Supplementary memorandum submitted by
the Agricultural Biotechnology Council (abc)
GM GOVERNMENT DECISION
1. In addition to our oral evidence session
of 17 May 2004 there were a few matters on which the committee
had requested we provide further evidence and one or two areas
that we felt supplementary data was required to clarify points
we had made. In this regard please find abc's supplementary evidence
below.
REGARDING ADVENTITIOUS
PRESENCE
2. As mentioned by Dr Colin Merritt, abc
feel that the current legal threshold of 0.9% for adventitious
presence of GM will prove workable in most situations, based on
scientific evidence, and observed adventitious presence levels
seen around. Additionally, the SCIMAC code adhered to during the
FSEs ensured that adventitious presence was not a problem during
the FSEs, and a similar code will prove equally effective once
GM crops are commercial in the UK.
3. We would also reiterate that this threshold
is about choice and not about safety. Some sectors of the industry
have hijacked this threshold and seek to exploit it or a self-imposed
"lower level" predominantly for marketing reasons not
supported by science.
4. Dr Merritt referred to a report by the
Union of Concerned Scientists that indicates that even in the
USA, where levels of GM crops are considerable and activity to
avoid adventitious presence is less robust that what is proposed
for the UK levels of adventitious presence are zero in many cases
and generally well below EU thresholds on those occasions when
adventitious level can be detected.
5. To substantiate this data we submit the
following data available at http://www.ucsusa.org/food_and_environment/biotechnology/page.cfm?pageID=1315
Table 2-2 shows the results from various tests
done by Genescan, one of the most experienced GM testing companies,
where they looked for adventitious presence of GM seeds in non-GM
seed in the USA. It indicates that 50% of non-GM maize samples
tested were GM-free and that the 50% that showed a GM level were
less than 0.1%. Similarly the soybean tests indicated 50% of samples
to be GM-free while the remaining 50% were below 0.05%, almost
20 fold below the legal threshold imposed by the EU.
6. However, as we pointed out there are
discrepancies, with other tests within the report, that show slightly
higher levels, further emphasising the essential need for standardised
methods of GM detection. Luckily the EU has anticipated this concern
and developed a ring of labs under the Joint Research Council
that will be responsible for providing standardised testing for
levels of GM presence within the EU.
REGARDING ACCEPTANCE
OF GM AMONGST
UK FARMERS
7. The National Farm Research Unit has been
surveying farmers regarding their attitudes toward growing GM
crops in the UK every moth since October 2000. While naturally
there has been a little variation in attitudes in any given month,
often reflecting the news of the moment, the accumulated figures
from over 22,000 farmer responses spanning four years indicate;
— 45% of UK farmers are unequivocally
in favor of growing GM crops in the UK;
— 21% are in favor of growing GM crops
but have some understandable qualifications such as waiting for
more market acceptance;
8. It is interesting to note that while
figures naturally fluctuate the percentage of farmers opposed
to growing GM crops in the UK has never risen beyond 13% and when
considering the emotion this debate has raised on occasion, such
a low figure of opposition really becomes an overwhelming endorsement.
The full results of these surveys including
the latest figures can be found at
http://www.monsanto.co.uk
REGARDING THE
WIDER ECONOMIC
IMPACT OF
GM CROPS AND
THEREFORE LOSS
(OPPORTUNITY COST)
IF NOT
ALLOWED IN
THE UK MARKET
9. While the committee was aware of the
Strategy Unit broad findings that recognised that, although economic
benefits to the UK are likely to be limited in the short term,
this was largely due to the relatively minor status in the UK
of the crops currently being considered and would increase considerably
once traits and crops more specifically suited for the UK were
available. It is worth noting the "limitation" of benefit
they identified was due to potential lack of market and public
perception, not that the intrinsic economic benefit of the crop
was low.
10. The Strategy Unit recognized that the
current GM crops being considered for the UK would contribute
£50 million per annum to the UK as a whole. This represents
a critical and significant financial benefit to individuals and
groups of farmers at a time when rural incomes have been at a
historical low and provide the supporting data for their conclusion
that existing GM crops offer "cost and convenience advantages"
to UK farmers.
