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In July 2002 Margaret Beckett announced a public debate on the commercialisation of GM Crops The government's Strategy Unit produced a draft " Scoping Note", outlining the study and invited comments by 25 October. CEL sent in the response below
October 2002

CHRISTIAN ECOLOGY LINK


General
Christian Ecology Link is a registered charity and voluntary organisation which aims to provide insights to environmental issues from the beliefs and values of the Christian faith community.

We take the view, based on the precautionary principle and our understanding of good stewardship, that not even field trials of GM crops in the UK are justified until far more is known about possible effects of growing such crops such as the way they can interact with other crops at a distance, the results for wildlife and the implications for bio-diversity. In our view, therefore, the question of the economic effects of commercial planting should not arise until these issues have been taken much further. Even when this point arises it should not be taken for granted that if some short or medium term economic benefit can be envisaged, this alone would justify permitting such plantings. Ethical and environmental considerations may be of more importance.

In addition, it must be recognised that technological developments often have important results which originally may have seemed rather remote. For example, did those making plans to handle a foot and mouth outbreak give any thought to the effect the measures to be adopted would have on youth hostels? Section 2.4 of the note mentions such concerns but in a manner that tends towards allaying them rather than identifying the potential problems and taking them into account in decision-making.

The pattern of the debate process
A basic criticism of the process is that it is in the wrong order. First we should have the full results of the field trials, then the scientific assessment, then the discussion of the economic effects of a decision about commercial planting; only when all this is clearly in the public domain would there be the basis for a fully informed public debate. Obviously this will take longer, but the Secretary of State has said that she wants a genuinely open and balanced discussion. Perhaps the Strategy Unit should study the potential costs and benefits of rushing the task.

The compass of the study
The study described in the note seems therefore to be a preliminary exercise which would need to be reworked when more is available by way of scientific data and assessment. What we would ask however is that in this study every possibility within its terms of reference should to be taken into account.

For example, there is need for greater clarity as to the crops concerned. What crops are regarded as "those in development that could be available within a 10 year time frame"? (Section 4.1) If it is intended that the study should apply to any kind of crop which might conceivably be grown in the UK, then a very wide range of scientific data would be needed. Is it available? If on the other hand the study is related only to a very limited list of crops then it is questionable whether many of the potential benefits listed have any relevance. Perhaps there should be a specific section of the report about the possibility of commercial planting of the crops which have been grown in field trials.

Does the draft note allow for consideration of the general argument there is no strong economic case for a GM commercial programme in the UK and, when allowance is made for the difficulties such as observing adequate clearance distances, it might not even be possible to mount a programme which is economically viable?

"No GM scenario"
We are glad that this scenario is mentioned. Will the study consider the economic benefits of UK being a GM Free zone?

SOME SPECIFIC POINTS
Section 2.5 (third bullet) mentions the domestic legislation on the introduction of new plant varieties but rather oddly omits mention of the EU legislation on which the National List system depends.

Section 5.7 Costs and benefits to different sectors will depend critically on who is responsible for avoiding cross-pollination. Will new legislation require farmers growing GM crops to keep them many miles away from any organic farms? Or (more likely?) will the absence of legislation force organic farmers to remove themselves many miles from GM users? The study will need to make assumptions about several possible scenarios.

Section 5.12: This looks at possible environmental benefits from GM methods. But the four bullet points all relate to a comparison between conventional and GM methods. A comparison between organic and GM methods would yield totally different results. Both should be considered.

Section 5.13: Considering environmental costs, the final bullet point cites the example of introducing herbicide resistance to wild plants. There are other characteristics which could be more serious if transferred, such as insect resistance or frost tolerance.

Christian Ecology Link
October 2002

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