London, United Kingdom
May 3, 2007
Managing the Footprint of
Agriculture: Towards a Comparative Assessment of Risks and
Benefits for Novel Agricultural Systems
Report of the
ACRE Sub-Group on Wider
Issues raised by the Farm-Scale Evaluations of Herbicide
Tolerant GM Crops
Revised after public consultation
3 May 2007
Summary
This report has been drawn up by a
sub-group of the Advisory Committee on Releases to the
Environment (ACRE) in response to requests by the Secretary of
State and the Agriculture and Environment Biotechnology
Commission to assess the wider implications of the Farm-Scale
Evaluations (FSEs) of genetically modified herbicide tolerant
(GMHT) crops. ACRE’s remit is currently limited to GMOs and the
release of certain non-GM species of plants and animals that are
not native to the UK. However, this report is based on the
experience gained by ACRE in reviewing the findings of the FSEs,
on the deliberations of the ACRE sub-group established to
examine the wider implications of this study, and on evidence
submitted by a variety of stakeholders to an open meeting held
in October 2004.
A draft version of this report was sent to a wide range of
stakeholders for consultation on 17th March 2006, the
consultation period ended 9th June 2006. The report has now been
revised to take into consideration the evidence submitted in
consultation responses. A document published alongside this
report1 details the responses made during the consultation
period and the revisions made to the report.
In recent years, it has become apparent that there are
inconsistencies in the regulatory assessment of the
environmental impact of GM crops in comparison with other
agricultural crops and practices. The EU Directive 2001/18,
which covers the release of genetically modified organisms,
requires an environmental risk assessment of possible immediate
and/or delayed, direct and indirect environmental impacts of the
specific cultivation, management and harvesting techniques used
for the GM plant as part of a rigorous approval process. Non-GM
crops and other changes to agricultural management do not
require similar risk assessments.
Quantitative field studies have shown that the environmental
impact of changes in agricultural management can be at least as
significant as those associated with GM crops. Examples include
the change from spring to winter sowing in arable crops and the
shift from hay cutting to silage production. There is, however,
currently no equivalent regulatory requirement for assessment of
the positive and negative effects of such changes in
agricultural practice on the environment prior to their
widespread adoption.
This inconsistency is further illustrated by GM herbicide
tolerant crops that require an extensive environmental risk
assessment before approval for cultivation and marketing whilst
herbicide tolerant crops produced by non-GM breeding methods can
be grown without an equivalent assessment. The FSEs showed that
differences in the impact on wild flora and fauna can be greater
between different conventional crops (e.g. between maize and
oilseed rape) than between a GM herbicide tolerant crop and its
non-GM herbicide susceptible counterpart. Directive 2001/18,
however, requires that the environmental impact of a GM crop is
solely judged in comparison with the impact of its non-GM
counterpart.
Directive 2001/18 also makes no provision for assessing both
potential environmental risks and benefits. For example, the
negative effects on weed and invertebrate populations of the
herbicide treatment used in the FSEs with GM herbicide tolerant
beet was a key factor in the decision not to permit the
cultivation of GMHT beet as managed in the FSEs. As the
Directive only considers risks, evidence of any potential
environmental benefits (such as reduced herbicide use leading to
reductions in direct and indirect CO2 emissions arising from
herbicide manufacture, transport and field operations) were not
considered.
By contrast, environmental benefits are now a major focus in the
introduction of a number of other novel crops (e.g. energy
crops) and agricultural management practices in the UK. There is
no regulatory requirement to assess potential environmental
costs in a fashion similar to GM crops. Environmental benefits
(or side-effects) are also the focus of the most recent round of
EU and national agricultural policy reforms, which now focus on
the multifunctional nature of agricultural systems, and their
capacity to contribute to a wide variety of environmental goods
and services in addition to food, fibre, oil and other primary
products. Under new policies, and some emerging private markets,
farmers will increasingly be paid to produce these environmental
goods and services (such as flood protection, carbon
sequestration, landscape aesthetics, and biodiversity services),
as well as to continue to produce food.
It is possible to conceive of transitions towards environmental
sustainability as arising partly from systems of management that
minimise the negative side-effects of agriculture (environmental
costs) whilst maximising positive side-effects (environmental
goods). Thus, understanding and balancing the potential risks
and benefits of existing and new agricultural technologies
(whether GM or non-GM) should be part of the UK’s current
support for the goal of greater environmental sustainability in
all its agricultural and land management systems. The wider
challenge is to achieve such changes whilst sustaining the
economic viability of farming. It is commonly stated that the
farming industry only contributes a relatively small amount to
GDP, yet this contribution rises substantially if all
environmental goods and services are counted alongside primary
food production.
To assess and manage more effectively the environmental
footprint of agriculture as a whole, ACRE suggests that a
broader and more balanced regulatory approach is required. This
approach would deal not only with GM crops but also with other
novel crops and agricultural practices. It would allow the
assessment of both environmental risks and benefits, and the
development of rigorous and balanced decisions.
The purpose of this report is to serve as a catalyst for debate
about the future development and regulation of novel
agricultural technologies and practices, and it is hoped that a
number of agencies would find some utility in adopting the
approach described. The report is primarily aimed at Ministers,
policy makers and regulators in Defra, in the devolved
administrations and across the EU.
