ngin - Norfolk Genetic Information Network
23 October 2002


Thanks to The Corner House for this critique of the overall theme of 'costs and benefits' in the UK Government's Scoping Note which forms part of the Government's Public Consultation on GM crop commercialisation.

Comments need to be with the Prime Minister's Strategy Unit by this Friday. 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**

To read the full txt of the Scoping Note:

Comments on the Scoping Note from:
Five Year Freeze
Munlochy Vigil:
Cost-Benefit, NGOs and the Government's Public Consultation on GMOs
comment by Larry Lohmann, The Corner House, 16 October 2002,

The Prime Minister's Strategy Unit's Scoping Note on "The Costs and Benefits of Genetically Modified (GM) Crops" is confused about what the function of the SU study is to be. It vacillates between two sharply-conflicting interpretations of "costs and benefits".

On the one hand, "costs and benefits" appears merely to be a loose metaphor for a collection of views on the positive, negative and unknown or unknowable consequences of growing GM crops in the UK. On this interpretation, the point of the SU study would presumably be to help increase awareness of the range and depth of these consequences, without attempting to compare them with each other quantitatively or necessarily point toward a conclusion about whether GM crops should be grown in the UK. Indeed, the acknowledgement on p. 6 that the "introduction of GM crops might lead to unforeseen and unintended consequences" and that there is a need to "address these issues in a manner that is consistent with the precautionary principle" suggests that the possible consequences, while they might be clarified, cannot be aggregated in actual cost-benefit terms. Similarly, if, as p. 14 states, "any scenario in which commercialisation [of GM crops] occurs should by definition have no significant environmental costs", then there will be little point in attempting to quantify those costs other than to establish that they are not zero.

On the other hand, the notion expressed on p. 19 that the SU is somehow to "quantify these costs and benefits" and "weight each of the categories of costs and benefits identified in the report" suggests that the SU is not talking in metaphors when it uses the words "costs and benefits". If this interpretation is to be followed, then the SU's work will not be compatible with the precautionary principle (which does not consort well with cost-benefit analysis), nor with serious respect for the uncertainties of "unforeseen and unintended consequences", nor with the government's commitment to commercial GM cropping's having no significant environmental costs (p. 14). On this interpretation, the SU review is likely, rather, to misrepresent the discussions that the SU facilitates as quantitative measurements of agreed-upon states of affairs which, when aggregated, point toward a conclusion. This would increase enormously the political power in the debate of whoever elicits, performs or aggregates these "measurements" (presumably unnamed individuals in the SU itself or the technical experts it enlists). As the historical record of cost-benefit analysis has shown, the result is less likely to facilitate than to polarize and make more difficult the "open and transparent" public debate into which the SU review is intended to feed (pp. 3, 9).[1]

The well-argued NGO attempt to "reframe the GMO debate in a development context" by emphasizing questions of power, rights, food security, precaution, exploitation and the historical realities of particular groups of poor people would be seriously compromised by any attempt to fit it into an SU study guided by this second interpretation of "costs and benefits". Clarifying or challenging the Scoping Note's framework should thus be one part of NGO efforts to reframe the GMO debate envisaged by the government.

1 See Corner House, "Whose Voice Is Speaking? Cost-Benefit Analysis, Opinion Polling, and Public Relations", 1998,

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