the USA and declare a moratorium on GM crops. Current Government attitudes are perceived as pro-industry and pro-USA.
• A moratorium is not a de facto ban. It would allow a breathing space to answer questions and take stock.
• Herbicide tolerant crops produced by conventional breeding methods give rise to similar concerns to those produced by GM.
• Concerns about spraying saturated fields need to be tempered. Farmers would not use tractors and other heavy machinery under these conditions. However, colder weather leads to delayed breakdown of the pesticide so leaching may be more likely when wet conditions follow application.
• There is particular concern about GM crops and FSEs in the Highlands because the perceived quality of the region's agricultural produce was a selling point.

12. SUMMARY OF POINTS MADE TO THE GROUP BY HIGHLANDS AND ISLANDS ORGANICS ASSOCIATION

Donnie MacLeod (organic farmer)

• 87 mainly small, local farmers are members of HI Organics. Most are mixed enterprises aiming to supply local markets. Business is growing fast and mainly by word of mouth.
• Customers' reasons for buying organic food vary and might relate to health, taste or a simple desire to have something that hadn't been tampered with.
• Those involved in the setting up of the local FSE had done so in apparent ignorance of a locally grown crop of oil seed rape.
• GM crops are an unnecessary risk when European farmers are subject to set-a- side and there are food mountains. They threaten the livelihood of organic farmers and are unwanted by customers. Eighty per cent of the public would prefer to see money spent on organic farming rather than crop trials. Guarantees that food was '99% GM free' are insufficient.
• Consultation without the intention of doing anything was wrong. Transparency without listening is arrogant and bully boyish.
• Countries such as USA and Canada that had previously supported the growing of GM crops were now starting to pull back.

13. FURTHER POINTS MADE IN RESPONSE TO QUESTIONS FROM GROUP MEMBERS

• Agriculture in the W Highlands consists primarily of small farms traditionally operated in an organic way. Generally speaking no or only small changes are needed to gain accreditation.
• The Soil Association's policy of zero tolerance for GM contamination is based on the customers wish to buy GM free food.
• Cross pollination from non-GM crops is a different issue. Natural breeding methods have been used for thousands of years and do not involve the movement of genes from one species to another.
• A degree of neighborliness was necessary to resolve restrictions on choice imposed by different farming methods.
• Liability for eg contamination by fungal spores would be a matter for the lawyers.

AEBC secretariat
March 2001

AGRICULTURE AND ENVIRONMENT BIOTECHNOLOGY COMMISSION

SUB-GROUP A (STRATEGIC DECISION MAKING)

These notes represent the views of the sub-group and those they held discussions with, not the full AEBC

NOTE OF VISIT TO A FARM NEAR INVERNESS WHERE AN FSE WAS TAKING PLACE ON 19 FEBRUARY 2001

Note: The group had written notes supplied by the farmer. A summary of the additional points made in the discussion is given below. Paul Rylott (Aventis) and Geoff Squires (Scottish Crops Research Institute) were also present at the invitation of the AEBC group but did not make any formal representations.

• Farm workers had not faced any hostility locally because of the farm-scale evaluation being conducted on the farm.
• Glufosinate kills a broad spectrum of weeds but is less effective against some than others (eg large grasses, pansy, cleavers and annual nettle are quite difficult to control with glufosinate).
• Pre-emergence sprays such as atrazine leave a 'desert' whereas with herbicide tolerant crops it is possible to allow weeds to grow up. After spraying the dying foliage provides a habitat. Concerns about glufosinate use should be put into context.
• Experience of growing GM HT crops in other countries (eg Canada) does not obviate the need for FSEs. The environmental issues are different; farmed areas are larger and without the diversity found in the UK.
• Expressed concerns about GM crops might be a political 'tool' reflecting wider concerns about the direction of agriculture.
• GM crops are grown to maximise margins which might be done by increasing yield or reducing inputs (or both) but yield is not measured as part of the FSE. Longer term impacts should also be studied.
• Farmers in North America had found advantages in using the GM crops available there. The main advantage is in easier management and reduced labour costs.
• HT GM crops are new and farmers have no experience with them in the UK. Over time they will learn how to use them and adapt their management regimes accordingly.
• There is a need for tolerance between different types of agriculture. Both farmers and consumers have a right to choose.
• Attendance at the second meeting to discuss the FSE had been lower than the first (150 approx as opposed to 400 approx).
• The SCRI had recently been awarded a contract from SERAD to study gene flow from the FSEs in Scotland.

AEBC secretariat
March 2001

AGRICULTURE AND ENVIRONMENT BIOTECHNOLOGY COMMISSION

SUB-GROUP A (STRATEGIC DECISION MAKING)

NOTE OF A DISCUSSION WITH PUPILS FROM FORTROSE ACADEMY ON 19 FEBRUARY 2001

Three members of the group (Justine Thornton, Phil Dale, Jeff Maxwell) had an informal discussion with seven pupils from the Fortrose Academy. The following points were made.

• GM had become an issue when the local FSE was announced. If it had been further away local people would have been less worried.
• Leaflets should be used to provide information. These might be written by a variety of people and present the differing views.
• People buy organic food because they know what they are getting.
• The long term effects of GM crops were unknown. On the other hand conventional farming also damaged the environment. Decisions needed to be made about the future of agriculture.
• Preferred characteristics that might be sought via GM technology could be barley which held its head and pest resistance.
• Local people should always be consulted about GM crops. Decisions should be made by mixed committees representing local and national views. Politicians should come to public meetings.
• GM crops might be important to the third world but could be susceptible to exploitation by big business.

AEBC secretariat
March 2001