Select Committee on European Communities Second Report - Written Evidence

Memorandum by the Royal Society for the Protection of Birds


  We welcome this opportunity to submit evidence to the sub-committee's enquiry into the EU regulation of genetic modification in agriculture.

  The RSPB in the UK and Europe (as part of BirdLife International) works towards better understanding of the ecological relationships between species and habitats and land management, and the economics of these activities. We promote constructive ideas for integrating the environment into agriculture policy. We have championed the achievement of specific, measurable and widely accepted targets for biodiversity conservation across farming policy as defined in the Government's Biodiversity Action Plan (BAP).

  The RSPB believes that the use of genetically modified (GM) organisms carries the threat of damage to biodiversity. The potential impacts on land-use as a consequence of the utilisation of GM organisms could create big and long term problems for the environment, and in particular for biodiversity. We believe that the current regulatory mechanisms and the way they are interpreted fail to deal with this threat. As a result RSPB have supported the call from English Nature and other UK conservation agencies for a five-year moratorium (until 2002) on allowing GM crops to be grown commercially. During this period we have called for the effects of such crops on the environment and biodiversity to be fully tested. The research should include the impacts on, and the changes in, farming practice and the consequent direct and indirect effects on biodiversity which may occur during or following the use of genetically modified organisms.


  1. There are a number of specific concerns that arise from the release of GM organisms into the environment:

    (a)  The establishment of the GMO as a "pest", such that it causes harm to ecological processes or to non-target species within the ecosystem.

    (b)  The transfer of the introduced genes from the GMO to other species, which subsequently become established as "pests".

    (c)  Changes in the extent to which herbicides, insecticides and other pesticides are used in the environment.

    (d)  Changes to the range for geographical locations, altitudes, soil types, etc., within which the production of certain crops is economically viable.

    (e)  Changes to seasonal cropping patterns.

  2. The existing regulations, both in the UK and Europe appear to have been designed to cover points a and b.

    (a)  The establishment of the GMO as a "pest", such that it causes harm to ecological processes or to non-target species within the ecosystem.

    (b)  The transfer of the introduced genes from the GMO to other species, which subsequently become established as "pests".

  3. However there appear to be no regulations at EU or UK level that deal with points c, d and e.

    (c)  Changes in the extent to which herbicides, insecticides and other pesticides are used in the environment.

    (d)  Changes to the range of geographical locations, altitudes, soil types etc., within which the production of certain crops is economically viable.

    (e)  Changes to seasonal cropping patterns.

  We feel that these impacts on land-use, and resulting indirect impacts on biodiversity, as a consequence of the use of GM organisms could create the big and long term problems for the environment. Indeed Professor John Beringer, Chairman of The Advisory Committee on Releases into the Environment (ACRE), alluded to this point in the 1996/7 ACRE Annual Report, Annex 1.

  4. As outlined in appendix 1, much of the biodiversity (plants, insects birds and mammals) of farmland has been in decline for at least 25 years. These declines have largely resulted from changes in farming practices resulting from scientific and technological shifts. We believe that the commercial use of GM organisms could lead to further changes and intensification of farming practices adding greater pressure to already declining farmland wildlife.

  5. Example 1: Herbicide tolerant crops. Such crops are modified to be resistant to "broad spectrum" herbicides, such as glyphosate or glufosinate ammonium. "Broad spectrum" herbicides kill a wide range of plants. In crops which are tolerant to these chemicals all plants and weeds that are not the crop will be removed, whether or not there would be a commercial advantage in doing so. Whilst we recognise that weed control of some form must take place we would question the need to remove all plants that occur in a particular crop.

6. There have been great advances in crop production in the past ten years using integrated systems such as Integrated Crop Management, which aims to reduce environmental impacts of farming within a conventional farming system. The principles of ICM recognises that not all weeds in a crop will have a negative impact on crop yield or performance. ICM systems use thresholds or targeting of specific weed species as an advanced way of dealing with the problem. Herbicide Tolerant Crops go against these principles and could have direct impacts on arable plants that are currently endangered and appear on the Governments BAP such as red hemp nettle and shepherd's needle.

  7. There are claims that the amount of herbicide being applied to herbicide tolerant crops will be reduced. This may be true, however it seems highly unlikely that the impacts of herbicide use will be reduced, consequently there is little point in reducing the volume applied.

