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CONSUMER CHOICE AND COEXISTENCE SUB-GROUP
NOTE OF EIGHTH MEETING: WEDNESDAY 26 MARCH 2003,
1 VICTORIA STREET, LONDON, 11.00am-3.00pm
MINUTES OF MEETING
Note: These are the views of the sub-group, not necessarily of the full Commission
UNCONFIRMED
Present
Ms Helen Browning
Dr Dave Carmichael
Dr Rosie Hails (Convener)
Ms Julie Hill
Dr Roger Turner
Secretariat
Richard Abel
Laura McMahon
Also present
Dr Elizabeth Hopkins
Apologies and welcome
1. Apologies had been received from Professor Jeff Maxwell.
2. The group welcomed Dr Elizabeth Hopkins to the meeting. Members looked forward to her assistance with drafting the report on consumer choice and coexistence.
Minutes of previous meetings
3. The draft minutes of the last meeting on the 4th March 2003 were confirmed.
Discussion
Table of separation distances
A draft table of available data on separation distances to achieve an Adventitious Presence (AP) threshold of 0.9% and 0.1% had been prepared by the secretariat for ease of comparison. Members found this useful as a starting point to highlight what might be possible if a coexistence regime was to be adopted and it also drew attention to the areas that needed further research and the areas where coexistence might prove difficult.
4. Further empirical data were needed to inform the group’s assessment of where difficulties were likely to be in practice, including how much of each is grown in the UK, including proportions of organic and non-organic and the proportion of fully fertile oilseed rape compared with varietal associations and partially restored hybrids. Field size and shape could have an effect on the cross-pollination rates. Small fields may make it harder for the farmer to cope with the separation distances. Using satellite technology to map crop distribution to provide better data about field sizes for this and other purposes had been rejected as too costly. (It was noted in this context that publicly available detailed data capable of providing an indication of changes to the landscape in the UK over the forthcoming years would be very useful for a variety of purposes.) Confidence limits for separation distances to achieve the thresholds should be clarified, as it was important to have a sense of how likely it was that a breach of the AP thresholds would occur with a particular separation distance – it could be very rare in some cases.
Action: secretariat
5. The group needed to know how farmers would react to separation distances and it was proposed that a version of the table should be given to those attending the stakeholder seminar. The apparent anomalies within the table would have to be fully explained before this, such as the difference in separation distances between the oilseed rape threshold of 0.9% shown by Ingram and that proposed by the Danish study. The group noted that the 600m separation distance adopted in the FSEs for organic beet was derived from historic seeds legislation related to varieties of beet which were open pollinators and were no longer used. The 6m used in the FSEs was a suitable distance to allow machinery to move around the field. With removal of bolters and weed beet (normal agricultural practice) a zero separation distance could be sufficient. The higher theoretical separation distances shown for forage maize had been adjusted down in practice for the FSEs, due to heterozygosity within the crop.
6. It was agreed that the AEBC report did not have to take a definitive view on precise actual separation distances for each crop but that it should draw on existing published research and analysis to derive in the first instance a range of separation distances which would in conjunction with other measures as appropriate, be expected to deliver coexistence.
7. It had already been decided that the report would cover consumer choice and coexistence on the farm and go only up to the point of delivery of the crop from the farm to the next stage in the supply chain however, some Members of the group felt that aspects of consumer choice may require reference to the imminent regulations on traceability and labelling and the demand at present by large food retailers for a threshold of 0.1% (‘zero’) AP in relation to many products. The impact of this on farming practice and separation distances should be clearly alluded to.
Thoughts on achieving possible coexistence
8. The group sought to summarise their position in recommending possible co-existence scenarios. They concluded that coexistence of beet at both 0.1 and 0.9% AP was probably achievable provided good farming practice was adhered to and the necessary control of bolters was performed. There was more difficulty in recommending measures for 0.1% for oilseed rape and maize. Members noted that almost all oilseed rape grown in the UK was of the fully-fertile variety (achieving 0.9% AP for fully-fertile appeared to be much easier than for other varieties).
