ngin - Norfolk Genetic Information Network

17 October 2002

URGENT: PLEASE RESPOND TO UK GOVERNMENT STITCHUP!

As part of the UK Government's consultation on GM crops, the Prime Minister's Strategy Unit has asked for feedback on a 'Scoping note' they have published for the report it plans to publish on 'The Costs and Benefits of Genetically Modified (GM) Crops'.

'Scoping note' is just jargon for something that sets out the scope for the study the Strategy Unit is planning.

The 'Scoping note' is reproduced in full below and as you will see makes some outrageously biased assumptions.

It's obviously important that as many people as possible write in and tell them so!

CONTACT DETAILS ARE GIVEN BELOW. Responses need to be in by **25th October**

You'll want to make your own points but here are some obvious examples of ludicrous bias:

The Scoping note talks about the benefits of GM but these are, of course, entirely hypothetical. It talks, for instance, about benefits for farmers that include:

* Stress & disease resistant plant lines;
* Low input crops, e.g. decreased nitrogen requirement therefore lower production costs;
* Higher yields;

Sounds great, but the crops that are close to commercialisation offer none of these benefits!

Surely it would make more sense to consider commercialisation on these grounds when such benefits were demonstrably available - not when they're demonstrably not!!

The same applies for the benefits projected for consumers and society at large:

* Lower product prices;
* Better quality food;
* Reduced likelihood of contamination with toxins and biocides.

* Low environmental footprint crops and farming systems;
* Availability of renewable raw materials;
* Stronger rural economy;
* Benefits to biodiversity [!!!!!!!!!!!!!!!!!!!]

This is sheer fantasy. There is no clear evidence that any existing GM crops can deliver any of these benefits. If anything, the reverse.  It's rather like being asked to consider whether to commercialise nuclear power plants that are less efficient than existing conventional power plants and staggeringly more hazardous than alternative energy sources, on the basis that they are projected to produce electricity that will be too cheap to meter at some undefined point in the future.

It's clearly absurd to assume that all the benefits that are projected for GMOs by their proponents will be realised.

Far more realistic would be to base any decison on the actual "benefits" that have accrued so far (eg higher costs, lower yields, lost markets etc. - see: http://members.tripod.com/ngin/farming.htm) and what impact they would have on our economy!!!!

It also fails to ask to what extent these benefits could be delivered by alternative means without the risks, e.g. via biotechnology without genetic engineering (through Marker Assisted Breeding, for instance)

Predictably, the concerns section (2.3) is short, hesitant and vague:

"For some people, there is also concern that the introduction of GM crops might lead to unforeseen and unintended consequences that are not even being considered as yet."

This sounds wonderfully vague but ignorance is so much the name of the game with this technology that unforeseen problems are a racing certainty (as some of the more honest proponents are prepared to admit), though obviously hard to cost.

Most of the concerns that are listed are posed as questions - what a contrast! The benefits can be assumed but the hazards are uncertain and/or are those of only "some people".

* Are GM foods safe to eat?
* Would GM crops have an adverse effect on the environment?
* How will the implications of UK decisions be affected by decisions on commercial growing of GM crops in other countries?

The Scoping note also assumes that GM crop production on a commercial scale is likely to go ahead everywhere else in the world. This is very unlikely to be the case - witness how isolated the UK is at the moment in Europe over GM food labelling and in its drive to lift the moratorium.

And if the report is limited to examining what effect GM commercialisation will have on the UK, why will it include its projected impact in developing countries?

"Agricultural biotechnology, including GM crops, may not represent a Œsilver bullet‚, but this technology does have the potential to improve agricultural production which is a component of the broader challenge of food security."

Why do we have to include a hazardous technology - GE - within this broader category? We can have modern biotechnology (MAB etc.) without GE.

Clearly the inclusion of this consideration is intended to create the sense of a moral imperative for the UK to grow GMos, ie in order to feed the hungry. And once again there is no consideration of the other (proven!) alternatives for doing this:
http://members.tripod.com/ngin/article2.htm
http://members.tripod.com/ngin/feedtheworld.htm

The section on costs (5) is shambolic & full of false assumptions. For example, it says, "growers will only choose to produce GM crops if there is a demand for GM products" but the US's loss of export markets for its crops show that farmers can be fooled by hype only to discover the full consequences of their actions later, particularly when subsidies and dumping are used to disguise the impact of market loss.

Clearly, Downing St are trying to use the economic argument to show that GM is vital for the UK, which flies in the face of all experience & it's important that we let Blair know we're on to him!

