APPENDIX 10
Letter to the Clerk of the Committee from
Swindon Friends of the Earth
Members of Swindon Friends of the Earth have
observed the following crops grown as part of the farmscale trials:
three Spring oil seed rape trials, one in Wiltshire
(subsequently destroyed by farmer) and two in Oxfordshire;
three winter oil seed rape at Hinton Waldrist,
Oxfordshire; and
two forage maize trials at Hinton Waldrist, Oxfordshire.
We draw the Environmental Audit Committee's
attention to the Friends of the Earth critique of the farmscale
trials that can be accessed at www.foe.co.uk/resource/reports/science_smokescreen.pdf[9]
that covers many of the questions posed.
1. THE ADEQUACY
OF THE
DESIGN ON
THE FARM
SCALE TRIALS
AND THEIR
ABILITY TO
ANSWER THE
QUESTIONS POSED
AT THE
OUTSET OF
THE TRIALS
The main failing in the design of the trial
was a failure to measure the yield of the crops and to assess
how this related to biodiversity.
Whilst studies have shown that the "weediness"
of a crop does not have a major impact on yield losses in the
mid to late stages of crop growth, competition from weeds in the
early stages of establishment of the crop can have a marked impact
with major losses reported. This is particularly the case of crops
like maize and beet where much bare tilled land is left between
the rows of crop.
Swindon Friends of the Earth has been criticising
the design of the farmscale trials since the protocols were first
discussed on the grounds that the crops might not be managed to
commercial standards but managed to maximise weed growth in the
GM half or minimising it in the conventional crop. In view of
the fact that GM crops have not been grown commercially in the
UK, it seemed only appropriate to measure comparative yields of
the two halves in order to detect bias. In order to appease our
concerns, we were lead to assume that a rough estimate of yield
would be provided by the farmer. We were assured that National
List (NL) trials looked closely at such matters as yield and quality
of the relevant crop. However NL trials are performed in weed-free
growing conditions whilst GMHT varieties are not grown with the
linked herbicide. We were disappointed to learn (page 1816 of
the report) that farmers' estimates of yield were gathered where
available but in many cases these were not adequate for analysis.
The scientists conclude that "it is unlikely that yields
were reduced by the timings of GMHT herbicide application used
in this study." Nonetheless, we recognise that weed control
plays an important part in crop management and this applies to
organically produced crops too. Whilst the timing of application
of the post-emergence herbicide is one factor, the quantity of
active ingredient in the spray is another. There is a balance
to be met between an acceptable level of weeds in a crop that,
for example, an organic farmer might find acceptable to one where
the crop is grown to maximise yield but where wildlife suffers
a decline (as in the NL trials).
As such, if reasonable yields can be achieved
in a GMHT crop and management of the cropped area also provides
a reasonable habitat for farmland wildlife that reverses the decline
in farmland biodiversity (as achieved in organic farming) then
this might indicate a positive benefit of growing GMHT varieties.
However without access to any data on yield, this important consideration
cannot be factored into the equation. It would seem prudent to
examine yield data where it has been collected in order to see
whether, for example, only favourable yields have been recorded
for GMHT maize but where biodiversity assessments were statistically
lower than the average—Figure 2b page 1807 clearly indicates
maize trials where weed control in the GMHT maize was greater
or equal to that achieved in conventionally grown maize.
2. THE CONDUCT
AND OPERATION
OF THE
TRIALS
Doubts about GMHT maize and other research required
With regard to GMHT "Liberty Link"
maize, the results of the farmscale trials show that conventional
maize management, that involved atrazine control of weeds on all
but four of the trial sites, was more harmful to wildlife. 100%
of commercial fodder maize (excluding organic varieties) fields
are sprayed with atrazine but its use on fodder maize is soon
to be phased out. It is unusual in farming to have one herbicide
that so dominates market use. Whilst other herbicides used on
crops may come and go, the role of atrazine in maize management
is unprecedented and requires special consideration in this study.
Whilst the results from the four maize trial sites (where atrazine
alternatives were sprayed) would not be statistically significant,
it would be useful to assess and compare the results in order
to see if the impact on farmland ecology is the same, worse or
better than those treated with atrazine before making any decisions.
