Conclusions and recommendations
1.
The benchmark against which GMHT crops were measured was not
ambitious, since biodiversity in conventional crops has suffered
greatly over the last half-century. (Paragraph 6)
2. We commend ACRE
for the speed with which it conducted its work. (Paragraph 9)
3. The advice from
ACRE is clear but it is not decisive. We acknowledge that in
its limited scope and contingent nature, the ACRE advice accurately
reflects the trials themselves. (Paragraph 11)
4. It is regrettable
that the Government failed to be transparent about the nature
of any deal made with the industry over the inclusion of beet.
Given the public's concern and suspicion on matters relating to
the GM industry we would expect greater openness. (Paragraph
25)
5. The problems evident
in north America have not been taken seriously enough. DEFRA
should have advised the SSC to take account of north American
experiences with GM. (Paragraph 31)
6. we are unhappy
that this work has been left until after most of the FSEs have
reported. Consequently, the findings from that trans-Atlantic
research have not now been factored in to the decisions that are
already being reached on those GMHT crops in the UK nearest approval.
This is clearly unsatisfactory. No decision to proceed with
the commercial growing of GM crops should be made until thorough
research into the experience with GM crops in north America has
been completed and published. (Paragraph 31)
7. We do not feel
that the choice of fields in regard to intensity had any effect
upon the results, except insofar as it possibly allowed them to
be expressed more clearly:. (Paragraph 35)
8. The north American
experience with oilseed rape and the devastation of organic rape
production should serve as an impetus to Government to bring in
prudent guidelines for separation distances as quickly as possible.
(Paragraph 37)
9. We are very concerned
about possible contamination by gene-flow and pollen spread of
non-GM crops and insist that the issue of liability be settled
before any GM crops are allowed to be commercially grown in the
UK. The Government should ensure, through primary legislation,
if necessary, that it puts into place, before any GM crops may
be grown commercially in this country, a clear and comprehensive
liability regime to underpin any future regulations dealing with
co-existence issues. Moreover, liability should lie with the
industry and not with farmers. It would be wrong for the Government
to allow farmers to be used as a firewall for the industry. (Paragraph
38)
10. We consider it
unfortunate that, as there was no definite yield component to
the results of the FSEs, rumours and assertions have been allowed
to proliferate concerning how the crops performed. (Paragraph
41)
11. We expect future
trials to incorporate robust protocols for formal measurements
of yield. (Paragraph 41)
12. These factors,
combined with the careful oversight of the trials by the consortium
and the SSC, make us reasonably confident that there was no clear
manipulation of the herbicide regime on GMHT crops in order to
favour their biodiversity. (Paragraph 43)
13. In the context
of public concern about GM crops and the north American experience
with GM, we believe that in order to determine the cumulative
effect of rotational crops upon biodiversity, the FSEs for those
crops should have lasted longer than three years. The trials
on forage maize should also have lasted longer. We believe that
the Government must take account of this in any future trials
(Paragraph 46)
14. We are concerned
that the GMHT forage maize trials were based on an unsatisfactory,
indeed invalid, comparison. It is vital that the Government permit
no commercial planting of GMHT forage maize until that crop is
thoroughly re-trialled against a non-GM equivalent grown without
the use of atrazine. (Paragraph 50)
15. It is clearly
unsatisfactory that no definite statement has yet been made as
to what the results were from the 25% of conventional forage maize
fields in which atrazine was not used and whether or not this
sample constitutes a large enough base from which to extrapolate
comparable results for non atrazine conventional maize against
GMHT maize. (Paragraph 51)
16. We support the
lawful right to protest but feel that future trials should be
better protected in order to safeguard scientific evidence that
may prove very valuable in domestic and international discussions
as to whether the commercial growing of GM crops should proceed.
DEFRA must consult with appropriate security bodies about achieving
more secure trial sites in future. (Paragraph 57)
17. we are concerned
that the industry was responsible for a number of key inputs into
the operation of the trials which appear to have been assessed
only against very broad or vague criteria, or which were taken
on trust. Even if these inputs had no cumulative effect upon
the results of the trials, they were sufficiently integral to
raise significant concerns as to the extent to which the industry
was in practice capable of influencing the results. (Paragraph
62)
18. it is inconceivable
that beet or spring-sown oilseed rape will be given consents to
be grown if managed under the same regime as applied in the FSEs.
(Paragraph 63)
19. It is vital that
the Government makes clear in its decision exactly what will be
required of applicants in future, and how it will assess whether
there is evidence of biodiversity harm from the use of the GM
crop and herbicide regime for which the particular application
is made. (Paragraph 65)
20. We agree that
the industry should pay for any future trials including the future
trials we think necessary for forage maize. (Paragraph 65)
21. We recommend that
future GM crop assessments of biodiversity impact should be no
shorter than four years . (Paragraph 67)
22. We agree and expect
to see thorough multi-year and multi-site trials for any new applications.
We likewise expect comparative assessment of biodiversity harm
to be undertaken on a crop by crop basis. (Paragraph 68)
23. biodiversity
levels have slipped intolerably over the last fifty years and
Government has a duty to attempt to regain some of that lost ground.
Indeed, the Government, in the light of the Curry Report, should
establish a benchmark for biodiversity in conventional crops,
at the less intensive end of the spectrum. It is against this
benchmark that future trials should assess innovatory practices
and regimes in conventional agriculture. This ought to make the
benchmark used in the FSEs irrelevant. (Paragraph 72)
24. While we applaud
the steps that Government has taken to assess biodiversity in
a rational way before permitting an agricultural innovation in
the form of GM, we believe that even if some GM crops with some
associated herbicide regimes are eventually shown to be less harmful
to biodiversity than their conventional counterparts, the Government
and its advisory bodies are still guilty of setting too low the
level of harm (Paragraph 73)
25. We therefore
recommend that in future trials the biodiversity benchmark against
which GM crops should be assessed should be that associated with
the less intensive and more biodiversity-friendly end of the
spectrum found in UK agriculture, such as organic crops.
(Paragraph 73)
26. The scope of the
trials was very narrow and the results cannot be regarded as adequate
grounds for a decision to be taken in favour of commercialisation.
(Paragraph 74)
27. it would be irresponsible
for the Government to permit the commercialisation of GM crops
on the basis of one narrow component of the entire evaluation
of GM technology. This would be the case even were there no
significant doubts as to the robustness, validity and relevance
of the FSE results. (Paragraph 75)
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