CONTACT DETAILS

Please send responses to the questions and issues raised in this note by post or email to:

GM Crops Team
Prime Minister‚s Strategy Unit
Cabinet Office
4th Floor Admiralty Arch
The Mall
London
SW1A 2WH

GMCrops@cabinet-office.x.gsi.gov.uk

In order for the SU team to be able to take submissions fully into account, responses should be sent to arrive in SU by 5.00pm on Friday 25th October 2002. All submissions will be published on the SU website. There will be further opportunities to comment on the work of the SU team during the course of the study.

The postal address and email address listed above may also be used for general questions relating to the study.

The SU website is at http://www.strategy.gov.uk.
---
Prime Minister‚s
Strategy Unit

The Costs and Benefits of Genetically Modified (GM) Crops
Scoping Note

Table of Contents

1. INTRODUCTION 3
2. CONTEXT 4
WHAT ARE GENETICALLY MODIFIED (GM) CROPS? 4
BENEFITS, COSTS AND CONCERNS ASSOCIATED WITH GM CROPS 4
THE GROWING OF GM CROPS AND CONSUMPTION OF GM PRODUCTS IN THE UK 6
3. THE PUBLIC DEBATE ON GM CROPS 8
THE FRAMEWORK FOR THE PUBLIC DEBATE 8
SUPPORTING THE PUBLIC DEBATE: THE SCIENTIFIC REVIEW AND THE SU STUDY OF COSTS AND BENEFITS 9
4. THE APPROACH OF THE SU REVIEW 9
SCENARIO ANALYSIS 9
CATEGORIES OF COSTS AND BENEFITS 10
ISSUES BEING TAKEN FORWARD IN OTHER WORK 11
5. INITIAL VIEWS ON THE MAIN AREAS WHERE COSTS AND BENEFITS NEED TO BE ASSESSED 12
COSTS AND BENEFITS IN GM PRODUCT CHAINS 12
COSTS AND BENEFITS IN CONVENTIONAL PRODUCT CHAINS 13
COSTS AND BENEFITS IN ORGANIC PRODUCT CHAINS 14
COSTS AND BENEFITS TO THE ENVIRONMENT 14
COSTS AND BENEFITS IN THE BIOTECHNOLOGY SECTOR AND ASSOCIATED INDUSTRIES 15
COSTS AND BENEFITS IN THE WIDER RURAL ECONOMY 16
IMPLICATIONS OF UK AND EU POLICY FOR GM CROPS IN DEVELOPING COUNTRIES 16
6. PROJECT OUTPUTS AND ORGANISATION 17
7. INVITATION TO SUBMIT VIEWS ON INITIAL QUESTIONS 18
8. CONTACT DETAILS 19

 1. Introduction

1.1 The purpose of this note is to set out the scope for the Strategy Unit (SU) study on the costs and benefits associated with the growing of GM (genetically modified) crops in the UK. This will include the implications of UK commercialisation decisions on the ability of developing countries to make an informed choice about GM crops. The study was announced by the Secretary of State for the Environment, Food and Rural Affairs on 31st May 2002, and further details were released on 26th July 2002.

1.2 The SU study will be taken forward alongside a review of the scientific issues relating to GM crops, and both will feed into a public debate on issues raised by the genetic modification of agricultural crops. The public debate is being organised by an independent steering board whose members are drawn from the Agriculture and Environment Biotechnology Commission (AEBC), and in a few cases from elsewhere. The steering board‚s aim is to promote an innovative programme of public dialogue that will enable the nature and spectrum of public views to be better understood. The review of the science is being led by the Government‚s Chief Scientific Adviser and DEFRA‚s Chief Scientific Adviser, with independent advice from the Food Standards Agency.

1.3 The SU study will aim to collect and analyse the facts on the potential impacts of growing GM crops in the UK. It will do so through an open and transparent process, taken forward through the following means:

* Regular publications of material on the SU website, and associated calls for information and views;
* Direct mailing of important documents to key stakeholders;
* Ongoing interaction and involvement with the steering board for the public debate;
* Meetings and seminars involving the full range of interest groups.

1.4 In addition, it is envisaged that stakeholders will have an opportunity to submit comments on the final report from the study.

1.5 The remainder of this note sets out the following issues:

* The context for the study, including the current state of the debate on GM, the reasons for undertaking this study now and what the study is aiming to achieve.

* The organisation of the study, including the way in which it will interact with the other strands, governance structures and schedule.

* Initial thoughts on main areas where costs and benefits need to be assessed in the study.

* Contact details for finding out more information and for sending your views to the study.

