Berlaymont, Brussels, Belgium
November 28, 2007
The
European Federation of Biotechnology handed over the
following letter to the Cabinet of Environment Commissioner
Dimas:
Mr Stavros Dimas
Commissioner for the Environment
European Commission
Rue de la Loi 200
1040 Brussels
Belgium
Brussels, 28 November 2007
Dear Commissioner Dimas,
The European Federation of Biotechnology, EFB, is very
concerned to read about your draft decisions to reject two
Bt maize product submissions based on discredited scientific
arguments that have not been reviewed by your own
independent scientific body, the European Food Safety
Authority.
We consider that the draft decisions do not have a
scientific basis and seem to be made without considering the
consequences for Europe or the fact that similar varieties
have been growing in Europe for the past 9 years with high
adoption rates with no adverse environmental effects and in
coexistence with conventional and organic farming.
Concerning the scientific studies contained in your draft
decisions, that claim to demonstrate environmental risks
presented by Bt maize, nine out of the eleven publications
actually confirm the environmental safety of Bt maize
cultivation and in fact do not identify any environmental
risk with respect to the cultivation of Bt maize in the EU.
Only two of these publications (Hilbeck et al., 2006, &
Rosi-Marshall et al., 2007) allege potential environmental
risks; the former being a philosophical approach, rather
than scientific data, and the latter is a questionable
extrapolation from laboratory tests. Indeed the
Rosi-Marshall et al. paper is based solely on laboratory
experiments, whereas the field data of the same authors
demonstrates no Bt effect on aquatic organisms (as shown on
their own website). As far as the field test is concerned,
it lacks decisive data on which transgenic maize plants were
used and the entire experimental documentation appears
sloppy and not meriting peer reviewed publication1. In
contrast to the theoretical risk projections of Hilbeck,
other authors have published a meta-analysis, of all
available studies carried out with Bt crops based on real,
scientifically acquired data that confirm there is no
indication of ecological risk arising from the cultivation
of Bt maize (Marvier et al., 2007; Romeis et al., 2007).
There is no new scientific evidence to contradict the
conclusions reached by the GMO Panel of the EFSA on the
safety of Bt maize cultivation in the EU. Furthermore, in
July 2007, the OECD published a consensus document 2 on
safety information of transgenic plants expressing Bt.
This document thoroughly reviews and confirms the safety and
high degree of specificity of the Bt proteins expressed in
Bt maize, including the protein expressed in line 1507.
Another inconsistency of your draft decisions is that they
fail to draw on a substantial body of scientific data
accumulated over several years and published in the last 12
months that highlight the economic, environmental and
consumer benefits of Bt maize. A total of 63 peer-reviewed
publications attest to the fact that Bt toxin does not
accumulate in the soil and does not affect aerial and
soil-based non-target organisms, on the contrary, there is
ample evidence that non-target insects are severely
threatened and reduced in their populations by spraying
pesticides.
In considering the environmental safety of Bt maize, it is
pertinent to note that Bacillus thuringiensis has been
widely used as an insecticide spray for the control of
European corn borer in Europe since 1938, when the first
commercial Bt preparation (Sporeine) came onto the market in
France. Given that Bt is a commonly used insecticide in
organic agriculture and given the current trend in the
expansion of organic farming in Europe, and the year-on-year
northward spread of European corn borer, it is inevitable
that Bt spraying will be on the increase. The scientific
data accumulated over recent years as part of biosafety
assessment dossiers compiled
on the various Bt crop varieties for commercial release will
provide useful evidence for assessing the environmental
impact of organic farming. As for the present time these
environmental assessments of Bt sprays with their much
higher concentrations have not been properly carried
through, and also not published in peer reviewed journals –
this in contrast to the many peer reviewed papers testifying
no negative effects in soil and agricultural environment of
GM Bt crops.
