Memorandum from Professor Chris Pollock,
Chairman of the Scientific Steering Committee for the Farm Scale
Evaluations of GM Crops
I submit this memorandum as chairman of the
scientific steering committee set up to oversee the conduct of
the farm-scale evaluations of genetically modified herbicide tolerant
crops.
This memorandum is separated into several sections
that in turn relate to:
1. The establishment of the scientific steering
committee.
2. The adequacy of the design of the farm-scale
evaluations.
3. The conduct of the farm-scale evaluations.
4. The publications of the results of spring-sown
crops.
5. The ongoing oversight of winter oilseed
rape trials.
1. THE ESTABLISHMENT
OF THE
SCIENTIFIC STEERING
COMMITTEE
The Deputy Prime Minister and then Secretary
of State for the Environment appointed the scientific steering
committee (SSC) in May 1999. The membership of the committee is:
— Prof Christopher Pollock (chair),
Institute of Environmental and Grassland Research.
— Dr Nicholas Aebischer, The Game Conservancy
Trust.
— Dr Alastair Burn. English Nature.
— Prof Mick Crawley Imperial College.
— Dr David Gibbons, Royal Society for
the Protection of Birds.
— Mr Jim Orson, Morley Research Centre.
— Dr Nick Sotherton, The Game Conservancy
Trust.
The secretariat for the committee is provided
by Defra-CGMP. Meetings have been attended by non-participating
assessors from Defra, Scottish Executive, English Nature and SCIMAC,
particularly during the early stages when methodology was being
developed (see below). All assessors were requested to leave when
actual results were discussed.
The terms of reference were agreed at the inception
of the committee and are as follows:
"To advise the Secretary of State for Environment,
Food and Rural Affairs, the Scottish Executive and the Welsh Assembly
on the ecological studies in the farm-scale evaluations of genetically
modified herbicide tolerant crops, particularly:
— The progress of the ecological studies.
— All aspects of the design and methodology
used in the studies.
— Statistical analysis of data.
— The conclusions which may be drawn
from the results.
— Publication of results.
— The need for further research. "
Studies other than the ecological studies were
conducted on the farm-scale evaluation sites. In particular these
included studies on gene flow between equivalent crops and between
crops and wild-relatives. The SSC was not responsible for oversight
of these but did consider whether they would interfere with the
core ecological studies. In each case they concluded the work
would not interfere.
Copies of the press notice announcing the intention
to establish a steering committee (issued on 15 April 1999) and
the press notice announcing the membership of the committee (issued
on 26 May 1999) are attached at Annex A and are available via
the FSE web-site www.defra.gov.uk/environment/gm/fse/press
The steering committee first met on 14 June
1999 and has met 11 times since. The minutes of each meeting are
published on the SSC's section of the Defra FSE website www.defra.gov.uk/environment/gm/fse/steering/index.htm.
In addition to formal meetings the SSC has conducted much business
by email correspondence, as a group, as sub-groups and as individuals.
Where this correspondence has led to formal advice, the advice
has been published on the SSC web-site (as above).
The SSC required that the research consortium
submit a progress report every six months, these reports are also
published on the web-site www.defra.gov.uk/environment/gm/fse
2. THE ADEQUACY
OF THE
DESIGN OF
THE FARM-SCALE
EVALUATIONS AND
THEIR ABILITY
TO ANSWER
THE QUESTIONS
POSED AT
THE OUTSET
OF THE
TRIALS
Much of the discussion during the early meetings
of the SSC was concerned with the details of the design of the
farm-scale evaluations and their ability to adequately address
the hypothesis under test. Deliberations continued through the
pilot year of the FSE until the design was finalised before the
start of the first full year of sampling (2000).
At the time of the first SSC meeting (4 June
1999) the hypothesis to be tested had been identified and the
research contractors had been appointed on the basis of their
tender to carry out the farm scale evaluations. Several pilot
fields had been sown using different approaches (both paired fields
and split field designs).
The SSC were charged with assessing what had
been carried out to date and advising on the way forward. We were
given a free hand to direct the ecological studies in the farm-scale
evaluations. Throughout the pilot year (spanning the first four
SSC meetings see www.defra.gov.uk/environment/gm/fse/steering/index.htm
discussions predominantly revolved around:
— The design of the FSE, in particular
whether a split or paired field design should be used. These
two approaches were both tested in the pilot year and the split
field design was eventually adopted (in which one field was divided
in half with the contrasting crop types planted in each half).
