This document was submitted to Carwyn Jones, Rural Affairs Minister of
the
Welsh Assembly Government, on 18th September 2003.
============================
Draft GM Coexistence Measures for
based upon "Commission Recommendation of 23 July 2003 on guidelines for
the
development of national strategies and best practices to ensure the
coexistence of GM crops with conventional and organic farming."
PREAMBLE
The following points should be borne in mind:
1. This is all about "co-existence" and so the wording must
conform to the
EU mantra that we are seeking to allow GM plantings to proceed alongside
conventional and organic plantings.
2. Other words used are "efficient", "cost-effective",
"transparent",
"science-based", "equitable", "cooperative"
and "proportional"
3. The driving force behind this is that member states should take
appropriate measures to avoid the unintended presence of GMOs in food and
other products and that these measures should "complement the comprehensive
regulatory framework that the EU has set up"
4. During the phase of introduction of GM farming, those farmers planting
GM should be the ones who bear the responsibility for implementing the
measures.
5. Continuous monitoring and evaluation and sharing of best practices
are
also needed so that measures can be improved over time. It is implied
here
that the GM crop growers are the ones who should bear the costs.
6. Measures should specify the crop type (ie the GM variety should be
named) and should be related to the potential for contamination (eg high for
GM rape but lower for GM potatoes) but local farming practices and landscape
/ ecology could be important.
7. If special pleading is needed for the introduction of very strict
measures in
country which is protected by law. Some of the protected designations
are
EU designations, and others are specific to the
8. Another very important point -- guideline 2.2.2 says it is important
to
look at the cumulative effects of GM contamination, which in the case of
oilseed rape (according to Dr Jeremy Sweet) will lead eventually to 100%
contamination by GM seeds and hybrids. On this basis, we believe that
the
Assembly could simply refuse to allow any GM oilseed rape to be planted in
cumulative effects of contamination from different sources would lead, over
a few years, to unacceptably high levels of contamination in conventional
and organic crops. In our view this will happen, with ALL the
GM crops
currently under consideration.
9. Another key point is that these measures should be driven by ECONOMIC
considerations, and would be additional to any measures which the Welsh
Assembly might bring in on health or environmental grounds.
==========================================
DRAFT MEASURES
1. Assembly will only authorise a GM release into the environment where
it
is advised by ACRE and other consulted advisory bodies that the crop "is
not
capable of causing harm to human health or the environment." (This
is
already Assembly policy.)
2. Assembly will make Environmental Prohibition Orders for all GM plantings
in
that there are no other plantings of related varieties within 6 km of the
planting site. (A 200m separation distance is clearly inadequate, and must
be greatly increased.) Presumably EPOs could be brought in for all
protected landscapes in
Reserves, etc, on the basis that any GM plantings in those areas would
threaten biodiversity and ecology? Environmental Protection Act and
Cartagena Protocol could be adduced here. Could there also be EPOs creating
"exclusion zones" or "cordons sanitaires" around the borders
of protected
areas?
3. Assembly, bearing in mind the local characteristics of small-scale
farming in
and conventional lines, and local ecological and climatic conditions, will
impose on-farm measures on a case-by-case basis where a farmer proposes to
plant a GM crop. These management measures may include on-farm isolation
distances, buffer zones, installation of pollen barriers down-wind, and
prohibition of plantings of related non-GM varieties for 2 or more years
following the harvesting of the GM crop.
3. Assembly will insist that a farmer proposing to plant a GM crop
cooperates with all neighbours within 10 km of the planting site and informs
them regularly on designated dates of sowing plans, precise characteristics
of the GM variety proposed, anticipated flowering time, spraying regimes,
harvesting date, and biosecurity measures in place to avoid
cross-pollination and accidental spillage of GM seed.
4. Assembly will insist that applicants for GM crop plantings demonstrate
that they have taken due account of local policies approved by County
Councils, National Park Authorities and other tiers of local government.
Where there is a clearly expressed democratic wish for a county or region
to
remain GM-Free, GM plantings, if they go ahead, could result in civil
disorder and high costs incurred in policing, prosecution of protestors etc.
Neighbours may also suffer incidental economic damage. Applicants for
GM
plantings must indemnify the Assembly and local authorities against all
costs that may be involved in these actions.
