ngin - Norfolk Genetic Information Network

17 October 2002


For NGIN's comments and the Scoping Note in full:
Five Year Freeze

GM Public Debate

Briefing (1):
The economics review

When the Government announced their intention to implement a public debate on the commercialisation of GM crops in the UK, they also announced plans for two simultaneous pieces of work, a review of the science and a review of the economics.

While the 'public debate' element will hopefully offer clear opportunities for members of the public to debate the issues, the other two strands need equally to engage and involve members of the public and stakeholder organisations. The public debate strand has been set up under the guidance of the AEBC in an open and transparent manner - the steering board, on which the Freeze sits, meets in public and minutes etc will be posted on the website.  However it is already clear that the economics and science strands are unlikely to work in such an open and accountable way.  This will fail to inspire public confidence and will be to the detriment of the entire process.

To this end we would like to encourage Freeze supporters to comment on and engage with all elements of the process wherever possible.  It is important that the entire process is monitored and scrutinised, and that the Government is aware of this.

The economics review is being carried out by the Prime Minister's Strategy Unit, although the Minister responsible for the study is Margaret Beckett, Minister for the Environment.  The objectives of the study are:

"to assess the full range of costs and benefits associated with the commercial growing of GM crops in the UK, including the effect on conventional and organic farming interests."

The Strategy Unit has published an initial scoping note, 'The Costs and Benefits of GM Crops', which can be downloaded at:

A hard copy is available from the Freeze office (tel: 0207 837 0642 or email

The Strategy Unit is inviting comments on the initial scoping note, and we encourage all Freeze supporters to respond however briefly this may be.  We are disappointed with the document, as it fails to address the unique nature of the problems and risks presented by GM crops.

Although the Strategy Unit is posing a set of questions to be answered by way of a response to the document, it is not necessary to be constrained by these and we suggest a letter outlining your concerns will be a sufficient response.  We have outlined some of the key criticisms below to help with this. Contact details of where to send responses and who to copy them to follow.

Points to include:

* Openness and transparency: the strategy unit should operate with similar attention to openness, transparency and public involvement as is being given to the public debate strand.

* Methodology: conventional 'cost-benefit' analysis is limited in its ability to allow for unknowns and to accommodate successfully issues that can not easily be quantified in economic terms.  With GM crops, for example, it is impossible to adequately assess the risk of the environmental impact of gene flow and to put a monetary value on this potential 'cost'.  The methodology also fails to allow for the wider social and economic implications that can arise further down the line.  Comparisons can be made with cost-benefit analysis of nuclear power in the 70's which failed to allow for the implications of waste disposal etc.  The Strategy Unit should employ a more robust and comprehensive methodology which acknowledges the limitations of risk assessments and covers unknowns.

* Framing of the study: plans for the 'public debate' emphasised the importance of involving the public in framing the issues for debate - and this is also critical in this work in order to secure widespread confidence in the process.  The workshops in which members of the public will frame issues to be covered by the debate should also be used to frame this study.

* Benefits and costs: the benefits outlined in the document (sections 2.2 and 5.3) are assumed to be achievable while in reality they are so far merely speculative, and in the case of section 5.3 and increased yields etc., unproven. There is an obvious lack of balance between this and the 'costs' section (2.3), illustrating the emphasis of the study (skewed towards supposed benefits rather than risks and costs).  This section diminishes real risks substantiated by increasing evidence to little more than 'public concerns'.

* Sustainable development: the study must be set in the context of the Government's commitment to sustainable development.   Costs and benefits of GM crops must be measured against the indicators for sustainable development which now underpin Government policy making.  Many of the 'benefits' outlined in section 2.2 can be achieved through other more acceptable methods and comparative analysis of these should be included.

* 'No GM option': this must be given greater prominence in the scenario setting.  The scoping note tends towards the assumption that GM is a given in both the UK and internationally.  However the market would suggest that this is not necessarily the case. The competitive advantage to be gained from the UK remaining GM free should be fully explored.

* Food Safety: there is a complete absence of consideration of potential impacts on human health from the creation of new allergens or toxins etc. Although supposed health 'benefits' from nutritionally enhanced foods are included, there is no acknowledgement of the costs incurred from potential food safety issues.  Conventional risk assessments are unable to predict all eventualities.

* Consumer choice: consumers do not behave merely as economic actors - many fluctuating factors influence consumer choice and this must be more clearly recognised in the study.

* Developing countries: the study includes looking at the impact of UK choices on developing countries.  This is a complex area and the implications of UK decisions are only a small factor.  The purpose of the current study is to look at the implications of commercialisation of GM crops in the UK, and should therefore be confined to this.

* Omissions: many critical issues are either absent entirely from the scoping note or are given less prominence than they deserve:
* Significance of international agreements such as WTO, Cartagena Protocol etc.
* The impact of industry consolidation and concentration of ownership of seed companies etc.
* Ownership of intellectual property through patents on genes, plants, seeds.
* Lack of an adequate liability regime which recognises socio-economic and environmental damage

Send comments to:

GM Crops Team
Prime Minister's Strategy Unit
Cabinet Office
4th Floor Admiralty Arch
The Mall

**Deadline: 5.00pm Friday 25th October**

Send a copy to Malcolm Grant, chair of the AEBC and the Public Debate Steering Board.  It is important that the Steering Board is aware of the views of NGOs and members of the public.

Professor Malcolm Grant
Agriculture and Environment Biotechnology Commission
Bay 479
1 Victoria Street

and finally.. send the Freeze a copy!

For more information please contact
Rachel Sutton
Five Year Freeze,
94 White Lion Street, London N1 9PF
Tel: 0207 837 0642; Fax: 0207 837 1141;

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