May 2004

In addition to our oral evidence session of May 17th,  2004 there were a few matters on which the committee had requested we provide further evidence and one or two areas that we felt supplementary data was required to clarify points we had made. In this regard please find abc’s supplementary evidence below.

Regarding adventitious presence:

As mentioned by Dr Colin Merritt, abc feel that the current legal threshold of 0.9% for adventitious presence of GM will prove workable in most situations, based on scientific evidence, and observed adventitious presence levels seen around.  Additionally, the SCIMAC code adhered to during the FSEs ensured that adventitious presence was not a problem during the FSEs, and a similar code will prove equally effective once GM crops are commercial in the UK. 

We would also reiterate that this threshold is about choice and not about safety.   Some sectors of the industry have hijacked this threshold and seek to exploit it or a self-imposed ‘lower level’ predominantly for marketing reasons not supported by science. 

Dr Merritt referred to a report by the Union of Concerned Scientists that indicates that even in the USA, where levels of GM crops are considerable and activity to avoid adventitious presence is less robust that what is proposed for the UK levels of adventitious presence are zero in many cases and generally well below EU thresholds on those occasions when adventitious level can be detected. 

To substantiate this data we submit the following data available at http://www.ucsusa.org/food_and_environment/biotechnology/page.cfm?pageID=1315

Table 2-2 shows the results from various tests done by Genescan, one of the most experienced GM testing companies, where they looked for adventitious presence of GM seeds in non-GM seed in the USA.  It indicates that 50% of non-GM maize samples tested were GM-free and that the 50% that showed a GM level were less than 0.1%.  Similarly the soybean tests indicated 50% of samples to be GM-free while the remaining 50% were below 0.05%, almost 20 fold below the legal threshold imposed by the EU.

However, as we pointed out there are discrepancies, with other tests within the report, that show slightly higher levels, further emphasising the essential need for standardised methods of GM detection.  Luckily the EU has anticipated this concern and developed a ring of labs under the Joint Research Council that will be responsible for providing standardised testing for levels of GM presence within the EU.

Regarding acceptance of GM amongst UK farmers:

The National Farm Research Unit has been surveying farmers regarding their attitudes toward growing GM crops in the UK every moth since October 2000. While naturally there has been a little variation in attitudes in any given month, often reflecting the news of the moment, the accumulated figures from over 22,000 farmer responses spanning four years indicate;

·        45% of UK farmers are unequivocally in favor of growing GM crops in the UK

·        21% are in favor of growing GM crops but have some understandable qualifications such as waiting for more market acceptance

·        27% don’t know

·        8% are opposed

It is interesting to note that while figures naturally fluctuate the percentage of farmers opposed to growing GM crops in the UK has never risen beyond 13% and when considering the emotion this debate has raised on occasion, such a low figure of opposition really becomes an overwhelming endorsement.

The full results of these surveys including the latest figures can be found at http://www.monsanto.co.uk

Regarding the wider economic impact of GM crops and therefore loss (opportunity cost) if not allowed in the UK market:

While the committee was aware of the Strategy Unit broad findings that recognised that, although economic benefits to the UK are likely to be limited in the short term, this was largely due to the relatively minor status in the UK of the crops currently being considered and would increase considerably once traits and crops more specifically suited for the UK were available.  It is worth noting the “limitation” of benefit they identified was due to potential lack of market and public perception, not that the intrinsic economic benefit of the crop was low. 

The Strategy Unit recognized that the current GM crops being considered for the UK would contribute £50 million per annum to the UK as a whole. This represents a critical and significant financial benefit to individuals and groups of farmers at a time when rural incomes have been at a historical low and provide the supporting data for their conclusion that existing GM crops offer “cost and convenience advantages” to UK farmers.

In other world areas the economic impact is truly vast, but this is not surprising. Currently 8 million businessmen and women (who happen to be farmers) have voluntarily decide to adopt GM crops and grow them on a collective area of 67.7 million hectares in 2003 representing a 15% increase on 2002, with a similar increase expected in 2004.  abc believe that 8 million people voluntarily choosing this technology is the most graphic evidence that this technology offers those individuals significant direct and indirect economic benefits.