— The required sample size of fields.
A large amount of work went into justifying the number of fields
required to adequately address the hypothesis. This work based
on a power analysis resulted in the preferred number being identified
and the work being published in the Journal of Applied Ecology.
— The pattern of selection of fields.
Discussion here revolved around the geographical distribution
of the fields and how different intensities of conventional management
should be represented in order to represent the range of practice
is operation for the comparator crops.
— The treatment of fodder and sugar
beet varieties. It was investigated whether fodder and sugar
beet should be treated as variations on a single crop or as two
crops. Based on preliminary evidence it was agreed that they should
be seen as variation in management of a single crop and so did
not require separate trials.
— The selection of species to be
studied. The research team in their tender for the project
had made a justified case for which species should be monitored
and how this should be done. This was considered in detail by
the SSC and refinements made.
— The design and sample size of
measurements within fields. The SSC reviewed and sought justification
for the adequacy of the within-field sampling protocols of each
of the chosen indicator species.
— The provision and auditing of
pesticide advice. The SSC identified the importance of monitoring
pesticide use on both GM and non-GM crops. The principle of delivering
"cost-effective weed control" was established and protocols
were agreed whereby pesticide use could be monitored and audited
to be certain that it had followed this principle.
These discussions concluded in spring 2000 with
agreement on the farm-scale evaluation design that remained essentially
unchanged until the completion of field trials in 2003.
3. THE CONDUCT
AND OPERATION
OF THE
TRIALS
Once the design and methods of the farm-scale
evaluations had been agreed the role of the SSC became essentially
one of monitoring the conduct of the trials and the preparation
and interpretation of the data. There was active involvement each
year in approving the selection of sites (spring for most crops
or autumn for winter oilseed rape) and in reacting to any unanticipated
incidents.
The SSC sought to hold meetings every six months.
The minutes of all meetings are available on the web-site.
Each spring for maize, beet and spring oilseed
rape, and each autumn for winter oilseed rape, the FSE research
team presented the SSC with their selection of sites for the forthcoming
season. The SSC considered the selection against the criteria
they had established in the pilot year: that of representing the
geographical range and management intensity of the particular
comparator crop in question.
The SSC view on the selection was either minuted,
if it coincided with a scheduled meeting, or separate advice was
published (both minutes and separate advice are available on the
web-site). On some occasions the SSC felt that the selection was
drifting from the ideal and this was conveyed to the research
team and published in the advice. By the completion of the trials
the SSC were content that any earlier unbalance had been redressed.
In addition to site selection issues the SSC
advised on a matter raised in parliament regarding the splitting
of a particular fields at Low Burnham see www.defra.gov.uk/environment/gm/fse/steering/advice/01.htm;
some questions relating to soil differences raised by Lindsey
District Council see www.defra.gov.uk/environment/gm/fse/steering/advice/02.htm;
and, advice on the impact on the ecological studies of unexpected
transformation events in GM oilseed rape sown as part of the FSEs
see www.defra.gov.uk/environment/gm/fse/steering/advice/06.htm
4. ANALYSIS AND
PUBLICATION OF
THE RESULTS
At the first meeting of the SSC it was agreed
that no results would be published until the trials were complete
and the results had been independently peer reviewed by a reputable
scientific journal. This is exactly what happened. The results
of the spring-sown crops were published on 16 October 2003 in
the Philosophical Transaction of the Royal Society. The results
for winter oilseed rape have yet to be published.
The SSC were charged with overseeing the process
by which the FSE results were published. At the 14 June 1999 meeting
the SSC unanimously agreed that "no data, analyses or conclusions
should be made publicly available until accepted for publication
in peer reviewed scientific journals". In practice the process
was in two stages: firstly, the draft results being prepared to
a standard that the SSC were content with, and; secondly, the
work being submitted to the journal and bought to the standards
that they independently set. The SSC were actively involved in
the first stage and monitored the second.
Discussions between the SSC and research team
led to agreement that the results should be divided among a series
of scientific papers and identified which results should go into
which paper. A process of iteration between sub-groups of the
SSC and the authors of the papers drawn from the research team
eventually led to a series of draft papers that the SSC were content
to sign off. In April 2003 these were then submitted to the journal
for peer review and publication. The choice of journal was agreed
between the SSC and research team.
In September 2003 the scientific papers were
accepted for publication and on 16 October 2003 the results for
spring sown crops were published.
The SSC also identified early in the FSE process
the need for a non-specialist summary of the scientific results.
