Memorandum submitted by Alan Simpson MP
(A12)
1. EXECUTIVE
SUMMARY
1.1 The GM Nation? debate intended
to be a welcome process, allowing the public to participate in
the making of big and controversial decisions. Despite the concerns
brought up in the following passages the debate attracted a good
response from the public, where they were able to find out how
to participate.
1.2 The central issues focused around the
following issues:
— the budget and timing of the
Debate;
— the role of the COI (Central
Office of Information);
— the adequacy of publicity;
— the role played by the FSA;
— the Debates themselves;
— the issues that were avoided.
These are the criticisms that this submission
focuses on.
2. BUDGET AND
TIMING
2.1 The amount of time and money allocated
for the debate was simply inadequate to facilitate the type of
process required by the Public Debate Steering Board (SB), and
also of that demanded by the complexity of the issue. Problems
were created for the SB when, halfway through the process, the
original budget (based on figures from the COI[9])
had to be revised and the time extended. Defra did cover the additional
management costs incurred by the COI as a result of the extension
and the final budget was double the original amount. However,
the amount was still insufficient to fulfil the task that had
been set. Yet another factor that hindered public participation
was the lack of funding for promotion and advertising. The budget
allocation for publicity was non-existent. Organisers of local
meetings had to foot the bill for these events themselves. These
were often small, unfunded voluntary organisations or even individuals.
As a result of the COI failing to follow up requests for assistance,
many local meetings were simply inadequately resourced.
2.2 The GM Nation? stimulus materials
(and details of the public debate county and local meetings) were
not available until the launch date in June. Potential organisers
had no idea what was required or what was available to support
them. Requests to extend the debate to allow more local meetings
to be organised were rejected by the Secretary of State, adding
to the suspicion that the Government was working to "approval
timetable" rather than an open consultation.
2.3 Government guidelines for public consultation
exercises allow at least a two or three month period. In this
case the public debate was only allowed six weeks. This was grossly
insufficient as it meant that many members of the public were
only just hearing of the debate as it was coming to an end. Similarly
many local authorities found it impossible to participate in the
debate within the allotted time frame.
2.4 The timing of the public debate was
defective on two other grounds. Critical information was inaccessible
throughout the debate. This was partly because the Strategy Unit
Report was only released days before the end of the process and
the Science Review was not published until after the debates had
finished. Moreover, the results of the Farm Scale Evaluations
(an exercise deemed by the Government as critical to the future
development of GM crops in the UK) were also unavailable to the
participants of the public debate. The public perception was that
this was deliberate rather than unfortunate.
3. APPOINTMENT
AND ROLE
OF THE
COI
3.1 The Central Office of Information (COI)
was appointed as the main contractor to deliver the GM Nation?
programme of events and materials. Two factors made this decision
controversial: It raised questions about how independent from
Government this would be. Additionally there were concerns that
the COI lacked both the experience and the competence to manage
a public debate of this kind. These misgivings were expressed
by both the AEBC[10]
and the members of the Steering Board. The SB was not able to
consider alternative contractors. It was told that the COI would
have to be used due to the limited time and budget. Also, Defra
had regular management meetings with the COI beyond that required
to ensure budget management. It appeared that Defra were keen
to keep control over the debate despite the public suggestion
that it was independent of Government.
3.2 There were certain areas of the debate
where the COI demonstrated a lack of experience. This was particularly
evident with the design of the open deliberative element of the
debate. The guidance needed by the SB was not forthcoming for
the creation of a debate which would imaginatively engage the
public; especially a public suspicious of GM and of the Government's
intentions. The debate failed to provide a public basis for understanding
and exploring scientific doubt about GM technologies. It did not
enable the public to make their own risk assessments about whether
Britain needs GM crops or of alternative choices about secure
and sustainable food supplies. The debate was therefore constructed
within narrow and limiting terms.
3.3 Information and materials necessary
for participating in the debate were not easily accessible. There
are numerous accounts from NGOs and members of the public facing
real difficulties in obtaining help via the contact points set
up by the CIO. Such difficulties, during the process of the public
debate, suggest that the COI lacked the capacity to deal with
the administration and organisation of the process. This basic
administrative failure will have limited the numbers able to take
part in the debate.
