I am writing to comment on this draft report in my personal capacity, and not as a member of a government advisory committee.

I welcome the fact that AEBC chose to investigate this area. I was, however, extremely disappointed with this draft, for the following reasons:

1. The paper does not explicitly indicate where it adds value to existing investigations and inquiries by other public bodies with differing mandates. It seems to me that the starting point of the terms of reference should be to define precisely where AEBC can make a difference with its analysis and consultation.



2. The analysis of agricultural biotechnology is partial as it does not also address other sorts of biotechnology research.



3. The analysis does not include a review of the methodology for classifying whether research falls under a biotechnology heading or not.



4. There is nothing in the paper about the two key drivers in agricultural policy, namely CAP reform and trade liberalization. This severely reduces the paper's relevance.



5. There is nothing in the paper on the international context of research. Public research is increasingly internationalized, with many links elsewhere in the world. At the same time, overseas research in biotechnology is rapidly growing. Why is there no mention of China and India, for example, when research in these countries clearly has an effect on, and is affected in turn by, research in the UK.



6. AstraZeneca long ago changed its name to Syngenta (p33).