1.6 The SU project team welcomes views on this note and on the scope of the study. Specific questions on the scope are highlighted towards the end of this note (section 7). Views on these questions would be especially useful, but wider views on the study are also welcome. Please send responses to the questions and issues raised in this note to the following postal or email address (see also section 8 of this note). In order that the SU team can take views fully on board, please ensure that responses arrive by 5.00pm on Friday 25th October 2002 at the latest.

GM Crops Team
Prime Minister‚s Strategy Unit
Cabinet Office
4th Floor Admiralty Arch
The Mall
London
SW1A 2WH

GMCrops@cabinet-office.x.gsi.gov.uk

1.7 All responses will be published in due course on the SU website.  Further opportunities to comment on the work of the SU team will be provided during the course of the study.
 

2. Context
What are genetically modified (GM) crops?

2.1 In traditional plant breeding two plants are cross-bred in an attempt to develop a new plant with a desired characteristic, such as improved yield. Only plants of the same or closely related species can be cross-bred in this way, and each plant‚s entire set of genes are mixed in the process. In contrast, a genetically modified (GM) plant is one that has had its genetic makeup altered either by the addition or deletion of individual genes. Where genes are added they may come from completely unrelated species.

Benefits, costs and concerns associated with GM crops

2.2 GM technology could potentially deliver a wide range of benefits ˆ and this range will almost certainly increase into the future as new technologies come on stream (e.g. the development of GM crops with medicinal benefits). These benefits could include the following:

* Potential benefits for farmers. These are benefits that would arise directly from the growing of GM crops in the UK, and would primarily act to reduce costs and improve the competitiveness of UK farmers. The benefits may in turn be passed on (at least in part) to consumers, and could arise through improvements such as:

* Stress & disease resistant plant lines;
* New cash crops, e.g. antimicrobials, therapeutic proteins;
* Diversification of activities;
* Low input crops, e.g. decreased nitrogen requirement therefore lower production costs;
* Higher yields;
* Better quality of life through time savings.

* Potential benefits that may accrue directly to consumers. These are benefits that would arise from the availability of GM products in the UK, and would not necessarily require that the crops were grown in the UK. Examples include the following:

* Lower product prices;
* Better quality food;
* Food for specific consumer groups, e.g. coeliacs;
* Novel bioactive molecules and drugs;
* Novel functionalities in proteins, carbohydrates/chemical intermediates/fibres;
* Reduced likelihood of contamination with toxins and biocides.

* Potential wider benefits to society. These could encompass the following range of areas:

* Low environmental footprint crops and farming systems;
* Availability of renewable raw materials;
* Stronger rural economy;
* Decreased use of fossil fuels;
* Benefits to biodiversity.
 

2.3 At the same time, costs could be incurred by farmers and others operating in conventional and organic product chains, for example as a result of cross-pollination ˆ or action to prevent cross-pollination ˆ from GM crops. In addition, there is a degree of public concern about the possible commercial growing of GM crops in the UK, and about GMOs (genetically modified organisms) and GM foods in general. In broad terms, the concerns can be grouped into the following areas:

* Are GM foods safe to eat?
* Would GM crops have an adverse effect on the environment?
* What would the introduction of GM crops mean for conventional and organic farming and for consumer choice?
* How would GM crops interact with future developments in UK agriculture and the rural economy?
* How will the implications of UK decisions be affected by decisions on commercial growing of GM crops in other countries?

2.4 For some people, there is also concern that the introduction of GM crops might lead to unforeseen and unintended consequences that are not even being considered as yet. These concerns might not be addressed by existing scientific evidence, and need to be considered as a factor in any assessment of costs and benefits. The SU will work with the public debate steering board and with the science review to seek to address these issues in a manner that is consistent with the precautionary principle.

The growing of GM crops and consumption of GM products in the UK

2.5 There is currently no commercial growing of GM crops in the UK. No GM crop has all the various regulatory approvals that are needed for commercial cultivation and marketing. Approval is required under the following legislation:

* European Union (EU) "Deliberate Release Directive" on the deliberate release into the environment of GMOs.
* Pesticides legislation (if the GM crop is a herbicide-tolerant variety).
* Domestic legislation on the introduction of new agricultural plant varieties (the ŒNational List‚ process).
* EU Novel Foods Regulation (258/97) for the associated food uses involving novel GM crops.

2.6 In addition, the Government has a voluntary agreement with the farming and industry body SCIMAC  that GM crops will not be grown commercially in the UK until the current programme of Farm Scale Evaluation (FSE) trials has been completed and the results assessed. The aim of the FSE trials is to evaluate the environmental impact of the herbicide use associated with GM herbicide-tolerant maize, beet and oilseed rape, relative to the weed control used with the equivalent conventional crops. The first FSE results will be published in the summer of 2003.

