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Press release 3rd May 2006
from GM Free Cymru

GM Free Cymru Response to ACRE Consultation

Consultation on the ACRE report on “Managing the Footprint of
Agriculture: Towards a Comparative Assessment of Risks and Benefits for
Novel Agricultural Systems”
Wider Issues Subgroup

http://www.defra.gov.uk/environment/acre/fsewiderissues/index.htm

Consultation Response -- deadline 9th June 2006

We note that this report was announced and was made available for
consultation on 17th March, at the height of the Curitiba meetings and
the fuss about terminator technology, with the invaluable help of Fiona
Fox and the Science Media Centre. News management at its best!
Although we were not included in the list of consultees, no doubt
because of an oversight on your part, we are happy to respond to the
document in question.

1. It seems to us that the purpose of the Report is to suggest that GM
crops are not really any more harmful then any other "novel" crops, and
that they are over-regulated by comparison with other crops. ACRE
would clearly like to see the current tight regulation, under the terms
of Directive 2001/18/EC, replaced by some sort of cost/benefit
analysis. The document describes something called a "Comparative
Sustainability Assessment" (CSA) which, if adopted by the Government
and applied to all novel crops, will no doubt keep the ACRE secretariat
and committee members gainfully employed. We are totally opposed to
any attempt to undermine or dilute the importance of Directive
2001/18/EC in the assessment and regulation of GM crops; no matter
what ACRE may feel, these crops are different in kind to all other
crops, and are associated with a unique set of environmental and health
dangers. The uncertainties associated with GM safety and environmental
impacts were flagged up by the EC in its "defence case" in the recent
WTO trade dispute with the USA, at the same time as the Commission was
cynically issuing consents for new GMO releases into the environment
and assuring the public that every single approved GM variety had been
proved to be entirely safe. In summary, we do not feel that GM
varieties are "over-regulated"; on the contrary, the case of the GM
peas in Australia has shown all too clearly that the regulatory process
in Europe (and that includes the UK) is far too lax.

2. The report mentions that there is too much concentration in the
regulatory approvals process on the negative or harmful effects
associated with GM varieties, and not enough opportunity for the
regulators (including ACRE) to assess any benefits arising from GM crop
plantings. We find this a bit rich, to put it mildly, since the whole
approvals process is designed to facilitate (a) the submission of
favourable or supporting evidence by the GM corporations applying for
consent, and (b) to assist applicants in obtaining consent as smoothly
as possible. It does not seem to have occurred to ACRE that this
process is itself corrupt, since it is based upon "advocacy science"
commissioned and carefully selected by the applicant corporations, and
since the science is in many cases non-replicable since the
corporations will not allow "independent scientists" access to their
plants and seed stocks. The recent case in which Monsanto shut off
supplies of MON810 seeds to Hungarian researchers (when they started to
find uncomfortable evidence of environmental damage) illustrates this
perfectly. In our view there is far too much emphasis on the
beneficial effects of GM crop plantings already, and until there is
greater objectivity in the science surrounding the approvals process,
we would be absolutely opposed to any move designed to give ACRE a role
in flagging up the benefits of GM crops or otherwise promoting their
benefits to a sceptical public.

3. In our view there must be no dilution of the Environmental Risk
Assessment Process associated with applications that fall under
Directive 2001/18/EC. In fact, the process should be tighter, with
ERAs undertaken by genuinely independent research teams and paid for by
the applicants for consent. These applicants should have no role in
choosing the consultants. We are aware that EFSA is attempting to push
the idea of ERAs being undertaken in future by accredited bodies which
have a sufficient capacity and competence for the work. That
immediately starts alarm bells ringing. We foresee that the "best"
bids (ie those which can be counted upon not to cause too much trouble)
might well come from the advisory committees (like ACRE) or
Environmental Ministries of those EU countries which traditional vote
for approvals and back up the "opinions" published by EFSA. That would
be to add another layer of corruption to a system which is already
corrupt -- and this is apparently something which has already been
noticed by many of the Environment Ministers of the EU.