9. In this context, Members also noted that oilseed rape was not a crop grown widely in the UK by the organic sector whereas maize in both grain and forage varieties was increasingly important to organic farmers. Perhaps there might in future be room for some sort of mutually acceptable compromise between organic and GM farmers.
10. This line of thought ran as follows. Organic production of maize required crop rotation, showed increasing environmental benefits and although not a grown to a great extent was potentially very important to the organic sector especially as feed for dairy cattle, and also as organic sweetcorn. Conversely, oilseed rape was not at present an important organic crop: very little was grown in the UK. Since around 90% of non-organic oilseed rape was winter-sown there could be scope for a mutual agreement whereby the presumption would be that farmers who wished to grow GM rape would grow winter-sown varieties and organic farmers would normally grow spring-sown crops, in order to maintain a 0.1% AP threshold for organic rape. Dave Carmichael told the group that spring oilseed rape tended to be grown by non-organic farmers as an emergency crop because its yield was significantly lower than winter varieties. This would seem to be unlikely to be a great problem for GM farmers – though clearly the yield difference would be a negative factor for organic farmers if organic rape production became widespread
11. The other side of the coin could be relatively large separation distances between GM maize crops and organic maize in order to minimise any AP. The question over whether biodiversity may be affected if only winter oilseed rape was grown was not a major issue, given that 90% was already winter-grown. The group felt that it was not for the AEBC in its advice to assume that the principal organic licensing authorities would alter their threshold limits, although that clearly was one possible solution to the most acute co-existence issues. This was only one line of thought on how to proceed, and would need to be tested with farmer and farming organisation stakeholders. The sub-group did believe that this was a possible example of seeking possible solutions to coexistence that went with the grain of present and likely future farming practices in each sector.
12. It was acknowledged that contrary to what had previously been suggested in relation to farmers talking regularly to their neighbours, one could not assume this went on routinely: in fact many did not have need to speak from one year to the next. Dave Carmichael stressed that if however farmers were planting a seed crop then it was much more usual for communication between to occur between farms. Cultivation of GM crops could mean that communication increased, as the situation would be analogous to seed-crop cultivation.
Other farming practices
13. The group discussed seed handling and spillage and possible impacts on AP. Some members had thought that roadside spillage of oilseed rape may cause problems in traceability. Rosie Hails suggested that it was unlikely that spillage of oilseed rape would cause a large problem on busy road verges as these were often mown before the plant became established. There would be more concern over quieter roads and field margins where mowing might not eliminate the problem. But volunteers did not tend to persist, and it seemed unlikely that roadside volunteers would be a significant factor in producing AP. Dealing with volunteers on the farm would seem to be more important. Crop rotation and good volunteer control would be key to this. A review of the evidence presented at the York workshop would help with determining this question.
Action: secretariat
14. It was possible that planting barrier rows in maize growing may allow for the reduction in separation distances. A combination of methods could be proposed starting with a basic separation distance and detailing the changes in separation distances with particular barrier planting. The secretariat would seek further evidence on this question.
Action: secretariat
Maize seed in the UK was normally imported and there could be concern over the AP level in the seed. This should be addressed in the draft report.
The draft report
15. Members felt that the introduction of the report needed to be very clear on what consumer choice actually meant in this context: it did not simply relate to individuals choosing an item of a shelf. If the report was to cover aspects relating to consumer choice then it should seek to do so in a reasonably comprehensive way and not over-simplify it. Reference should be made to the ability to deliver choice but that the cost implications may make this unrealistic and it would be necessary to put it into the context of UK and foreign agricultural systems. The presentation previously given to the group by Anna Bradley provided useful information on factors affecting consumer decisions e.g. accessibility, affordability and the opportunity for redress. This should be included in some way in the introduction.
16. The introduction should also clearly state what the AEBC was seeking to do through this work and the possible ways forward without any recourse for legal intervention. The report should set out all the options for dealing with possible coexistence and highlight strengths and weaknesses of each. It should be exact on what it can offer advice: i.e. consumer choice as it relates to possible coexistence on the farm, recognising that further measures would need to be in place to minimise AP elsewhere in the supply chain.