3.4 Further concerns expressed of the role
of the COI:
— A failure to understand the breadth
and scope of the process proposed by the AEBC
— A serious underestimate of the budget
needed to deliver a credible public process
— A failure to develop stimulus materials
that had been sufficiently tested prior to the commencement of
the debate
— A failure to offer local meeting
organisers sufficient support
— Failure to proactively encourage
local meetings especially in areas of the country or communities
where the inhabitants had not joined in the long running debate
on GM.
— Problems with the use of the CD
— Problems in distributing response
forms (eg one person was posted a form completed by someone else)
— The electronic response form was
different to the paper version
— Poor response time to telephone enquiries.
4. PUBLICITY
4.1 In simple terms, there was insufficient
publicity given to the process to make it a genuine national debate.
Because of the limited budget there was no allocation for advertising
and promotion. Publicity was limited to media coverage and this
was at best erratic.
4.2 There was no significant or repeated
publicity in either of the main farming publications—Farmers
Guardian or Farmers Weekly.
5. THE ROLE
OF THE
FSA
5.1 The Food Standards Agency organised
a Citizen's jury, focus groups, a schools debate, video and publication
on GM. The FSA's intervention in the public debate has been criticised
by the FSA's Consumer Committee as being biased. Outside organisations
took the same view. It cannot be helpful for the FSA to be seen
as a sales team for the biotech industry when its central role
is that of a public watch dog. The FSA spent £110,000 on
this and did so without prior consultation with the GM Nation?
steering board. It did not appear to be the wisest or best use
of public money.
5.2 The FSA report to ministers on the GM
debate was produced before the debate had even concluded. This
fuelled public cynicism about their role in the debate.
6. THE "DEBATES"
6.1 One major criticism of the debates was
the unbalanced pro-GM scientific representation of the speakers.
Pro-GM scientists (many supported by the biotech corporations)
were out in force but were keen to avoid the awkward issues of
scientific doubt and to sidestep key areas of contention. Members
of the public raising serious concerns about risk and risk assessment
were brushed aside. Public criticism was that the debates were
often used to intimidate and discredit opponents rather than subject
the science to serious scrutiny. There was also criticism about
the biasing of "expert panels for the debates".
6.2 The Berkshire GM debate, at the University
of Reading, was a good example of this. The University has a strong
pro-GM stance and local GM companies were strongly represented
at the meeting. Those putting a pro-GM case were a principal research
fellow at the university and a scientist from Syngenta. Those
putting the case against were a member of the University Students'
Union and a local anti-GM activist. Nothing in the debate was
designed to subject the science to tough scrutiny.
6.3 In another debate one of the pro-GM
speakers introduced himself as a molecular biologist, but not
as a member of a biotech company funded by Monsanto. Monsanto
representatives arrived with the speaker, conducted a press interview
with him and answered difficult questions on his behalf. They
also repeatedly sought to challenge the credentials of speakers
putting the anti-GM case. The public were left wondering why the
biotech industry was allowed such a high profile role in the conduct
of the debate.
6.4 No attempt was made by the COI or the
Steering Board to clarify the scientific issues that needed to
be addressed in the debate. This meant that misleading claims
were able to be repeated without ever being explored. In the debate
at Coventry Town Hall the claim that "DNA is DNA is DNA"
was used to suggest that GM-DNA is no different from natural DNA
and ignoring the fact that integration of transgenic DNA into
a cell's genome (rather than its absorption into a cell) is one
of the big risk areas that we currently know little or nothing
about.
6.5 Key players were left out of the debate.
Despite being the people who would either directly use or have
their neighbours' use of GM crops indirectly impact upon their
lives, farmers' voices have been surprisingly limited in the overall
debate. Recent figures published by FARM[11]
reveal that in a sample of 600 farmers randomly selected across
England and the Welsh borders 51% disagreed with the development
of GM crops would overall benefit farmers, with 11% strongly disagreeing.
Farmers, however, were given limited opportunity to voice this
opinion during the debate.