  8. The plants that are removed by "broad-spectrum" chemicals also provide a habitat for insects. Some of these insects are declining in population (see appendix 1), the majority are not pests or crops and indeed some are "beneficial insects" which prey on the insect pests.

  9. The loss of plants and insects from the arable ecosystem may have important repercussions for the food chain. A JNCC report, entitled A Review of the Indirect Effects of Pesticides on Birds produced by a consortium including, RSPB, Oxford University, BirdLife International, Butterfly Conservation, The Institute of Terrestrial Ecology, and Plantlife was submitted to the Department of the Environment, the Joint Nature Conservation Committee and English Nature in May 1997. The indirect effect of pesticides on birds can be defined as the removal of components thus denying sources of food for birds. The Game Conservancy Trust have shown that indirect effects have caused the decline of the grey partridge (population decline of 82 per cent on the last 25 years). The conclusion of this report found that whilst such effects had not been proven they could not be ruled out for another 19 bird species. The Government has committed itself to conserving 15 of these species in the BAP.

  10. The recommendations from this report included calls to try and reduce the impact of pesticide use which could be achieved by encouraging the use of more target-specific chemicals. The use of crops that are genetically modified to be tolerant to broad spectrum chemicals works in the opposite direction and will have damaging effects on wildlife as a result.

  11. The current European regulations fail to pick up these indirect impacts on land-use and consequently on biodiversity. Crops such as glufosinate-ammonium tolerant oilseed rape have already been approved for use and are currently awaiting marketing consent in Member States before they can be grown.

  12. An example of the gaps created by the UK regulation is apparent when considering herbicide tolerant crops. ACRE assess the risk to human health and environment according to the type of the herbicide tolerant crop. This would involve the identification of hazards such as capacity to survive, establish and disseminate, potential for gene transfer, phenotypic and geotypic stability, pathogenicity to other organisms. The likelihood of these hazards occurring would then be assessed, followed by an assessment of what this would mean for the environment or for human health.

  13. In order to be able to use the herbicide on the crop approval would have to be sought for the new use. Within this assessment would be the efficacy of the chemical at doing the job it is required, and the toxicity of the chemical to humans and certain other species.

  14. These two regulatory processes leave a large gap of potentially serious environmental impacts that are not assessed at all in the approval of GM crops.

  15. Example 2: Insect tolerant crops. Crops that are tolerant to insect attack could be potentially beneficial to wildlife as they could reduce the amount of insecticides being applied to the crop. This could reduce the impact on the food chain by only removing insect pests and not other insects which occur in the field.

  16. However a recent report in New Scientist[36] looked at research carried out on GM maize that has been modified to be tolerant to an insect, the European corn borer. The work found that there were some secondary effects on an insect predator of the corn borer.

  17. The modified crop contains a gene from the bacterium Bacillus thuringiensis that produces an insecticidal protein. When the crop pest eats the crop it ingests this "natural" poison. However when an insect predator of the corn borer, the lacewing was fed on corn borer larvae that had been eating the crop, the death-rate of the lacewing doubled. The doubling of death rate was also recorded when lacewings fed on other pests that had been feeding on the crop but were not affected by the poison (the insecticidal protein only affects certain species such as the corn borer).

  18. A review of the insects that are food sources for birds, from The indirect effects of pesticides on birds shows that lacewing are a dietary component for the 19 bird species, 15 of which appear on the Governments BAP. Therefore the use of this crop could have effects higher up the food chain. Furthermore lacewing are also natural predators of crop pests or "beneficial insects", and can help the farmer in protecting crops.

  19. Whilst the lacewing in the wild would not feed exclusively on the corn borer it could have cumulative impacts further down the food chain.

  20. This demonstrates again that not all the potentially serious environmental impacts are being covered by the current European regulatory packages. Insect tolerant maize is already commercially grown in the certain parts of Europe.[37]

  21. A further indirect effect of crops that have been modified to resist certain pests or to be resistant to broad-spectrum pesticide use, is that they may remove the need to rotate crops. Crop rotations are traditionally used to reduce impacts of pests (fungal diseases, soil borne insects and weeds). Rotations however are important for wildlife in that they provide a variety of crops in which a greater variety of weeds and insects will exist, consequently providing food for a wider variety of birds and mammals. The loss of rotations could simplify cropping and further reduce habitats and put further pressure on declining wildlife.

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