Once the draft papers had been submitted to the journal, the research
team commissioned a writer to draft such a summary, based only
on the scientific work. The SSC were involved at all stages of
drafting and the final draft of the summary was approved by the
scientific steering just prior to publication of the scientific
papers. The summary was made available on the day of launch.
On the day of publication the SSC issued advice
to ministers indicating the completion of the farm-scale evaluations
of maize, beet and spring oilseed rape. A copy of the SSC advice
is attached at Annex B.
Copies of the results, summaries and advice
are available at www.defra.gov.uk/environment/gm/fse.
5. WINTER OILSEED
RAPE
The SSC is still in operation. It will oversee
the publication of the results of the winter oilseed rape trials
before being dissolved.
The final field trials of winter oilseed rape
were harvested in autumn 2003. Since then analysis of samples
and data has been underway by the research team. Shortly the SSC
will be in the process of overseeing the drafting of results and
their submission to a scientific journal, following an identical
protocol to that used for the other three crops.
It is expected that the papers will be submitted
to a journal early in 2004 and, if accepted, published later in
2004. At that time the SSC will advise ministers on the outcome
of the winter oilseed rape trials.
November 2003
Annex A
PRESS RELEASES ANNOUNCING THE INTENTION TO
ESTABLISH THE SSC AND ITS MEMBERSHIP
1. RESEARCH
CONTRACTS TO
STUDY WILDLIFE
AND GM CROPS
ANNOUNCED
15 April 1999
A consortium led by the Natural Environment
Research Council's (NERC) Institute of Terrestrial Ecology has
been awarded three contracts to study the effects on wildlife
of the management of Genetically Modified (GM) crops, Environment
Minister Michael Meacher announced today.
The primary objective of these farmscale evaluations
is to study how the management of GM herbicide tolerant maize,
spring oilseed rape and winter oilseed rape might affect wildlife
compared to the management of their non-GM equivalents.
In answer to a Parliamentary Question from Alan
Simpson (MP), Mr Meacher said the evaluations would compare the
effects of the management of genetically modified crops on farmland
wildlife with the effects of managing conventional crops.
"The evaluations, which will take four years,
will ensure that the managed development of the introduction of
genetically modified crops announced at the House of Lords European
Communities Sub-Committee last October, will take place safely."
"The evaluation programme will help address
the concerns which have been raised by English Nature and the
Royal Society for the Protection of Birds. We need to get reliable
evidence to help us decide whether the management of genetically
modified herbicide tolerant crops could have the potential to
accelerate the decline of farmland wildlife which has taken place
over the last 50 years."
"The research will not only address issues
relating to genetically modified crops. This is an extremely important
opportunity to contribute towards a more detailed understanding
of the effects of agricultural management practices on farmland
wildlife generally," he said.
The cost of the research contracts will be £1.1
million for each crop. Funding comes wholly from the Department
of the Environment, Transport and the Regions (DETR), Ministry
of Agriculture, Fisheries and Food (MAFF) and The Scottish Office.
The industry body SCIMAC (Supply Chain Initiative for Modified
Agricultural Crops), is providing the seed for the crops and helping
to locate suitable farms.
The progress of the research will be monitored
by an independent steering committee of experts which will report
to the Secretary of State. The Steering group is currently being
set up and will include experts from English Nature and the RSPB.
A full text of Mr Meacher's Parliamentary answer
is attached.
Notes to Editors
Two or three sites will be chosen this year
for each crop, each being used to establish the methodology for
monitoring for subsequent years.
The first planting for the farmscale evaluations
took place on 3 April at a site in Wiltshire. A second site, in
Oxfordshire, has been advertised locally. Other sites will be
announced shortly.
Fields will be about 10 hectares in area, a
size which reflects commercial scale agriculture in the UK. In
years 2000 and 2001 20 comparisons between genetically modified
and non-genetically modified crops will be made and studies will
be carried out after harvest of each crop in each year until autumn
2002.
Michael Meacher announced the managed development
of introductions of genetically modified crops at the House of
Lords European Communities Sub-Committee on Agriculture on 21
October 1998.
The farmscale evaluations will include studies
on wildlife in GM herbicide tolerant maize, spring oilseed rape
and winter oilseed rape, and their non-GM equivalent crops. These
crops are the closest to commercialisation.
Fifteen research organisations were invited
to tender for these contracts to carry out the wildlife studies.
The Government also consulted widely on the tender specifications.
