Memorandum from the National Farmers'
Union of England and Wales
INTRODUCTION
The NFU is a business association representing
some 75% of the total output of farming in England and Wales.
We aim to enable our members to provide high quality, safe, varied
food and other products, in a diverse and spectacular countryside,
while remaining at the heart of a thriving rural economy. We represent
farmers and growers with a wide spectrum of views on GM technology.
Therefore, the potential impact of the application of GM technology
in UK agriculture is of great interest to us. We are particularly
concerned that measures are put in place to ensure responsible
use of this new technology for the benefit of grower and the environment,
while safeguarding choice for both growers and consumers.
1. The adequacy of the design of the farm
scale trials and their ability to answer the questions posed at
the outset of the trials
1.1 We are not in a position to comment
in detail on the design of the farm-scale evaluations (FSEs).
The design of the experiment appears suitable to address the issue
under consideration. However, we note the trial results indicate
the likely impact of cost-effective management of herbicide tolerant
(HT) crops compared to the conventional equivalent crop, managed
according to current practice. The fact that the herbicide tolerance
trait was developed using genetic modification would appear to
make no difference to the results.
2. The conduct and operation of the trials
2.1 SCIMAC was established in June 1998
to support the open and responsible management of GM crops in
the UK. The NFU, as a member of SCIMAC, is committed to ensuring
that the growing of GM crops in the UK is carefully managed, identifies
closely with public opinion, and delivers a meaningful choice
for consumers. SCIMAC developed a programme of on-farm management
guidelines for GM herbicide tolerant crops to ensure best practice
in the way the crops are grown, and to provide choice for consumers
via identity preservation of GM crops and neighbouring non-GM
crops.
2.2 SCIMAC role during the FSE programme
was as follows:
— To identify a pool of participating
farmers from which the Scientific Steering Committee could select
trial sites.
— To provide seed and chemicals to
be used in the trials.
— To develop on-farm management guidance,
endorsed by Government, for participating farmers.
— To ensure correct disposal of the
crops and any spare chemical or seed.
2.3 The NFU was a founder member of SCIMAC
and continues to actively support it. With our industry partners
we were involved in the drafting of guidelines to ensure responsible
management of GM crops during the FSEs. The NFU's role as a member
of SCIMAC ensures that the views and requirements of its farmer
members, whatever their chosen production method, can be represented.
2.4 The FSE results were delivered despite
recurring problems with vandalism of the trial sites. We recognise
the achievement of the team of scientists in gathering a robust
data set while operating under difficult conditions. During the
FSEs the NFU wrote to both the Prime Minister and the Home Secretary
to highlight the intimidation and criminal damage aimed at farmers
participating in the trials. We have consistently supported the
open and transparent approach taken by the Government in publishing
trial site locations. However, we are disappointed that greater
protection was not afforded the participants and the trial sites.
Inconsistencies in policing and sentencing combined with loopholes
in the law on aggravated trespass must not be allowed to hamper
the ability to conduct such research.
3. The ways in which the results of the farm
scale trials will be integrated with policy and decision making
3.1 Although we are not in a position to
speak for Government we make the following suggestions on how
the results should be used by Government in decision making:
3.2 We support a science-based, case-by-case
approach to decision making on GM crops. The NFU fully supported
the trial programme as a means to provide essential data to assist
the government in taking evidenced-based decisions as to whether
or not such crops should be grown commercially in the UK. We,
like everyone else, now await the government's decision on whether
the commercial growing of GM crops should be allowed in future.
We urge that a decision must be taken on each individual crop
in turn, and that the wider impact on the environment (as indicated
by the FSE results) should be considered and if necessary measures
to encourage best practice for environmental benefits could be
considered as part of the consent conditions.
3.3 We believe coexistence of GM crops with
other non-GM methods of production must be integral part of policy-making
on commercial growing of GM crops. If the Government does decide
to allow the commercial introduction of GM crops, we believe the
current liability framework must be clarified to provide greater
certainty to all growers as to where they stand if GM admixture
arises and help to avoid conflict between growers. We strongly
urge the Government to ensure that farmers, seed suppliers and
other operators are fully informed about the liability criteria
that apply in the case of economic damage caused by admixture
(as recommended by the European Commission on 23 July 2003).
3.4 We suggest the most appropriate mechanism
for managing liability relating to GM crops is to ensure that
new varieties undergo a formal risk assessment for food safety,
animal and human health and environmental damage prior to approval
for environmental release or marketing. Each business should be
responsible for ensuring to the best of its ability that its product
meets the market standard. The supply chain as a whole has a responsibility
to ensure market standards are practical, workable and deliverable.