Several studies have looked at quantifying the economic benefit to farmers, many of which such as more targeted chemical use, has secondary environmental benefits that are difficult to place a pound value on. Some of these reports and their main conclusion follow.

·     The National Center for Food and Agricultural Policy (NCFAP) studied nine crops currently in development for the EU market and concluded that crops developed through biotechnology could help European farmers reap an additional 8.5 billion kilograms of food and improve farm income over €1.6 billion while using 14.4 million fewer kilograms of pesticide. http://www.ncfap.org

·     The introduction genetically modified herbicide tolerant (GMHT) sugar beet will provide average economic benefits of £154 per hectare to UK beet producing farmers (May 2003)

·     10% of UK GDP and 1.75 million people are employed by industrial sectors, which rely on biotechnology applications. Nawaz 2003.

·     Biotechnology is extremely important to the EU, its own estimates place its value at €100 billion for the EU by 2005, (European Commission, 2002).

·     Economic modeling forecasts predict that the worldwide adoption of genetically modified crops could boost the overall income of all regions by $316 billion by 2015. (Australian Bureau of Agricultural Resource Economics (ABARE) Foster, 2003).

·     The introduction of GM-oilseed rape to Canada has increased farmer and the supply chain earning of up to $250 million and $215 million a year, respectively. The Canadian Canola Council estimates that GM oilseed rape farmers spray 6000 tonnes less herbicide and use 31 million litres less diesel a year (Canola Council of Canada, 2001).

·     The eight-biotech crops grown commercially in the US increased saved growers $1.5 billion in 2001. Extrapolated analysis of 32 biotech crops under development but approaching commercialization indicated that, if adopted, they would contribute an additional $400 million per year to grower savings (Gianessi et al, 2002).

We must consider the opportunity impact in the UK if the rest of the world moves forward with more environmentally friendly and also more economically viable agriculture and UK farmers are denied this option.   

A recent report from Australia, referred to by Dr Merritt in his evidence session concluded,  "Some stakeholders who represent groups that might be adversely affected by the release of GM canola for commercial production argued before me that the existence of these negative effects on other stakeholders alone implies that the release should not be permitted. This argument is inadequate, as it takes no account of potential benefits and ways of reducing risks. A denial of a commercial release would impose costs on those seeking to grow GM canola in just the same way, as the release would impose costs on other stakeholders." http://www.vic.gov.au/VictoriaOnline?action=content&id=328&pageName=Latest&pageTitle=Latest

Regarding ‘legal prosecution’ of farmers:

Concerns were raised in our evidence session about high profile cases where the industry was involved in legal disputes with farmers. It is a NGO provoked misconception that the industry is suing farmers that accidentally receive or grow any GM crops at all and that the industry pursues any individual that is found to have ‘one GM plant within his farm boarders’. This is simply not true.  No legal prosecution by the industry has been initiated against a farmer that had adventitiously grown GM seed.  It is not Industry’s intention to ever prosecute farmers that have adventitious of GM crops on their farms.

The few high profile cases that have occurred have been initiated against farmers that have grown entire fields of very high purity GM crops. In these rare cases industry needs help create a level playing field for all farmers.  It would be unfair for 99% of farmers actively growing a GM crop to be paying companies a technology fee for the cost and time benefit of growing a GM crop, only to be out competed by their neighbor that is receiving the same costs and time benefit, without paying a technology fee to the company that spent decades and tens of millions of dollars developing the technology.

These rare cases are not about controlling farmers or patenting life. They are about protection of legal property.  In the most high profile of these cases between Monsanto and Schmeiser. Mr Schmeiser lost the initial action, as well as two further appeals that culminated in defeat again last week, in the Canadian Supreme Court.

Finally as always we would be most willing to provide further evidence or data as and when required by the Committee.

For further information please contact:
abc
PO Box 30791
London WC2N 4DF
Tel: 020 7395 8944
enquiries@abcinformation.org