5. Being mindful of the current trend within Wales for the use of
contractors and Machinery Rings in drilling, crop management and harvesting,
and seed transport onto and off the farm, Assembly will insist that all
machinery which comes into contact with GM material and which subsequently
moves off-farm is cleaned, sprayed and sterilized to at least the same
standards as used in IGER seed trials, accredited seed lots etc. Machines
must also carry biosecurity signs (skull and crossbones?!) when transporting
GM materials off-farm, and they must carry biosecurity labels indicating the
dates of contact with specified GM varieties. This is all necessary
to
avoid unintended spillages of seed/mud mixtures and use of machines, for
example, on a GM maize field in Tenby on one day and on an organic maize
field in Haverfordwest on the next day. Spillages on roadways are also
well
known (cf NIAB Report / Jeremy Sweet correspondence), leading to
adventitious occurrences of GM plants on highway corridors. Even more
onerous measures might be employed on machines operating in protected areas
(eg National Parks). The GM crop applicant must take responsibility
for
informing machinery contractors of these measures, must ensure that all
biosecurity rules are followed, and must carry all costs involved.
6. Assembly will insist that all GM plantings are notified to the general
public through press notices, farm-gate notices etc at least three months
ahead of the proposed planting date. The fields concerned must be clearlyu
identified through the use of six-figure grid references. If more than 100
local residents protest against the planting, the applicant must call a
public meeting and must take due account of the feelings of the meeting.
If
the meeting requests that the proposed GM crop planting should be abandoned,
the Assembly may refuse to authorise it.
7. Being mindful of the need for careful monitoring of biosecurity,
GM crop
management procedures, and the risks of cross-pollination, the Assembly will
impose a monitoring regime appropriate to the GM crop proposed. The
applicant will be required to carry the costs of the monitoring work.
8. Prior to GM crop planting, every applicant will be required to submit
a
detailed site-specific Environmental Impact Assessment. Guidelines will
be
published by the Assembly. On receipt of the EIA, the Assembly will
decide
whether the risks inherent in the proposed GM crop planting are low enough
to justify approval.
9. All farmers and contractors involved in the planting, management
and
harvesting of a GM crop, and in the transport of GM materials off-farm, will
be required to complete, in advance, an approved training course in GM crop
management. Documentation relating to personal accreditation will have
to
be produced.
10. Applicants for GM crop plantings will be required to exchange
information with neighbours, local authorities, the Assembly and the general
public relating to crop characteristics and health and safety assessments,
associated herbicides and management matters at least three months prior to
planting. This information will be held on a public register, and the
Assembly will be mindful of objections that may be raised relating to
scientific deficiencies, safety concerns etc.
11. The Assembly will ensure that advisory services are available to
farmers proposing to plant GM crops, and to other farmers who might be
affected economically, and the seed developers will be expected to
contribute to the funding of these services.
12. Before the Assembly gives any consent for a GM crop planting, it
will
wish to be satisfied that the farmer concerned has adequate liability
insurance in place against consequent financial losses by neigfhbours and
other farmers, and against consequential losses incurred by the Assembly or
local authorities. The Assembly will wish to see documentary evidence
of
this liability insurance.
13. The Assembly will require a written management plan designed to
minimise the risk of GM contamination by farm animals and wild animals
including roe deer, birds, bees, foxes and badgers. In particular, they will
seek assurances that no farm animals will be allowed onto land used for GM
crops within three years of the date of GM seed planting.
14. The Assembly will look for on-farm measures to ensure that ramblers
and
riders will not have access to GM crop fields in the years of planting and
harvest and for three years thereafter. Density and usage of footpaths
is
important here. Could also be health / allergy effects for sensitive
individuals. Seeds on muddy boots, horses' hooves, pollen on clothing?
(See
the recent article in Country Walking magazine: "Walkers in GM scare"
- Sept
2003).
15. Assembly will seek written guarantees that there is complete
segregation of GM and non-GM seed stocks at the silos of the seed supplier.
This is in recognition of the fact that in the United States it is now
impossible to guarantee the purity of maize seed supplied to conventional
or
organic farmers.
16. Assembly will not tolerate any secrecy in the planting of GM crops,
since this erodes public confidence and creates concern. Assembly will
maintain a public register of all GM crop plantings in Wales, including
six-figure grid references for fields used, farmers name and full address,
seed owner's full name and address, and monitoring and crop management
history etc. All records submitted in support of planting applications,
and
all other paperwork, will also be on the public record and will be available
for inspection by interested parties.