Government response
Introduction
The Government welcomes this opportunity to respond
to the Environment, Food and Rural Affairs Select Committee's
conclusions and recommendations regarding the conduct of the GM
public debate.
In May 2002 the Government accepted a recommendation
by the Agriculture and Environment Biotechnology Commission (AEBC)
to hold a public debate on GM. The debate was jointly sponsored
and co-funded by Defra and the Devolved Administrations in Scotland,
Wales and Northern Ireland, with additional funding from DTI.
An independent Steering Board (PDSB) was set up to carry out the
further work that was then needed to design and deliver the debate
programme. The main debate activities were finally held during
June and July 2003, and the Steering Board submitted its report
to Government in September. The debate was one strand of a wider
'GM Dialogue', which also included a science review and a study
of the costs and benefits of GM crops.
Overall we believe that the public debate was a qualified
success, and we do not share the Committee's view that it was
'an opportunity missed'. Nor do we accept that its successes were
outweighed by its shortcomings. The debate was an innovative attempt
to engage the public in a complex policy issue. It was not instigated
by Government, nor did government see it—as has been alleged—as
an attempt to change public opinion. Its aim was to get a clear
indication of the range of people's views on GM, though it clearly
had a role in informing and raising awareness. Thousands of people
participated by attending public meetings, visiting the website
and sending letters and emails. By any standards that is a remarkable
achievement.
Nevertheless we acknowledge the importance of identifying
any lessons learned from the debate process to help inform any
future exercises in public engagement, whether these are conducted
by Defra, other Government Departments or other organisations.
We have set out below our response to the Committee's specific
conclusions and recommendations. Our response to the public debate
will be published shortly, and will explain how the debate has
informed the policy-making process.
Recommendation 1
Underpinning the public debate was
the laudable aim of engaging the public in policy-making about
a controversial issue. Launching the public debate was imaginative
and innovative. Many people did engage with the debate, and, even
if the views of a large proportion were unshakeable, giving them
the opportunity to air their opinions in a formal setting was
worthwhile. Any criticism that we make elsewhere in this report
of the conduct of the debate must be seen in that context. (Paragraph
10)
We welcome and share the Committee's conclusion that
the public debate was worthwhile. The debate was a genuinely innovative
activity, and Government took a number of risks, including by
appointing an independent Steering Board to manage the process.
The Steering Board's report concludes that the debate was a qualified
success and that it was clearly welcomed and valued by the public.
Nevertheless it was a learning process for all involved—Government,
the Steering Board and the Central Office of Information (COI).
Recommendation 2
The work conducted in the 'narrow-but-deep'
groups was valuable, and its outcomes very interesting. We commend
the PDSB for commissioning the groups. Any criticism that we make
of the debate in this report does not extend to the 'narrow-but-deep'
work. (Paragraph 12)
We agree that the 'narrow-but-deep' groups
were an important part of the debate process, and served as an
important 'control' on the open debate process. We will comment
further on the differences between the views of the 'narrow but
deep' element and the 'self-selecting' participants in our separate
response to the public debate report.
Recommendations 3 and 5
It is not clear why the Government
did not accede to the AEBC's original timetable for the debate
or why, once it became clear that the science and economic reviews
and the FSE results would not be available to inform the debate,
it did not set a later deadline for the PDSB's report. (Paragraph
15)
The fact that the debate was not informed
by the outcomes of the economic and scientific reviews, nor by
the results of the FSEs, is highly regrettable. Without this information
- some of which was commissioned specifically to inform the debate
- the likelihood that the wider 'public' would be informed about
GM as a result of the debate was much reduced. We recommend that
the Government now explain why the deadline for the debate was
such that the two reviews and the FSEs could not be used to inform
the process, and why, once it became clear that the debate would
end too soon, the Government did not ask the PDSB to extend it.
(Paragraph 28)
The GM public debate was announced in May 2002. It
was envisaged that the Steering Board would submit their report
to Government in June 2003. It was already known that there was
no question of the full set of peer-reviewed farm scale evaluation
(FSE) results being available before the autumn at the earliest.
Indeed the final results are not yet available.