The contracts valued at £3,343,596 have been awarded to a
consortium led by the NERC Institute of Terrestrial Ecology and
including the Institute of Arable Crop Research and the Scottish
Crop Research Institute.
Consultations with the scientific community
will continue this year to finalise arrangements for the wider
scale plantings in 2000. To this end, a scientific steering committee
is being set up to advise on the scientific approach to be taken
and the analysis of the results. The committee will have an independent
chairman and include experts from English Nature and the RSPB.
The wildlife studies being carried out in this year's plantings
of two or three fields per crop will help inform these discussions.
The number of fields which will be planted in
years 2000 and 2001 is important. It is considered that comparisons
between 20 sites will be necessary to ensure that the results
gathered will be statistically robust and will allow for the variation
in environmental conditions which are experienced, and the agricultural
management practices which are used throughout the country.
Text of Mr Meacher's answer
The monitoring arrangements for releases of
genetically modified organisms are decided on a case by case basis
for each consent application. This year, some sites will be used
for the farm-scale evaluations which will compare the effects
of the management of genetically modified crops on farmland wildlife
with the effects of managing conventional crops.
The Government has awarded three contracts to
study the effects of the management of GM crops on wildlife to
a consortium led by the Natural Environment Research Council's
(NERC) Institute of Terrestrial Ecology. The consortium also includes
the Institute of Arable Crop Research and the Scottish Crop Research
Institute. Each contract is worth £1.1 million; funding is
provided wholly by my Department, the Ministry of Agriculture,
Fisheries and Food (MAFF) and The Scottish Office.
The evaluations, which will take four years,
will ensure that the managed development of the introduction of
genetically modified crops announced at the House of Lords European
Communities Sub-Committee last October, will take place safely.
They will help address the concerns which have been raised by
English Nature and the Royal Society for the Protection of Birds
about the management of genetically modified herbicide tolerant
crops having the potential to accelerate the decline in farmland
wildlife which have taken place over the last 50 years.
In order to make comparisons between the GM
and non-GM crops, the sites identified for the research in 2000
will be subject to pre-planting sampling and analysis. The research
will look at the effects of the management of GM and non-GM crops
on the soil; for example earthworm population monitoring provides
a good indicator of the structure and fertility of the soil. Above
ground environmental impact will be studied, again by carrying
out surveys of plant populations and invertebrates.
This research will not only address issues relating
to genetically modified crops. This is an extremely important
opportunity to contribute towards a more detailed understanding
of the effects of agricultural management practices on farmland
wildlife generally.
This research will be monitored by an independent
steering committee of experts which is currently being set up
and will report to the Secretary of State; the results will be
made widely available.
Press Notice 410
15 April 1999
2. MEACHER
ANNOUNCES SCIENTIFIC
COMMITTEE TO
OVERSEE GM CROP
EVALUATIONS
25 May 1999
Membership of a new scientific steering committee
to oversee the ecological studies on farm-scale evaluations of
genetically modified crops was announced today by Environment
Minister Michael Meacher.
The Government announced its intention to establish
a steering committee on 14 April. Its members are independent
of the biotechnology industry and the research contractors undertaking
the ecological studies.
The new committee will be headed by Professor
Christopher Pollock, Research Director of the Institute of Environmental
and Grassland Research.
Members of the steering committee are: Professor
Mick Crawley from Imperial College; Dr David Gibbons, Head of
Conservation Science at the Royal Society for the Protection of
Birds; Dr Nick Sotherton, Director of Research for the Game Conservancy
Trust; Dr Nicholas Aebischer, Director of Biometrics at the Game
Conservancy Trust; Mr Rob Kempton, Director of Biomathematics
and Statistics Scotland; and Dr Alistair Burn of English Nature.
Announcing the membership, Michael Meacher said:
"I believe that we have appointed some of
the UK's leading scientists in the field of farmland ecology and
conservation to advise us on the farm-scale evaluations. The establishment
of this steering committee will ensure that managed development
of GM crops in the UK is underpinned by sound science.
"The primary objective of the farm-scale
evaluations is to study how the management of GM herbicide tolerant
maize, spring oilseed rape and winter oilseed rape might affect
wildlife compared to the management of their non-GM equivalents.
"The farm-scale evaluations of GM crops
is extremely important research which will ensure that the managed
development of GM crops will take place safely. I want to ensure
that the research is undertaken rigorously, and so my Department
has set up a scientific steering committee to oversee this research
and to advise on how it should progress over the next four years."