In addition, we assume that data has been collected
that compares farmland biodiversity in organically managed maize
crops compared to conventionally treated crops. This might give
an indication of the potential to grow fodder maize with atrazine
alternatives and to assess how this might compare with the results
of the farmscale evaluations for maize.
3. THE WAYS
IN WHICH
THE RESULTS
OF THE
FARM SCALE
TRIALS WILL
BE INTEGRATED
WITH POLICY
AND DECISION-MAKING
DETR (now DEFRA) Biotechnology Safety Unit (and
the Scottish Executive) produced a report dated August 2000 that
was published on their web site on 20 February 2001. The paper
was entitled "Farm-Scale Evaluations: Background Papers on
the Evaluations—The Science of the Farm-Scale Evaluations".
Paragraph 5 states:
"if GMHT herbicide management does exacerbate
the adverse effects of conventional agriculture, the FSE results
will provide the evidence needed to modify or delay EU directives
covering the commercialisation of GMHT crops until risk associated
with the management of these crops has been fully assessed. The
FSE are probably one of, if not, the largest ecological investigation
of their type in the world and will provide invaluable information
about the indirect effects of non-GM conventional farming as well
as those of new GM technology."
The adverse findings related to the management
of glyphosate tolerant beet and glufosinate ammonium tolerant
spring sown oil seed rape now provide the evidence needed to initiate
a ban or restriction on cultivation should the GMOs receive an
EU Part C marketing consent.
4. THE IMPLICATIONS
OF THE
TRIAL RESULTS
FOR GOVERNMENT
AND OTHER
DECISION-MAKERS;
AND
On a case-by-case basis, we suggest that there
are now grounds to impose Article 23 of the deliberate release
of GMOs DIRECTIVE 2001/18/EC on GMHT beet and spring-sown oil
seed rape should a Part C consent be provided.
This safeguard clause states: "Where a
Member State, as a result of new or additional information made
available since the date of the consent and affecting the environmental
risk assessment or reassessment of existing information on the
basis of new or additional scientific knowledge, has detailed
grounds for considering that a GMO as or in a product which has
been properly notified and has received written consent under
this Directive constitutes a risk to human health or the environment,
that Member State may provisionally restrict or prohibit the use
and/or sale of that GMO as or in a product on its territory."
Moreover the UK government should submit the
results of the farmscale trials to inform EU Member States in
the decision making process to market these GMOs.
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
We are informed (GM Nation? The Public Debate
booklet on GM crops/food in section on Environmental Impact, Q.4
"What about UK science ?": views "for")
that biotechnology companies employ almost 20,000 people in the
UK, and contribute approximately £2 billion to the British
economy" We are told (same reference) that not allowing commercial
growing of GM crops will force GM companies abroad. This is echoed
in the Strategy Unit report ("There would be a significant
opportunity cost if the UK lost its ability to research, develop
and bring GM crops to market.")
What we are not told is that there are only
1,145 people employed in the UK agricultural biotech sector (DTI
figures*). This figure presumably includes people working outside
transgenic biotechnology such as those working in marker assisted
breeding or radiation induced mutation techniques. There may well
be another 19,000 people working in biotechnology such as medical
applications.
(* from Written Answers to Parliamentary Questions,
House of Commons, Hansard, 11 September 2003)
http://www.publications.parliament.uk/pa/cm200203/cmhansrd/cm030911/text/309
11w05.htm£30911w05.htmlsbhd7
TRADE AND INDUSTRY
Biotechnology Industry
Mr Roger Williams: To ask the Secretary
of State for Trade and Industry what estimate she has made of
the change in (a) turnover and (b) employment in the UK biotechnology
industry within the duration of the farm-scale trials programme.
[128699]
Jacqui Smith: In the agricultural biotechnology
sector, the following statistics are available:
| December | Revenue (£ million)
| Employees |
| 2000 | 160 | 1,147
|
| 2001 | 198 | 1,145
|
Note:
No other figures are available for earlier years.
|
October 2003
|
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9
Science as a Smokescreen, written by Emily Diamand, published
by Friends of the Earth, March 2003. Back
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