2.7 Any decision by the UK Government on the growing of GM crops will be made in the context of the EU legal framework. This creates a single market for the growing of GM crops in Europe and for the import of GM crops grown elsewhere for use as food, animal feed or in other products. The GMO concerned is individually assessed on the basis of the scientific evidence. If this risk assessment shows that any potential adverse effects of the GMO on human health or the environment can be avoided or appropriately managed, the product is allowed on to the EU market. It can then be used by anyone according to any conditions of use, including requirements for environmental monitoring.

2.8 So far, three GM crops have been approved for import and cultivation in the EU and three for import only.   Those approved for cultivation have not been grown widely: a total area of less than 0.1 million hectares of GM crops (mainly insect-resistant maize) has been grown commercially in Spain, Germany, France and Portugal. This contrasts with the 50 million plus hectares of GM crops grown commercially outside the EU  ˆ primarily in the Americas and China.

2.9 Data for 2001 reveal the extent to which GM crops are already widespread in the world outside Europe.  For example:

* GM soybeans accounted for 46% of the 72 million ha crop worldwide.
* GM maize accounted for 7% of the 140 million ha global maize area.
* GM cotton accounted for 20% of the 34 million ha global crop.
* GM canola  accounted for 11% of the global crop of 25 million ha.

2.10 The several years of experience in commercial growing of GM crops around the world should provide useful evidence that can be used in the SU study.

2.11 Commercial imports of GM soya and maize for food, feed or for processing (mainly from the US) have formed a significant part of the agricultural commodity trade with the EU since the mid-1990s. Animal feed and food ingredients based on this trade circulate widely on the EU market.

2.12 Recently updated generic EU rules require that all products consisting of or containing GMOs have to be labelled and accompanied by documentation enabling them to be traced through the production and distribution chain. Further EU proposals currently under negotiation seek to extend the traceability and labelling rules to food and feed and to products such as highly refined oils that are derived from GMOs but contain no detectable GM material. These proposals also seek to introduce a centralised procedure under the European Food Safety Authority for the authorisation of GM foods and animal feeds and to update current rules on labelling of GM foods, including the exemption for products containing technically unavoidable trace levels of GM material below 1%.
 

3. The public debate on GM crops

The framework for the public debate

3.1 A recently convened steering board ˆ independent of Government ˆ will oversee the public debate on issues raised by the genetic modification of agricultural crops. This is in line with recommendations made by the Agriculture and Environment Biotechnology Commission (AEBC) in its advice to Government.

3.2 The AEBC was set up by Government in June 2000. Its remit is to provide the UK Government and Devolved Administrations with independent strategic advice on developments in biotechnology that impact on agriculture and the environment, particularly their public acceptability and ethical and social implications.

3.3 In Autumn 2001, the AEBC published a report on the FSEs ("Crops on Trial"), in which it called for a public debate on the future of GM crops before any moves towards commercialisation.  The AEBC advised that this debate should seek to encourage public discussion and examination of GM issues.

3.4 Further to the publication of "Crops on Trial", Government  asked for more advice from the AEBC on how the public debate should be conducted. This further advice was published by the AEBC on 26th April 2002.  In her initial response on 31st May 2002, the Secretary of State for the Environment, Food and Rural Affairs, Margaret Beckett, announced that the Government would promote a "full and informed" public debate on GM issues.  This will precede the decisions the Government will later need to take on the possible commercialisation of the GM crops in the FSE trials.

3.5 In a more detailed response published on 26th July 2002, Government explained that it had accepted the AEBC recommendation for a steering board, independent of Government, to oversee the debate. Government has now invited Professor Malcolm Grant, the chairman of the AEBC, to appoint and chair this board, which met for the first time on 13th September.  Government has asked for a report on the debate in June 2003.

3.6 The SU project team will work closely with the public debate steering board, and will seek to develop a constructive two-way flow of information. The SU will provide regular reports to the steering board and the board will in turn provide views on the scope and content of the SU‚s work, including ways that it could usefully contribute to the wider debate. In addition, the SU will work with the steering board to ensure that appropriate information on the costs and benefits assessed in the SU study is available for use in focus groups and public events run as part of the wider public debate. This will help to ensure the open and transparent process to which the SU is committed.

3.7 In addition, the steering board will share with the SU (and with those overseeing the science review) the initial work commissioned for the public debate on reviewing what is already known about public attitudes to the possible commercialisation of GM crops in the UK, along with new focus group work with members of the public that will frame the issues for debate. This will help set the context for the SU study.