The Government's view has always been
that the FSE results, while important in themselves, were not
central to the public debate. The reason for this is that the
FSEs were looking at a single narrow question (i.e. whether the
management of GM herbicide-tolerant crops would have an adverse
effect on farmland biodiversity), whereas the public debate was
not intended to focus exclusively on GM crops. The Government
wanted to give the public the opportunity to debate the broader
questions and concerns that they have about GM. Indeed the report
of the public debate has helped to put the FSE results into context,
as it is clear that people's concerns about GM crops are driven
by a complex range of issues. It is also important to bear in
mind that the FSEs were effectively looking at the effects of
herbicide use, and therefore are only directly relevant to the
assessment specifically of the environmental impact of GM herbicide-tolerant
crops.
Our intention was always that the science review
and the costs and benefits study, the other two of the three strands,
would proceed in parallel with the public debate, and that
they would report at around the same time. It was envisaged that
there would be interaction between the three strands, though in
practice there was not as much as we had hoped. The Foundation
Workshops commissioned by the public debate Steering Board helped
to frame the issues for all three strands of the GM dialogue.
The Strategy Unit and Science Review also adopted an open and
transparent approach to their work, inviting comments via their
websites and, in the case of the Science Review, by holding open
meetings.
The AEBC recommended that there should be a public
debate before decisions had to be taken on the possible commercialisation
of GM crops. Decisions to approve GM crops for cultivation are
taken collectively by EU member states. There is clearly scope
for the Government to influence EU decisions, but we do not control
the timetable for EU decision-making. Early in 2003 the
European Commission was signalling that the EU approvals process
could restart as early as October.
The Government therefore anticipated that we might
need to take a view on whether specific crops should be approved
for commercial cultivation as early as October 2003. In line with
the AEBC's advice, we wanted to ensure that we were in a position
to make informed decisions—and that meant having at our
disposal not only the findings of the public debate, but also
those of the science and economic strands, and the FSE
results. If we had further extended the deadline for the Steering
Board's report, then decisions to approve GM crops for commercial
cultivation could have been scheduled at EU level before we had
had chance to consider the findings of all three strands of the
public dialogue. This would clearly have been unacceptable. Our
view remains that the decisions we took on timing were appropriate.
Recommendation 4
Whether or not the performance of the
COI significantly affected the conduct of the debate, given the
criticism surrounding its appointment it is unfortunate that the
PDSB was not able to at least consider other contractors. The
fact that it was not able to do so is the direct result of the
constraints placed on the PDSB by Government - principally, in
this case, the deadline set for completion of the debate. Those
constraints meant that the PDSB was perhaps not able to appoint
the best contractor, and the perceived independence of the debate
was jeopardised. (Paragraph 26)
We have explained above the time constraints which
affected the timetable for the debate. The Steering Board decided
that appointing COI as their prime contractor would enable them
to proceed more quickly. However, we do accept that if more time
had been available, it might have been preferable to invite other
companies or consortia to bid for the work.
We do not accept that the appointment
of COI jeopardized the perceived independence of the debate. It
is generally accepted that the debate was indeed run independently
of Government and that the involvement of COI did not compromise
the Steering Board's independence in any way.
Recommendations 6 and 7
Whether or not the 'public' in general
would have become involved in the debate, the inevitable consequence
of insufficient resources being available to publicise and promote
it was that it did not engage the wider population. It would have
been helpful if there had been an opportunity to employ a range
of techniques to encourage public participation. Moreover, time
was an important factor: with more time a greater amount of work
could have been done to reach out more widely. It is profoundly
regrettable that the open part of the process, far from being
a 'public debate', instead became a dialogue mainly restricted
to people of a particular social and academic background. The
greatest failure of the debate is that it did not engage with
a wider array of people. (Paragraph 31)
To engage with the wider public, the
debate needed to go into their living rooms, rather than be conducted
in the village hall. With sufficient time and money to publicise
and promote the debate, we have little doubt that it would have
been possible to do so. (Paragraph 32)
We agree with the Committee's view that
it is necessary to employ a range of techniques in order to encourage
greater public participation. Government and the Steering Board
had a shared aim of securing the broadest possible participation
in the debate, particularly at 'grass roots' level. The Steering
Board's chosen approach—organising a series of launch events,
and encouraging people to organise their own meetings at local
level—has much to recommend it. Its success was limited
mainly by the lack of advance publicity and the six-week timeframe,
both of which resulted from delays earlier on in the process.