Agriculture is vital to the European economy, and Europe
stands to gain much by the cultivation of new high
performance crop varieties. Bt maize ensures productivity in
years of heavy infestations and reduces the need for
pesticides. In 2006, GM maize varieties including these two
products were planted on 25.2 million hectares around the
globe, and on 62,187 hectares in Europe. Spain has grown Bt
maize for 9 years, and the benefits of Bt maize to Spanish
farmers are well documented: average yield benefits have
often been 10% and sometimes higher, which adds €15 million
income to Spanish growers. Recent field trials in Italy
showed that Bt maize performed better than conventional
varieties with yield increases of between 28 and 43 percent.
These trials demonstrated that Bt maize can not only be more
profitable for farmers, but is healthier because of lower
contamination with hazardous fungal mycotoxins which
represent a significant health threat to humans and animals
when present in the food chain (Regulation (EC) No
1881/2006).
Farming systems are very diverse, from conventional to
organic or genetically modified (GM). This ensures that
agriculture provides an abundant and affordable supply of
healthy food and feed, and offers consumers more choice. The
EU’s explicit policy is that 'No form of Agriculture should
be excluded from the Union', and the European Commission
asks Member States to develop rules for the coexistence of
different production systems, like Bt maize and non-GM
maize, all long term scientific coexistence studies on maize
demonstrate the feasibility of coexistence.
It is important that the consequences of any obstacles to
the cultivation of GM maize varieties such as these are
carefully evaluated, since a number of alarming indicators
point to a future collapse of the EU livestock production
due to the unavailability of imported feedstuffs.
The Portuguese Council Presidency has recently called for an
open debate on the impact of the EU GM policy on food and
feed security, in the light of an extra cost of € 2 Bio for
EU-livestock producers resulting from de-facto import bans
on feed maize and corn gluten feed from GM corn producing
countries.
The draft Commission Decisions are totally unacceptable, not
only for European farmers and consumers, but also set a
terrible example for other parts of the world that presently
draft guidelines for the cultivation of GM crops, since they
look to Europe as an example. This is especially true in the
developing world where there is an urgent need of new
technologies to raise agricultural productivity. Other GM
strains of maize are under development that will have
enhanced nutritional quality or tolerance to drought, and
must be given the chance to reach those
who need them the most. It is a proven fact that in
developing countries Bt maize is healthier due to its much
lower content of mycotoxins, which have dramatic detrimental
effect on human health (cancer, spina bifidis).
In conclusion, Commissioner, your proposals to not approve
the two Bt maize lines for cultivation based on discredited
scientific arguments would not only undermine the EU’s own
scientific advice and risk assessment procedure but would
also represent a significant threat to the competitiveness
of European farmers.
To impose such bans is economically wrong, and pesticide use
for controlling European corn borer would continue, It is
also wrong on grounds of human health considerations.
European farmers would be denied a valuable economic choice
and Europe would import more grain to meet demand, but from
where. It would do nothing to support the choice of feed
producers or consumers. Such a move would violate EU
procedures and without scientific evidence to support them
would ultimately be rejected.
As European scientists we urge you to reconsider and return
to a reasoning based on science and experience. The
consequences of approving these draft Decisions and the
precedents they would set would be the marginalisation of
science in Europe, the discrediting of the European Food
Safety Authority and the collapse of the EU-livestock
industry.
Yours sincerely,
Emeritus Professor Marc Van Montagu
President of the European Federation of Biotechnology
The European Federation of Biotechnology - The European
Federation of Biotechnology is the non-profit
association of all national and cross-national Learned
Societies, Universities, Institutes, Companies and
Individuals interested in the promotion of Biotechnology
throughout Europe and beyond.
1 More detailed comments on the study can be visualized at
http://pubresreg.org/index.php?option=com_smf&Itemid=27&topic=9.0
2
http://www.agbios.com/docroot/articles/07-214-001.pdf
The European Federation of Biotechnology is the non-profit
association of all national and cross-national Learned
Societies, Universities, Institutes, Companies and Individuals
interested in the promotion of Biotechnology throughout Europe
and beyond. The mission of the EFB is to enable biotechnology to
serve its rightful role in society. |
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