ACRE concluded that the following principles should be used to
guide future assessment of novel agricultural products and
practices. An effective approach should:
- take account of benefits
as well as risks,
- be evidence based,
- recognise that an
opportunity will often be needed to assess the impact of
novel crops and practices on a limited scale, before
widespread use,
- be based on comparative
assessment with current crops and practices,
- protect and nurture
opportunities for innovation and therefore choice of
comparator should take care to avoid the rejection of novel
crops and practices while retaining more damaging
established crops and practices,
- be straightforward to
apply,
- be sensitive to the
competitiveness of all sectors of UK agriculture.
ACRE proposes a matrix-based
approach in the form of a Comparative Sustainability Assessment
(CSA) that could be used to encourage a more objective and
comprehensive approach towards agricultural and rural policy.
The CSA presented in this report has been revised in response to
comments made during the consultation.
The revised CSA contains ten criteria for assessing
sustainability, benefits and risks. None of these criteria have
precedence, and all factors will be assessed and evaluated in
order to come to a judgement.
This report contains seven worked examples to illustrate how the
CSA might be used in practice. The examples were chosen to cover
a broad range and include GM as well as non-GM examples.
Although the focus of this report is on novel crops, animals and
practices, examples of past introductions are included here to
show their impact. The examples are:
- Japanese Knotweed as
an example of the past introduction of an ornamental
plant;
- Winter wheat as an
example of the past expansion of a crop/practice;
- Biocontrol of the
European corn borer with Trichogramma as an example of
the past introduction of a new practice (compared with
two alternative control methods, insecticides and Bt
maize);
- The energy crop
Miscanthus as an example of a recently introduced crop;
- Bt cotton as an
example of a novel insect resistant GM crop;
- A comparison of
herbicide tolerant amenity grasses developed through GM
or conventional means – an example of a potential future
introduction;
- American mink as an
example of the past introduction of a non-native mammal.
The worked examples are a synopsis
of the evidence that would be considered in a full CSA analysis,
and illustrate that there are positive and negative side-effects
in each case. These examples show that the introduction of
ornamental plants and non-native mammals could have significant
negative effects; that changes in agricultural practice can have
major environmental impacts and that breeding methods are less
important than the nature of the trait expressed by a novel
crop. The worked examples highlight some areas of uncertainty
and areas of further research, which would be required for the
development and use of the CSA.
When defining the scope of ‘novel crop’ and ‘novel practice’, to
which a CSA should be applied, regulators will have to take into
account not only the change, but also the potential scale of
introduction and what it is expected to replace.
The report considered important factors to take into account
regarding implementation of the suggested approach but its role
was not to provide a detailed guide.
In the short-term ACRE envisages that CSAs and currently
available supporting evidence could be used in the development
or pre-assessment of government schemes to encourage
environmental benefits or the use of novel crops (e.g.
mitigation measures used in Environmental Stewardship schemes,
incentive schemes for biofuels).
In the long-term ACRE envisages CSAs and the comprehensive
evidence supporting them to be used to inform the workings of an
advisory committee. CSAs would enable the committee to advise
policy makers about the balance between negative and positive
impacts of a proposed introduction, allowing policy makers to
base their decision on all relevant evidence.
By taking into account the overall benefits associated with a
new product or practice in comparison with currently available
systems, ACRE’s proposals are designed to encourage innovations
that can assist government commitments for sustainable
agriculture. ACRE does not envisage the CSA to be used at the
level of the individual farm, thus ensuring that the direct
regulatory burden on farmers is not increased. The Committee
recommends that any decisions based on the CSAs should be
reversible in the light of any new evidence.
All EU Directives are subject to revision over time and in the
long-term ACRE believes that the CSA method could be
accommodated within European legislation concerning the release
of genetically modified organisms. At present applicants wishing
to release GMOs are not required to submit any
v
information on the benefits associated with the use of the GM
products. However this information is important in order to
determine whether the overall impact of a GM and its management
is worse than that of equivalent products in current use. ACRE
stresses that a revision of this nature would not represent a
“softening” of the current regulatory regime with respect to
GMOs.
ACRE notes that before implementing regulation (either by formal
legislation, codes of practice or information campaigns)
government departments are required to carry out a regulatory
impact assessment2 (RIA). An RIA is a framework for analysis of
the likely impacts of a policy change and the range of options
for implementing it. These assessments cover the impact of
regulation on social, economic and environmental sustainability.
Under the current system environmental considerations are
assessed using monetary value based on consumer willingness to
pay or willingness to accept compensation for environmental
damage. ACRE suggests that the CSA method presented in this
report could provide a useful alternative to the approaches
currently used in these assessments as a mechanism for achieving
environmental policy goals and ensuring more consistent
regulation with respect to the environment.
This revised report was approved by ACRE in December 2006.
1 Overview of Responses available
at
www.defra.gov.uk/acre/fsewiderissues/
Full report:
http://www.defra.gov.uk/environment/acre/fsewiderissues/pdf/acre-wi-final.pdf
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