Why we won't participate

We recently wrote about a survey organised by Technopolis, consultants to the European Commission, to solicit the views of stakeholders on the Commission's plans to deregulate certain types of GM crops. Claire Robinson of GMWatch was invited to participate in the survey and originally intended to do so but has decided to refuse on the following grounds.

Range of stakeholders not clear

The survey was sent only to selected people and we are aware of prominent expert groups and individuals who are well qualified to participate but who were not invited to do so. The breakdown of invited stakeholders has not been published. But judging by the Commission's bias in its own public consultation on GMO deregulation, this survey could be heavily biased in terms of soliciting the participation of a high proportion of supporters of GMO deregulation – who represent only a tiny sector of society as a whole but who have money and power on their side.

Bias in the survey questions

The survey reflects and reinforces the pro-deregulation bias of the Commission's own consultation on this issue. GMWatch participated in the consultation, even though it was fundamentally flawed, in that it took the GMO industry's promises of "sustainable" GMOs as fact. The survey appears to follow the Commission's line that deregulation is necessary and desirable. For example, it calls one deregulation scenario "proportionate", suggesting that the current GMO regulations are disproportionate. And it assumes that certain types of GMO could be obtained naturally or by conventional breeding, an assumption that is not supported by scientific evidence and runs contrary to much existing evidence showing that the changes induced by gene editing are different in quality and quantity from those that can happen naturally.

"Crystal ball" thinking

The survey expects survey respondents to look into their crystal balls to predict scenarios for the period 2030–2035, regarding the number of new GM products that will be available and what environmental and health impacts they will have. Such "crystal ball" speculations are not suitable for forming policy, which should be based on evidence and the precautionary principle.

Confusing questions

The survey questions and answer options have caused immense confusion, with many respondents – including us and scientists – uncertain as to what "negative" and "positive" means for different indicators. While we appreciate Technopolis’s recent attempts to clarify the survey questions and answer options by issuing further guidance, we have no confidence that all the respondents who have already submitted their answers will be able to take the time to revisit them in order to check them against the guidance. We similarly have no confidence that those who did not previously submit their answers but still intended to do so at the time they received the guidance will take the extra time to check their prospective answers against the guidance. This is especially the case as so many people are on holiday and away from their desks during August.

We are aware that as a result of the confusion caused by the questions and answer options, people who share the same view (e.g. in wanting pesticide use reduced and having no confidence that new GMOs will help achieve this aim) have answered the survey questions in diametrically opposite ways. This means that the findings of the survey will be completely unreliable.

Lost opportunity

In our view, this survey was a lost opportunity by the Commission to seek input from a variety of stakeholders. The bias and confusing questions are particularly frustrating because it would have been easy to design an objective survey with questions that everyone can understand and respond to.