Supporting the public debate: the scientific review and the SU study of costs and benefits

3.8 Alongside the public debate and the SU study, there will be a review of the science of GM issues.  A prerequisite of a good quality public debate is that information is readily available, in a form which considers arguments both for and against, and which attempts to include relevant lessons learned (from other countries, previous similar examples, etc.). The SU study together with the science element of the debate will contribute this information to the wider public debate.

3.9 It will be important for the SU study to integrate with the science review. Many areas of debate ˆ such as the coexistence of GM and conventional agriculture, and environmental impact of different farming systems ˆ have both scientific and economic considerations. Regular communication will be necessary and the opportunity to contribute joint elements or to participate in joint events will be fully explored.
 

4. The approach of the SU review
Scenario analysis

4.1 The SU will take a forward-looking approach and will consider a range of scenarios for the possible development of GM crops in the UK during the next decade, including a "no GM" scenario. Hence the study will look at crops currently in trial and also at those in development that could be available within a ten-year timeframe. The scenarios will cover a range of values for the following key parameters:

* The extent to which GM crops may or may not be grown in the UK (e.g. total area of land that might be used for GM crops, and geographic dispersal of that land);

* The range of GM crops that may or may not be grown in the UK. This could change considerably over time, as new food and non-food crops are developed;

* The extent to which GM products may or may not be consumed in the UK (e.g. the range of different types of GM crops that might be used as ingredients in food and non-food products in the UK, or sold as food and non-food products in their own right);

4.2 The scenarios will also take into account possible variations in:

* The level of imports into the UK of GM agricultural commodities for use in food, animal feed and other non-food production;

* Possible changes to European and international law and regulation, such as EU labelling legislation and WTO rulings.
 

Categories of costs and benefits

4.3 The overall costs and benefits of GM crops will vary between these different scenarios, and will involve the following components (which are discussed further in the following section):

* The costs and benefits to the GM (food and other) products industry, including the agri-biotech sector, farmers, the food processing sector, the retail sector and consumers of GM products ˆ including the costs and benefits of segregating GM ingredients or product components from non-GM.

* The costs and benefits to the conventional (food and other) products industry, including the agri-biotech sector, seed producers, farmers, the food processing sector, the retail sector and consumers of conventional products ˆ including the costs and benefits of conventional products (e.g. animal meat) that rely significantly on GM materials in their production (e.g. GM soya in animal feed).

* The costs and benefits to the organic (food and other) products industry, including the agri-biotech sector, farmers, the food processing sector, the retail sector and consumers of organic products.

* Environmental costs and benefits, including impacts on biodiversity, soil pollution, water pollution and energy use.

* The costs and benefits to the wider biotechnology and pharmaceutical sectors, including any relating to the UK‚s overall reputation as a centre for excellence in scientific research.

* The costs and benefits to the wider rural economy, including impacts on agricultural support services, and any impacts on tourism.

4.4 These impacts will be assessed at UK and regional level, and attention will be paid to the impacts on the devolved administrations. Differing regional impacts can be expected as a result of variations in a number of factors, including:

* The types of farming and types of crop grown in different areas of the UK;
* The location of agri-biotech industry;
* The natural habitats and biodiversity found across the UK; and
* Levels and types of tourism.

4.5 In addition to these impacts, it will be important for the study to consider the wider international implications of decisions about GM taken by the UK and by the EU more generally. For example, it may be that if the commercialisation of GM crops is held back in the UK, research may focus on developing GM crops for agricultural conditions in countries where crops are grown, such as the Americas, China, etc. If this is the case, the UK may find itself unable to benefit from future developments in biotechnology. In contrast, if commercialisation takes place, any increase in costs to conventional or organic farmers ˆ for example through the need to prevent cross-pollination from GM crops ˆ could damage the international competitiveness of that sector and hence the UK‚s trade position. These international implications will be heavily influenced by decisions taken on the uptake of GM crops in other countries.

4.6 The study will also take a high-level overview of the costs and benefits of GM crops for developing countries. This will focus on the potential impact of decisions on commercialisation of GM crops taken by the UK (and in turn by the EU) on the ability of developing countries to make an informed choice about GM crops.

Issues being taken forward in other work

4.7 A number of issues relevant to the SU study are being addressed elsewhere. Although the SU study will draw on the relevant sources, it will not undertake new work in any of these areas:

* Evaluation of arguments from a purely scientific angle. This will be carried out by the science review running in parallel with the SU study, and the SU project team will incorporate data and information from that review into its own analysis.