17. Reference should also be made to patterns of agriculture and policy on GM crops in the devolved administrations and any differences that might need to be considered.
18. A suggestion was made that a small worked example of coexistence of each particular crop should be included. This would detail any change in costs and the implications of this and where the costs may fall. It would include environmental impact and monitoring and testing expenses along with the possible effect on consumer choice.
19. The impact of possible GM crop cultivation on beekeepers needed to be covered in the report.
Action: secretariat/Dr Hopkins
Testing
20. The group discussed the possible difficulties surrounding testing. In the initial period of a possible coexistence regime, it may be difficult to rely solely upon a protocol and it may be necessary to carry out a full testing programme of sites around a GM crop within a certain radius. Some Members thought this would prove too costly and labour intensive, but others felt it might be necessary in order to test the protocol successfully and that as there was likely to be a gradual take-up of GM crops if they were commercialised, this may not be as onerous as it first appeared. This data could be made available to help development of an insurance market. Farmers should also perhaps be required to keep a sample of the seed from their crop for a specified period of time so that it could be available for test in case of dispute.
21. The specifics of testing for AP in oilseed rape were raised. There was a relatively short interval between testing and harvesting, when testing had to take place. If immature seed was used for the test, it might not give a reliable result using the polymerase chain reaction (PCR). The reliability of the testing laboratories would also need to be scrutinised. It would hopefully become possible to cease testing (unless there was a case in dispute) if it could be proven that farmers had followed the protocol and that the protocol was robust.
AEBC meeting 4th April 2003
22. The group agreed that a short synopsis of the main points of the report as it stood and the emerging thinking of the group, together with specific areas for discussion with the full Commission should be circulated to all AEBC Members before the meeting. A copy of the draft report as it stood and a revised version of the secretariat separation distances table and supporting notes should accompany it for AEBC Members but it was agreed that the draft report was not ready for publication as a tabled paper at the meeting at this stage.
Action: secretariat
23. The group would seek specific guidance from the Members on the following points:
a) The scope of the report and the balance of the two main strands of consumer choice and coexistence. Was a more comprehensive report than that envisaged at present necessary? (If so, that would have time implications)
b) The emerging indications of where pressure points are likely to arise in keeping to thresholds. (Roger Turner would lead discussion at the Commission meeting on this point, giving a brief oral presentation using a compare/contrast format of the crops)
c) The options for possible coexistence. Could some be rejected? Which were more desirable?
d) What implications did the policy development on coexistence within the European Commission and wider political developments, including the threat of WTO (World Trade Organisation) action have on the work of the AEBC on consumer choice and coexistence?
e) How the AEBC report related to the wider public debate;
f) What to cover at the stakeholder seminar.
Action: secretariat/Dr Hopkins; Dr Turner
The stakeholder seminar
24. The group decided that the stakeholder seminar should be divided into three parts. There should first be an overall introduction of what the group was trying to achieve and broadly what it wanted from the meeting and a general overview of the current thinking. Rosie Hails would chair this. The second strand would be led by Roger Turner and focus on possible protocols and whether these should be voluntary or mandatory. The final session would look at other opportunities that may arise from introduction of any coexistence regime such as wider environmental improvements and would be introduced by Julie Hill. In this session we would also explore whether there were imaginative solutions available to deal with the difficult cases of coexistence with organic growing of oilseed rape and maize. Each period would consist of a question and answer session, chaired by the relevant sub-group Member who had introduced the item. Dr Hails would wrap up the session at the end.
25. It would be important to give equal weight to the two threshold levels of 0.9% and 0.1% and not to get too immersed in the lower of the two.
26. It would also be important at the seminar to seek a steer from food processors and supermarkets about what threshold they expected to work to in coming years and in respect of what crops.
Any other business
27. There was none
AEBC Secretariat
March 2003
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