The steering committee will oversee progress
of the research and advise on experimental design, the statistical
analysis for the results obtained, and on any interpretations
of the results which can be made. The research contractors, a
consortium of leading research institutes led by the Institute
of Terrestrial Ecology, have already started work on the farms
where the crops are being grown. They will report on the progress
made at the first meeting of the steering committee on 14 June.
Notes to Editors
Michael Meacher announced the managed development
of introductions of genetically modified crops at the House of
Lords European Communities Sub-Committee on Agriculture on 21
October 1998.
The ecological studies are being carried out
by a consortium of organisations led by the NERC Institute of
Terrestrial Ecology, which also includes the Institute of Arable
Crop Research and the Scottish Crop Research Institute.
This year the farm scale evaluations for spring
oilseed rape has been planted at three locations: Lushill Farm,
Hannington, Highworth, Swindon, Wilts; Model Farm, Shirburn, Watlington,
Oxfordshire; and Advanta Seeds UK Ltd, Boothby Graffoe, Lincolnshire.
The maize has been planted at four locations:
Walnut Tree Farm, Lyng, Norwich, Norfolk; Home Farm, Spitle-in-the-Street,
Glentham, Lincolnshire; Little Park Farm, Mortimer, Reading, Berkshire;
and Rothamsted Farm, Harpenden, Hertfordshire.
Both GM crops have been modified to be herbicide
tolerant; neither is insect resistant, nor contain the Bt gene.
DETR press release (PN 410) about the selection
of the research contractors was issued on 15 April.
Press Notice 507
25 May 1999
Annex B
Scientific Steering Committee for the
GM crop farm-scale evaluations
Final advice to Ministers
16 October 2003
The Scientific Steering Committee was formed
in May 1999 to oversee the ecological studies that are the farm-scale
evaluations. The studies have been conducted by a consortium of
independent contractors made up of the Centre for Ecology and
Hydrology, Rothamsted Research and the Scottish Crop Research
Institute.
The remit of The Scientific Steering Committee
includes advising the Secretary of State for Environment, Food
and Rural Affairs, the Scottish Executive and the Welsh Assembly
on the outcome of the Farm-scale evaluations.
Today eight scientific papers containing the
results of the farm-scale evaluation of spring-sown crops (maize,
beet and spring oilseed rape) have been published in The Philosophical
Transactions of the Royal Society (Biological Sciences). The
publication of these papers, following full peer-review, provides
independent endorsement of the SSC's view that the farm scale
evaluations were designed and executed to a high standard. The
SSC is content that these eight papers collectively have adequately
addressed the null hypothesis under test: that, for each crop,
the effect on the abundance and diversity of wildlife of the management
of the GM crop does not differ from the effect of the management
of the conventional equivalent. The null hypothesis was rejected
in each case.
Growing conventional beet and spring rape was
better for many groups of wildlife than growing GM herbicide-tolerant
(GMHT) beet and spring rape. Some insect groups, such as bees
(in beet crops) and butterflies (in beet and spring rape) , were
recorded more frequently in and around the conventional crops
because there were more weeds to provide food and cover. There
were also more weed seeds in conventional beet and spring rape
crops than in their GM counterparts. Such seeds are important
in the diets of some animals, particularly some birds. However
some groups of soil insects were found in greater numbers in GMHT
beet and spring rape crops.
In contrast, growing GMHT maize was better for
many groups of wildlife than conventional maize. There were more
weeds in and around the GMHT maize crops, more butterflies and
bees around at certain times of the year, and more weed seeds.
It is not the remit of the Scientific Steering
Committee to comment on the regulatory significance of these findings.
However the results will be passed to The Advisory Committee on
Releases to the Environment (ACRE) and both the SSC and the research
team will willingly assist ACRE in their deliberations if required.
The data from the winter oilseed rape trials
are being collated now. Data analysis and report writing will
begin shortly. It is intended the results will be published in
mid-2004 at which time the SSC will advise on the outcome.
All data collected in the farm scale evaluations
will be made available for further research purposes or for public
inspection. Details of how access will be managed will be published
shortly.
The SSC would like to congratulate the research
consortium on the successful completion of this work.
Signed:
Professor Christopher Pollock (Chairman), IGER
Dr Nicholas Aebischer, Game Conservancy Trust
Dr Alastair Burn, English Nature
Professor Mick Crawley, Imperial College
Dr David Gibbons, RSPB
Mr Jim Orson, Morley Research Centre
Dr Nick Sotherton, Game Conservancy Trust
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