* Issues purely concerned with food safety. The Food Standards Agency (FSA)  is the UK authority for evaluating GM foods under the EU Novel Food Regulation, and oversees safety assessment of GM foods by independent scientists. The FSA will be providing independent advice to the science review being carried out in parallel with the SU study, and the SU will draw on this advice where necessary. In addition, perceptions of the safety of GM foods will affect consumer demand, and this effect will be taken into account.

* Costs and benefits associated with approvals for research and laboratory GM crops grown in the UK (referred to as "contained use"). The Health and Safety Executive (HSE)  closely control the contained use of GMOs, and also enforce and monitor the environmental protection aspects of the relevant regulations. Establishments undertaking the initial laboratory research into potential applications for GMOs must notify HSE.

* Ethical considerations around GM research in general. These considerations seem likely to be raised in the context of the public debate being promoted by the independent steering board, and into which the SU study will feed.

4.8 In addition, it should be stressed that analysis of broader GM research, including genetically modified animals, is outside the scope of the SU study. However, any inter-relationship between the decision on commercialisation of GM crops and the further development of UK bioscience will be reviewed.
 

5. Initial views on the main areas where costs and benefits need to be assessed

5.1 The SU study will seek to draw on existing literature, expert advice and the experience of other countries to identify costs and benefits in each of the areas set out below.

Costs and benefits in GM product chains

5.2 If GM crops are grown commercially, this will create a product chain stretching from agri-business through the farmers growing GM crops (the "supply-side") and the processing and retail of GM products (the "market-place"), to the consumers purchasing GM products (the "demand-side").

5.3 There are currently no farmers growing GM crops on a commercial basis in the UK. But once the current voluntary agreement comes to an end, and if additional GM crops are approved in the future, farmers may choose to switch to GM for a number of reasons. These reasons will depend on the particular GM crop in question, but may include (see also paragraph 2.2):

* Increased yields;
* Reduced use of pesticides and herbicides, and hence fewer health risks and reduced costs;
* Reduced energy use, and hence reduced costs; and
* Increased convenience / time savings, leading to reduced labour and production costs.

5.4 These would have to be traded off against any cost increases, such as those arising from potentially higher seed prices. In addition, there may be costs associated with legislation on environmental liability. A new EU Environmental Liability Directive is currently being debated, and will almost certainly have implications for GM.

5.5 However, growers will only choose to produce GM crops if there is a demand for GM products. This will arise from consumers (both in the UK and abroad), and will be mediated through retailers. Consumers‚ decisions on whether or not to purchase goods incorporating GM products will be based on a trade-off between the perceived benefits of the goods (in terms of lower price, better quality, etc.) against any perceived risks. The way in which consumers assess this trade-off will depend crucially on the information they receive (e.g. via labelling).

Costs and benefits in conventional product chains

5.6 Developments in GM could have a number of impacts on conventional product chains. Goods using GM products would be close substitutes for goods based on "conventional" (non-GM) products, and would provide stiff competition if they could be produced at lower cost.

5.7 In addition, there could be a more direct cost to conventional (non-GM) farmers, arising from mixing of GM and non-GM material, either by seed being spilt or inadvertently mixed, or though cross-pollination between GM and non-GM crops. Where crops flower and produce pollen, and in the absence of protective or separation measures, cross-pollination can result in the transfer of GM material into neighbouring non-GM crops that are sexually compatible. If traceability and labelling rules (see above) are put in place, conventional (non-GM) farmers will be forced to ensure that the "contamination" of their crops stands at less than 1%.  Otherwise, their crops may have to be labelled "GM" and thus could face different demand and prices than otherwise would have been the case.  Measures to limit inadvertent mixing or cross-pollination, such as crop separation distances, may involve changes in existing farming practice and extra costs.

Costs and benefits in organic product chains

5.8 The impacts of GM crop commercialisation on the organic products industry will be similar to those on conventional product chains. In other words, GM products could substitute for organic products. And measures to limit GM cross-pollination, such as crop separation distances, may involve changes in existing farming practice and extra costs.

5.9 There is also considerable debate as to whether or not GM content is compatible with the "organic" label. Under EU rules it is possible to sell food as "organic" with an incidental GM presence, although organic certifying bodies may choose to apply stricter terms on their own members.  It is not for this study to analyse the definition of organic food, but a pertinent issue is the impact that trace GM content might have on demand for organic products, especially in relation to the potential for supplies of 100% GM-free organic food from countries where GM crops are not grown.

Costs and benefits to the environment

5.10 The commercialisation of GM crops could have a wide range of environmental impacts, in principal positive or negative, and these will vary according to the extent and scope of commercialisation. However, Government has made it clear that it will not allow the commercialisation of any GM crops that are expected to have a significant adverse impact on the environment. This means that in one sense, any scenario in which commercialisation occurs should by definition have no significant environmental costs.