4. There is a certain smugness in the Report relating to the conduct
of the FSEs and the results that came from them. We are aware that
ACRE advised that the field trials of GM sugar beet and GM oilseed rape
demonstrated environmental harm compared with their non-GM
counterparts, and that it advised that GM maize would not result in
adverse impacts "if managed as in the FSEs". We are also aware that
there are differential and harmful effects on wildlife associated with
all conventional (and especially high-input) farming systems and crop
management regimes. But we have criticized the FSEs as being highly
flawed, and as you will be aware we do not believe that the null
hypothesis was adequately tested in any of the trials because
management procedures were manipulated and did not replicate real
farming conditions. Also, the most meaningful comparisons (with
organic or low-input farming regimes) were not effectively made. The
wording in your report is carefully crafted to give the impression that
some GM crops may be slightly harmful, but other conventional crops are
even more harmful. That again skates over the crucial point that GM
crops (for example those containing Bt toxins) are UNIQUELY DANGEROUS
AND UNIQUELY UNPREDICTABLE IN THEIR LONG-TERM EFFECTS.

5. We applaud the involvement of ACRE in work designed to more
accurately define harm, and in the work looking into pesticide effects.
However, we are concerned that ACRE might seek (as EFSA is doing) to
redefine the word "harm" to mean precisely what you wan it to mean, so
that it becomes "significant ecological damage" or some such thing,
with fuzzy (and very convenient) greyness surrounding the whole term.
There are plenty of cost-benefit analyses going on already, and we want
ACRE to concentrate on protecting the public and the environment from
damage. Let others (including the seed merchants and the NFU) flag up
the supposed benefits of GM crops if they want to.

6. We are not at all happy with the Illustrative examples included in
the document, and ACRE bias towards GM varieties is all too clearly
seen. Here are two quotes:
On Bt cotton: "Compared to cotton sprayed with insecticides, Bt cotton
has major benefits in terms of the environment, yield security, and
human health. The environmental disbenefits appear marginal by
comparison."
On Bt maize: "The use of Bt maize has provided farmers with more
security and higher yields. A large body of research on the effects of
Bt maize on not-target arthropods has not shown any ecologically
significant negative impacts in the field."
Those statements are both travesties, and we cannot understand why they
were not modified by ACRE committee members during the editing process
on this document. At the very least, the "conclusions" should give
greater weight to the appalling evidence now coming out of Europe,
India and Australia which shows that Bt varieties are capable of
inducing toxic shock in mammals, allergic reactions among humans, and a
great deal of harm (and we use that term advisedly) to soils and the
environment generally.

In conclusion, we have fundamental disagreements with ACRE on a wide
range of issues, and we would be opposed to any role being given to
ACRE which would give that body opportunities to flag up the supposed
benefits of GM crop plantings in the UK and Europe.

We may submit further comments on this document before the deadline of
9th June 2006. If you require a fully referenced version of this
submission, please let us know.

Yours sincerely,

Dr Brian John
GM Free Cymru

==========================

The ACRE sub-group currently has the following terms of reference:

To advise ACRE on the wider implications of the farm-scale evaluation
(FSE) results with respect to the deliberate release of genetically
modified organisms into the environment.
To advise on the implications of the FSE for the scientific assessment
of the environmental impact of agriculture generally, including advice
on the appropriate objectives for environmental protection in farmland
including the baselines against which the risks of the deliberate
release of genetically modified should be compared.
To advise on the assessment of adverse effects with respect to
agricultural management (building on the work of previous ACRE
sub-groups) in a way that is consistent with government objectives for
enhancing farmland biodiversity.
To advise on the extent to which the assessment of indirect
environmental benefits is relevant in the assessment of GM crops.
To advise on issues arising from the use of comparative risk assessment
methods in assessing indirect management effects of GM crops (building
on the work of previous ACRE sub-groups).
To advise ACRE and ministers of any discrepancies in regulation that
hamper the assessment of GM and other crops and management practices.
To advise ACRE on any new research needs to address the wider
implications of the FSEs.