It is perhaps inevitable that people who
had an existing interest in GM were more likely to attend the
large public meetings. However, this is probably less true of
some of the meetings organised at local level by organisations
with no prior or particular interest in GM issues. Nevertheless
people who choose to take part in a debate of this sort are by
definition 'self-selecting', and are therefore more likely to
already be engaged with the issue than the general population.
To some extent this may be difficult to overcome, though more
publicity would undoubtedly have enabled the debate to reach more
people. In particular a tie-in with a TV programme could have
been a very effective way of engaging people, and although the
Steering Board discussed this idea it appears that it was not
pursued early enough. One of the key lessons from the debate is
that it is important to have an effective communications strategy
in order to maximise opportunities for publicity through a range
of media channels.
Recommendation 8
We endorse the view that it is critically
important that the holding of the debate is seen to have an influence
on the decisions subsequently made by Government. We recommend
that in its response to the report of the public debate (and to
this report) the Government set out exactly how it will take into
account the outcomes of the debate in its decision-making about
GM technology. In particular, it should set out precisely the
legal framework under which decisions about GM will be taken.
(Paragraph 36)
The Government has to operate within the existing
EU legal framework, which in turn must be consistent with WTO
rules. In this regard the key piece of legislation is the new
and strengthened EC Directive 2001/18 on the deliberate release
of genetically modified organisms (GMOs) into the environment,
which requires case-by-case decisions following a comprehensive
assessment of any potential risks to human health and the environment,
on the basis of the scientific evidence. The requirements of Directive
2001/18 are also reflected in various other pieces of EU legislation
governing the approval of medicines, veterinary medicines, plant
protection products and, from April 2004, food and animal feed.
We will provide a fuller explanation of how the EU regulatory
system works in our response to the public debate.
The public debate will nevertheless help to inform
the stance we take in future discussions with our EU partners
about our regulatory role in relation to GMOs.
Recommendation 9
We would value an explanation from
the Food Standards Agency of its decision to undertake a 'pubic
debate' of its own about GM food, why it chose to do so at the
time that it did, what was the cost to public funds of its initiative,
and how its work relates to the other strands of the public debate.
We would also be keen to learn of future plans for the Agency
to study public opinion about GM food. (Paragraph 38)
The Food Standards Agency will be responding
separately on this point. However we believe that the FSA's activities
were a useful contribution to the wider public debate.
Recommendations 10 and 11
The public debate was an imaginative
initiative, but nonetheless represents an opportunity missed.
Although other reasons for its failure can be found, including,
no doubt, a degree of public apathy, two principal problems resulted
from Government decisions: the tight deadline set for completion
of the process, which meant that relevant data (the reports from
the Strategy Unit and GM Science Review Panel, and the outcome
of the FSEs) was not available, and the paltry resources allocated
to the debate. The Government, in its response to our report,
must allay the suspicion that, having agreed to undertake a public
debate, it did as little as it could to make it work. (Paragraph
41)
We trust that the Government will look
seriously at the lessons to be learned from the conduct of the
GM public debate. As we have made clear in this report, the main
lesson is that wide-ranging consultative exercises such as the
GM public debate must be adequately resourced and must be given
enough time to be conducted properly. (Paragraph 42)
While we acknowledge that with hindsight the initial
level of funding allocated to the debate was too low, it was
based on an estimate by COI of the funds needed to implement
the programme outlined by the AEBC. When a strong case was made
that it was inadequate the funding was doubled. It is doubtful
the Government could then have agreed to the debate for which
Defra had not been funded had substantially greater resources
been known to be required. We do not in fact accept that the final
budget was insufficient. Some of the available money could have
been spent more wisely, and it is questionable whether spending
significant other sums on publicity would have represented good
value for taxpayers' money. GM Nation? succeeded in generating
considerable media coverage, and with more time and thorough planning
it should be possible to achieve even greater levels of publicity
with similar resources.
As indicated above, we continue to believe that the
deadlines we set for the public debate were appropriate, bearing
in mind the need to ensure that we were able to consider its findings
before decisions were taken at EU level on the possible commercialisation
of GM crops. We do however accept that in the absence of external
time constraints it would be preferable to allow a greater planning
period for similar activities in future.
Department for Environment, Food and Rural Affairs
March 2004
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