5.11 The science review running in parallel with the SU study will consider the evidence on environmental impacts ˆ and the associated uncertainties. This scientific analysis will act as an important input to the SU study, which will attempt to put values where possible on the environmental impacts that may arise. In the longer term, the FSEs will add to the pool of knowledge by enabling analysis of the effect, if any, that the management practices associated specifically with GM herbicide-tolerant (GMHT) crops might have on farmland wildlife, when compared with weed control used with non-GM crops.

5.12 More generally, and notwithstanding these uncertainties, a number of environmental benefits could arise and will need to be taken into account. These may include:

* Improvements in biodiversity from reduced pesticide and herbicide use;
* Reduced soil and water pollution from reduced (and differently timed) pesticide and herbicide use;
* Reduced soil erosion from a different approach to weed removal; and
* Reduced emissions of air pollutants from lower energy use.

5.13 At the same time, it will be important to take into account the range of environmental costs that could in principle arise, and that will be assessed in the science review and in any Government decisions on GM crop commercialisation. These may include:

* Loss of biodiversity as insect-resistant crops reduce populations of insects used as food by birds and small mammals;
* Loss of biodiversity from changing farm practices;
* Changes to the ecological balance of the soil; and
* Cross-pollination, potentially introducing (for example) herbicide tolerance to wild plants.

Costs and benefits in the biotechnology sector and associated industries

5.14 The UK has a strong record of academic and commercial science. The UK has just 1% of the world‚s population, but funds 4.5% of the world‚s science, produces 8% of the scientific papers and receives 9% of the citations.  A study carried out by London Economics for Monsanto in 2000 estimates the biotech sector‚s contribution to UK GDP at about 1%.

5.15 GM crop research and development is carried out by the agricultural (or agrochemical) biotechnology sector. In contrast to the wider pharmaceutical sector, this industry has been in decline in the UK for the last 20 years. Since 1980, the number of R&D posts in the agrochemical and biotechnology sector in the UK has decreased by over 60%. The largest annual decrease was between 1999 and 2000. No agrochemical company today has its headquarters in the UK, and there is only commercial one major research facility remaining (Syngenta in Berkshire).  Research facilities are now concentrated in the US, though Germany and France have also overtaken the UK.

5.16 The commercialisation of GM crops in the UK may boost the agricultural biotechnology sector in the UK, by encouraging GM-related research. It is also possible that this will have spin-off benefits for the wider biotechnology industry, and for academic research. Also, it is possible that the UK‚s reputation as a centre for scientific excellence could suffer if it seeks to restrict the commercialisation of GM crops in a manner inconsistent with the scientific evidence.

5.17 An alternative argument would state that Government decisions on commercialisation of GM crops could have limited impact on company decisions about where to locate research facilities. This might be especially likely if those research facilities are working on GM crops likely to be grown primarily outside the UK. Taking this perspective, the reason for the recent closures in the agrochemical and biotechnology sector would have to lie elsewhere ˆ for example in industry consolidation, changes of ownership and the possibility that the UK‚s competitive advantage in scientific research may simply lie elsewhere.

Costs and benefits in the wider rural economy

5.18 There are at least three routes by which the wider rural economy may be affected. The first of these is through the effect that GM crops will have on farm economics, which will have an indirect effect ˆ potentially positive or negative ˆ on the sustainability of the rural economy. The second is through the impacts on the agricultural products and services industries. And the third is through any impacts that GM crops could have on the perceived reputation and attractiveness of the environment for tourists ˆ either positive (e.g. through reduced pesticide use) or negative (e.g. through concerns about health impacts).

Implications of UK and EU policy for GM crops in developing countries

5.19 The overall costs and benefits of GM crops in the UK may also include impacts on other ˆ particularly developing ˆ countries‚ ability to produce or consume GM crops. The decision on whether to produce or consume GM crops is a matter for individual countries and will depend on a range of specific costs and benefits. This study will explore whether their ability to decide is affected by UK (and EU) policy.

5.20 Food security is a complex issue of major concern across developing countries. Agricultural biotechnology, including GM crops, may not represent a Œsilver bullet‚, but this technology does have the potential to improve agricultural production which is a component of the broader challenge of food security.

5.21 GM crops could enhance food nutritional value and increase agricultural productivity in a range of environments including those susceptible to drought and low soil fertility. This could improve farm and off-farm incomes, reduce the health risks associated with pesticide use ˆ where relevant ˆ and help preserve existing biodiversity through reducing the expansion of agricultural land. However, as in the developed world, there are concerns about environmental impact and food safety ˆ for example with regard to the effectiveness of the regulatory regimes for the technology.

