APPENDIX 4
Memorandum from CropGen[5]
CROPGEN
A consumer and media information initiative,
CropGen's mission is to make the case for GM crops by helping
to achieve a greater measure of realism and better balance in
the UK public debate about crop biotechnology.
CropGen consists of an independent panel of
scientists, farmers and a consumer specialist who recognise that
crop biotechnology offers many potential benefits. The members
of the panel, all experts in their fields and many of whom are
involved in active research at public research institutions address
the key issues relating to GM crops.
QUESTIONS FROM
THE ENVIRONMENTAL
AUDIT COMMITTEE
1. The adequacy of the design of the FSEs
and their ability to answer the questions asked
The FSEs were set up to answer the question
posed by English Nature—would the use of herbicide tolerant
crops have a negative impact on the ecosystem (diversity). This
was rephrased by the FSE team to provide a null hypothesis to
test: that there was no difference in effect between the two treatments
(weed management in GM herbicide tolerant crops vs. conventional
weed management (in a non-GM variety of the same crop)).
It is clear from the report that the power analysis
used achieved the targeted level of precision, picking up 80%
of 1.5-fold differences. The results showed that there were differences
between the herbicide tolerant (GM) and non herbicide tolerant
(conventional) sides of the split fields, in the responses of
the plants and the invertebrates to the treatments. It has met
its objective, as it has provided statistically supported data
on the relative levels of the assessed species on each half of
the field.
The research consortium' primary aim was to
demonstrate whether there were or were not differences in the
levels of plants and invertebrates between the two treatments.
Conclusions are still needed on the ecological and agronomic consequences
of these differences and it was not the primary role of the project
to assess their potential impact on a national scale. Although
the research consortium has endeavoured to begin to explore these
issues, further predictive modeling work is needed.
It should be emphasized that the trials show
how different methods of weed management impact on wider ecology.
They do not address the impact of GM crops per se. They do however
open up a huge question, now that there are some baseline data,
on what is the ecological impact of agriculture. The three spring
crops tested are relatively minor (6% of arable crops in total)
and so ecological impacts of different levels of weed management
in them will not be major on a national scale. BUT they provide
a scenario to ask the question about the ecological impact of
more major crops. Thus the results of Winter Oilseed Rape anticipated
in 2004 will be of much greater importance, as this crop is the
commonest crop after cereals.
2. The conduct of the trials
This has been exemplary. Only 5% of the data
was lost, despite the `attentions' of those opposing the work.
The staff had to work under considerable pressure both whilst
collecting the data and writing the reports. They are to be congratulated
for doing such a fine job. The data set is the most extensive
on the ecological effects of agriculture ever collected, and is
several fold more detailed than anything done previously anywhere
in the world.
3. Integration with policy and decision making
The FSEs provide information on the relative
effects of conventional and herbicide tolerant (GM) crop management
on diversity. The results can be used to contribute to the decisions
on the commercialisation of GM crops but they must be put in context.
(a)
It is clear, as pointed out in the reports, that
the type of crop grown often had a greater effect on diversity
than treatments within crops. Thus herbicide tolerant oilseed
rape has more diversity than conventional beet.
(b)
The comparisons in the analyses presented to date
are relative and thus a highly significant difference may simply
be comparing two levels of very low species incidence. Thus the
results need to be put in context.
4. Implications of the results for government
To my mind the major outcome of the FSEs is
not the relative comparison of two ways of controlling weeds,
but is the provision of baseline data on how the whole of arable
agriculture affects diversity. The methodologies could be reused
(in a more restricted way—defined by analysis of the FSEs
data) to explore how other crop production practices affect diversity
(eg growing wheat, using a new pesticide). The database from these
trials can now also be used to look at the level of research needed
to generate adequate information on the environmental impact of
new GM (and non GM) traits. A targeted approach based on the FSEs
would reduce the level of resources needed to achieve this aim.
5. Costs and benefits of GM crops
The FSEs say very little about the costs and
benefits of GM crops, though the information presented could be
used to assess the financial implications of the two contrasting
methods of weed control. An overall cost/benefit analysis is not
possible because crop yields were not assessed. However, economic
evaluation of weed control in conventional and herbicide tolerant
sugar beet has already been done, outside the framework of the
FSE trials. Even on the simple economic comparisons of the cost
of weed control, the FSEs can only ever provide an economic "snapshot"
and changes in the availability and price of different herbicides
will change the relative costs and benefits.
The trials say nothing about co-existence of
GM crops or the health aspects of GM foods.
November 2003
5 By Peter Lutman, Rothamsted Research, Rothamsted. Back
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