3.5 We suggest an advisory system for farmers
should be developed, to encourage measures to promote the responsible
use of the new technology and offer practical advice to all growers
on best practice. This will be particularly important for those
farmers that want to be proactive in protecting their business
interests and the integrity of their production.
3.6 Accepted thresholds for GM and non-GM
purity in agricultural production (and the production procedures
required to achieve them) are an important aspect of achieving
satisfactory coexistence of different production systems. Rational
dialogue across all production systems will be needed to achieve
these objectives.
3.7 The NFU welcomed the public debate on
GMOs initiated by the Government and the approach taken by the
Independent Steering Board on the budget provided. It was our
hope that this initiative would encourage meaningful discussion
about GM technology and make a significant contribution towards
Government decision-making alongside the FSE programme results
and other scientific studies on the potential impact of the technology.
We note the Secretary of State promised to listen to the results
of the debate. Therefore, we assume that whatever decision the
Government takes on commercial growing of GM crops there will
be some indication as to how public opinion has been taken into
account. The NFU believes it is vital that public trust in Government
regulatory bodies, and science in general, is improved through
information, openness and dialogue.
4. The implications of the trial results
for Government and other decision makers
4.1 The consistency of the results across
all sites and between years clearly indicate that how farmers
choose to manage the technology on farm will be crucial in determining
its environmental impact. The results show that the difference
between crops is greater than between GM and non-GM varieties,
in terms of impact on farmland biodiversity. It is therefore likely
that changes in cropping due to agriculture policy or market drivers
will have a more significant impact on biodiversity in the UK
than the use of herbicide tolerant crops. The implication is therefore
that we need a wider debate on how policy and market drivers will
affect the balance of production in the UK, in particular a better
understanding of what balance of crop species will be grown and
what new crops species will be introduced. The discussion of GMHT
crops must be put in this wider context.
4.2 The results are also important for farmers
on an individual level. There has been a great deal of interest
in the trials and how the technology performs, not just in terms
of impact on biodiversity but also the potential for more environmentally-friendly
weed control. The trials were not designed to explore the different
options offered to farmers by GMHT crops. Therefore, if the technology
is to deliver maximum benefit for both farmers and the environment
then the question of how to best manage the technology agronomically
must be addressed through further research. We question whether
the responsibility for undertaking this research should be left
solely to private industry.
4.3 We suggest the importance of trial results
for conventional agriculture should not be underestimated. This
is the largest ecological survey that has been conducted and data
set for conventional agriculture alone is useful. For example,
we look forward to the publication of the results of the winter-sown
oilseed rape trials, to be able to compare these with the spring-sown
oilseed rape. We understand further data from spring-sown crops
will also be published at a future date. Further analysis of data
should also be undertaken as opportunity to explore other questions.
4.4 We note the intense interest in the
FSE results in other countries and suggest both the results and
subsequent Government decisions may have an influence on policy-makers
around the world. This underlies the importance of the UK Government
taking a science-based, proportionate approach to decision-making.
5. The costs and benefits of GM food, bearing
in mind the potential market, in the light of the farm-scale trials
and the recent Strategy Unit report
5.1 We believe GM crops could potentially
offer some cost and convenience advantages to UK farmers. However,
we make a distinction between the short-term and the long-term
costs and benefits of GM crops.
5.2 In the short term (within three to four
years), we feel the economic benefits to UK farmers are likely
to be limited, due to a number of reasons:
— only a narrow range of existing GM
crops have been developed for use in UK conditions;
— full approval for commercial use
of these crops has yet to be obtained; and
— weak consumer demand is likely to
limit take-up by farmers.
5.3 In the longer term, future developments
in GM crops have the potential to offer more wide-ranging benefits,
to both farmers and to consumers. Several factors may contribute
to improving the potential for GM crops, including:
— the development of GM crops with
agronomic benefits better suited to the UK;
— the development of GM crops delivering
direct consumer benefits (eg delivering foods with reduced allergenicity
or added nutrients) and/or non-food GM crops used as a source
of pharmaceuticals and vaccines; and
— any potential change in public attitudes
to the technology as a consequence.
5.4 At the same time, it can be argued that,
should consumer demand for non-GM products remain constant or
increase, there would be potential opportunities in remaining
GM-free. In any case, it is clear that the overall balance of
future costs and benefits will be highly dependent on public attitudes,
the ability of the regulatory system to manage uncertainties and
the ability of the regulators to communicate this satisfactorily
to the public.
5.5 The NFU sees more potential markets
for crops than just food use. The Environmental Audit Committee
may wish to consider non-food uses such as industrial feedstock
or biofuels, which are likely to become increasingly important
markets for agricultural products in the future. Furthermore,
non-food uses are perhaps a more attractive market than food uses
for GM crops in the medium term given perceived consumer sensitivity
to GM food.
November 2003
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