5.22 The use of GM crops in developing countries has so far been concentrated in a few countries with relatively large domestic agricultural markets. The extent to which they can be part of the solution elsewhere will depend on whether developing countries can:

* Access the technology to develop locally adapted cultivars, either directly or through International Agricultural Research centres;
* Diffuse them to both large-scale and resource-poor farmers; and
* Develop an enabling environment of institutions and policy, especially in the context of international environmental and biosafety protocols.

5.23 The SU study will consider these issues as background to put into context the potential impacts of UK (and by extension, EU) GM policy on developing countries. These impacts are envisaged to work through a number of different routes, including:

* Technology transfer and aid from the UK to developing countries;
* Impacts on competitiveness of DETE agricultural products (GM and otherwise) in international markets;
* Signalling of attitudes to GM.

5.24 The approach taken in the study will be to categorise developing countries according to their capacity to take up and use GM crops. The study will then consider the main impacts on the ability of each of these different categories to make an informed decision on GM crops. The main focus of the study will then explore the differential impacts of decisions taken in the UK (and EU) on this ability.
 

6. Project outputs and organisation

6.1 The final report from the SU study will be an analytical report presented as a contribution to the debate. It will not seek to draw conclusions about Government policy. We expect to invite comments on the final report.

6.2 The Sponsor Minister for the study will be Margaret Beckett, Secretary of State for the Environment at DEFRA. The Sponsor Minister will provide oversight and guidance on the study. In addition to the governance provided by the Sponsor Minister, the SU team will also provide regular reports to the steering board for the wider public debate on GM issues. And the SU will work with relevant Departments in taking forward the project. This will include the Devolved Administrations.

6.3 Further advice to the SU study will be provided by a series of Expert Groups, each of which will be attached to a specific analytical workstream within the project. Membership of the Expert Groups will be determined early on in the course of the project, in consultation with the public debate and science strands of the work on GM issues.

6.4 As the workstreams are scoped, the team will also keep under review the need to commission further work as required, from other Government Departments and from external UK and international experts.

6.5 Timelines and tasks will be kept under review throughout the course of the project, and amended as necessary. The major milestones currently envisaged are as follows:

* 25th September 2002: Scoping note published on SU website and sent directly to key stakeholders;

* 25th October 2002: Deadline for responses to the scoping note;

* End-November 2002: Interim workstream papers published in draft on the SU website and sent directly to key stakeholders, alongside responses to the scoping paper. The interim workstream papers will set out the information that has been gathered by the SU project team at that stage, and will propose a methodology for analysing costs and benefits. Submissions on the interim workstream papers will be invited;

* January 2003: Deadline for comments on interim workstream papers;

* Early February 2003: Summary of comments on interim workstream papers published on website, alongside update on work in progress;

* Spring 2003: SU report published as a contribution to the public debate, and comments invited.

6.6 This timetable will be kept under review throughout the course of the project, and any changes will be highlighted on the SU website.
 

7. Invitation to submit views on initial questions

7.1 The SU is committed to an open and transparent process that takes on board all sources of information and a full range of views. As part of this process, we especially welcome views on the following questions:

7.1.1 Do you agree with the broad categories of costs and benefits identified in this report? Are there any additional categories that could be usefully considered, while remaining within the overall remit of the study?

7.1.2 What do you expect the main costs and benefits to be within each of the overall categories:

GM product chains;
Conventional product chains;
Organic product chains;
The environment;
The biotechnology sector and associated industries;
The rural economy;
Developing, Emerging and Transition Economies (DETEs)?

7.1.3 What information do you have that would enable SU to quantify these costs and benefits? Do you know of any other sources of information that should be explored?

7.1.4 How would you weight each of the categories of costs and benefits identified in the report?

7.1.5 What do you see as the major uncertainties that will need to be dealt with in the study? How should these be addressed in an assessment of costs and benefits?
 

8. Contact details

8.1 Please send responses to the questions and issues raised in this note by post or email to:

GM Crops Team
Prime Minister‚s Strategy Unit
Cabinet Office
4th Floor Admiralty Arch
The Mall
London
SW1A 2WH

GMCrops@cabinet-office.x.gsi.gov.uk

8.2 In order for the SU team to be able to take submissions fully into account, responses should be sent to arrive in SU by 5.00pm on Friday 25th October 2002. All submissions will be published on the SU website. There will be further opportunities to comment on the work of the SU team during the course of the study.

8.3 The postal address and email address listed above may also be used for general questions relating to the study.

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