11. In other world areas the economic impact
is truly vast, but this is not surprising. Currently 8 million
businessmen and women (who happen to be farmers) have voluntarily
decide to adopt GM crops and grow them on a collective area of
67.7 million hectares in 2003 representing a 15% increase on 2002,
with a similar increase expected in 2004. abc believe that 8 million
people voluntarily choosing this technology is the most graphic
evidence that this technology offers those individuals significant
direct and indirect economic benefits.
12. Several studies have looked at quantifying
the economic benefit to farmers, many of which such as more targeted
chemical use, has secondary environmental benefits that are difficult
to place a pound value on. Some of these reports and their main
conclusion follow.
— The introduction genetically modified
herbicide tolerant (GMHT) sugar beet will provide average economic
benefits of £154 per hectare to UK beet producing farmers
(May 2003)
— 10% of UK GDP and 1.75 million people
are employed by industrial sectors, which rely on biotechnology
applications. Nawaz 2003.
— Biotechnology is extremely important
to the EU, its own estimates place its value at
100 billion for the EU by 2005, (European Commission,
2002).
— Economic modeling forecasts predict
that the worldwide adoption of genetically modified crops could
boost the overall income of all regions by $316 billion by 2015.
(Australian Bureau of Agricultural Resource Economics (ABARE)
Foster, 2003).
— The introduction of GM-oilseed rape
to Canada has increased farmer and the supply chain earning of
up to $250 million and $215 million a year, respectively. The
Canadian Canola Council estimates that GM oilseed rape farmers
spray 6000 tonnes less herbicide and use 31 million litres less
diesel a year (Canola Council of Canada, 2001).
— The eight-biotech crops grown commercially
in the US increased saved growers $1.5 billion in 2001. Extrapolated
analysis of 32 biotech crops under development but approaching
commercialization indicated that, if adopted, they would contribute
an additional $400 million per year to grower savings (Gianessi
et al, 2002).
13. We must consider the opportunity impact
in the UK if the rest of the world moves forward with more environmentally
friendly and also more economically viable agriculture and UK
farmers are denied this option.
14. A recent report from Australia, referred
to by Dr Merritt in his evidence session concluded, "Some
stakeholders who represent groups that might be adversely affected
by the release of GM canola for commercial production argued before
me that the existence of these negative effects on other stakeholders
alone implies that the release should not be permitted. This argument
is inadequate, as it takes no account of potential benefits and
ways of reducing risks. A denial of a commercial release would
impose costs on those seeking to grow GM canola in just the same
way, as the release would impose costs on other stakeholders."
http://www.vic.gov.au/VictoriaOnline?action=content&id=328&pageName=Latest&pageTitle=Latest
REGARDING "LEGAL
PROSECUTION" OF
FARMERS
15. Concerns were raised in our evidence
session about high profile cases where the industry was involved
in legal disputes with farmers. It is a NGO provoked misconception
that the industry is suing farmers that accidentally receive or
grow any GM crops at all and that the industry pursues any individual
that is found to have "one GM plant within his farm boarders".
This is simply not true. No legal prosecution by the industry
has been initiated against a farmer that had adventitiously grown
GM seed. It is not Industry's intention to ever prosecute farmers
that have adventitious of GM crops on their farms.
16. The few high profile cases that have
occurred have been initiated against farmers that have grown entire
fields of very high purity GM crops. In these rare cases industry
needs help create a level playing field for all farmers. It would
be unfair for 99% of farmers actively growing a GM crop to be
paying companies a technology fee for the cost and time benefit
of growing a GM crop, only to be out competed by their neighbor
that is receiving the same costs and time benefit, without paying
a technology fee to the company that spent decades and tens of
millions of dollars developing the technology.
17. These rare cases are not about controlling
farmers or patenting life. They are about protection of legal
property. In the most high profile of these cases between Monsanto
and Schmeiser. Mr Schmeiser lost the initial action, as well as
two further appeals that culminated in defeat again last week,
in the Canadian Supreme Court.
The Agricultural Biotechnology Council (abc)
May 2004
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