6.6 Although NFU attempted to organise meetings
in their own right these did not prove effective in delivering
large scale farmer involvement or an interaction between farmers
and consumers. The timing of the debate meant that many farmers
were unable to become involved as they were busy with silage-making
and preparations for harvest. It isn't rocket science to know
that if you want to gather farmers together in discussion groups
or other meetings, you need to get them before or preferably after
harvest (The Royal Show excepted). October through to February
is the most productive time to get farmers into a meeting room.
6.7 Only three official national debates
were scheduled across England. This did not include Norfolk, the
potential heartland of commercialisation. Why was such a key area
ignored? The few large scale farmer proponents of GM are represented
in Norfolk and ought to have been required to address the critical
arguments of those against the technology.
7. DEBATING WHAT?
7.1 To have a useful, informed debate, the
key areas of scientific disagreement should have been clearly
laid out before the public. The public were asked to debate in
an information vacuum, and worse. No critical, relevant scientific
evidence on the problems and hazards of GM crops as opposed to
the potential benefits was presented.
7.2 There is a priori and empirical
evidence (presented in Annex 1) suggesting that GM is inherently
unsafe and unpredictable. There are easily identifiable critical
areas of scientific doubt or challenge. These key areas of scientific
concern should have been presented to the public and addressed
independently. This, rather than the "case by case"
approach recommended by the GM Science Review First Report, is
what the public have a right to expect of government.
7.3 There was also a failure to present
the many health, environmental and social benefits of sustainable
non-GM agriculture as opposed to GM agriculture. The debate failed
to address the alternatives to GM—both in terms of crop
management techniques and non-transgenic plant breeding techniques,
such as Marker Assisted Selection. Any informed decision about
GM can not be reached without a full appraisal of costs and benefits
and these need to be weighed against those for alternative strategies.
7.4 The debate did not even attempt to address
public concerns over safety of GM crops for health and the environment,
the absence of tests about allergenicity, or the social and economic
impact of commercial GM crops production already affecting farmers
in the United States, Canada, India and elsewhere.
7.5 Throughout "the debate" the
public was faced with a serious lack of critical information on
GM. They were also kept in the dark about what use the Government
intended to make of the debate. Public scepticism about the Government's
intention to take any notice of the outcomes of the debate was
a major factor in the public's attitude towards the debate process
itself. Deep scepticism based on historic mistrust of Government's
actions on this issue and legitimate doubts about the displacement
of independent science by "bought" science meant that
public perception of the debate was that the process was little
more than a PR exercise.
7.6 The steering board did try to elicit
from the Secretary of State assurances that the Government would
act on the results of the process. The ambiguity of the government's
response inevitably affected the level of public involvement.
Never the less we must not detract from the efforts put in by
tens of thousands of people around the country to take part in
this debate. The demands for involvement that went unmet, indicate
both the level of public concern about this issue and the extent
to which the government has failed to carry the public with it
in it's desire to press ahead with early GM crop commercialisation.
Alan Simpson MP
September 2003
POST SCRIPT
This submission has been put together following
discussions with, and contributions of evidence from, a range
of individuals and groups concerned about the conduct of the GM
Nation? debate. In particular I would like to thank Clare
Devereux Director of Five Year Freeze (also a member of the steering
board overseeing the process of the debate), Sue Mayer of GeneWatch,
Dr Mae-Wan Ho of the Institute for Science in Society (I-SIS),
Robin Maynard of FARM, Pete Riley of Friends of the Earth, Members
of Friends of the Earth Wokingham and Caroline Clarke of the Burnhams
Group, for the assistance they have given me.
9 Central Office of Information. Back
10
Agriculture and Environment Biotechnology Commission is the Government
strategic advisory body on biotechnology issues affecting agriculture
and the environment. Back
11
FARM is a campaigning organisation set up by working farmers
for working farmers, but its membership is also open to and represented
by the wider public. The organisation's overall objective is to
fight for a sustainable and diverse food and farming sector in
the UK. Its membership is not restricted to membership to any
particular sector, system or scale of farming. Back
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