Here are the comments of Friends of the Earth International on the UN's Millennium Project Draft Global Plan of Action.

The comments criticize the Millennium Project papers, which are calling for a new "African 21st Century Green Revolution" and the use of GM crops as a key mechanism to erradicate hunger, poverty and malnutrition.

The final MP Global Plan of Action is expected to be completed by December and will be presented officially next year.

EXCERPT: "Throughout the draft action plan, the 'need' for a green revolution for Africa is constantly repeated, yet this is in opposition to key findings, such as the ones from the InterAcademy Council report 'Realizing the Promise and Potential of African Agriculture', published in July 2004 and about which Kofi Annan made his recommendations. In fact, the IAC report did not recommend a new Green Revolution, but what it termed 'rainbow evolutions' - in other words, bottom up, location and farming system specific developments, rather than a simple, technology based approach applied uniformly across the continent, as is implied by the action plan."
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The Green Revolution and Genetic Engineering

Comments on the preliminary draft of the UN Millennium Projectís final report: 'A Global Plan to Achieve the Millennium Development Goals'

Friends of the Earth welcome the possibility to comment on the preliminary draft of the UN Millennium Projectís final report: "A Global Plan to Achieve the Millennium Development Goals". The following set of comments will address particularly the goals number 1 of eradication of extreme poverty and hunger in the context of the proposed new 'Green Revolution' addressed in the draft report of the Global Plan of Action (I). We have also addressed the goals 4,5 and 6 of reducing child mortality, improving maternal health and combat HIV/AIDs, malaria and other diseases, in relation to the topic of Gene technology, addressed in the recent draft report of the Task Force of Science and Technology of October 3rd (II). The last set of comments is made taking into account that this draft has not yet been reviewed by the Task Force Coordinators and the final report has still to take into account the final work of the taskforces.

I. A new 'revolution against hunger and poverty'

1. Introduction

The Global Plan of Action aims to translate the MDGs from aspiration to reality, and is calling for increased investments in interventions recommended in that report over the coming decade.

Friends of the Earth International strongly believes in the necessity to urgently tackle the first MDG goal of eradication extreme poverty and hunger, and the need for a renewed global effort to achieve this. Nevertheless, Friends of the Earth is very concerned about the instruments that are recommended in the Plan of Action to achieve this goal, namely the call for a new 'Green Revolution'.

The reports underlines in numerous occasions that to achieve this, particularly in Africa 'the most important initial step in escaping from rural poverty in most low-income countries is raising the productivity of smallholder farmers through a package of rural interventions that collectively lead to a 'green revolution'.

As your report states half of the hungry are smallholder farmers, and in the case of Africa three-quarters of Africa's poor live in rural areas. While Friends of the Earth believes that there is a need for creating policies and strategies to support and improve the livelihoods of smallholder farmers, we strongly disagree with using a 'green revolution', as the key strategy to tackle rural poverty and hunger. A new 'revolution against hunger and poverty' is needed, not a new 'green revolution'.

2. Will the Green Revolution model be the silver bullet to tackle rural poverty and hunger?

Friends of the Earth agrees with the report's recognition that there is no silver bullet for poverty alleviation, and that every country faces distinct challenges and therefore requires distinct solutions. Nevertheless, the Report in fact contradicts itself by overemphasising a common-global approach to tackle rural poverty and hunger via a Green Revolution. While Friends of the Earth believes in the urgency of developing concrete, solid and adequate strategies to tackle poverty and hunger, it deeply disagrees in the approach taken in the Plan of Action of using the dogma of the Green Revolution and ranking low agriculture productivity as the key problem of rural poverty.

The report particularly focuses on Africa, and in numerous occasions calls for an African 21st Century Green Revolution. It describes the financing of a '21st Century African Green Revolution' as an absolutely required element in an African strategy to overcome hunger and poverty. This approach is based on the previous success of the Green Revolution, particularly in Asia, and concludes that ìFood production could double or even triple in Africa in a decade, if policy makers and donors invest in a 21st Century African Green Revolutionî

Nevertheless the Green Revolution's narrow focus on increased food production is not the 'silver bullet' to solve hunger, and this is already recognized by organizations like the World Bank, which in 1986 in a study on world hunger and poverty concluded that a rapid increase in food production will not necessarily provide food security. In addition, a 1999 study by the International Food Policy Research Institute (part of the World Bank) found that in 63 countries with malnutrition, improvements in social factors - health, environment, women's education & status - accounted for nearly three-quarters of the reduction in malnutrition since 1970.

Asia is a concrete example of this, where despite increases in food production from the Green Revolution, hunger was not reduced; on the contrary, in South Asia for example it was estimated that in 1990 there was 9 percent more food per person than in 1970, but there were also 9% more hungry people. The draft report itself recognizes the limits of a Green Revolution in the case of Southern Asia, where ìundernourishment still remains a chronic problem for many parts of the population despite the success of the Green Revolution in producing an overall food surplusî. Overall, the United Nations estimates that in the early 1990s, 80% of all malnourished children in the developing world lived in countries with food surpluses. This further emphasizes the frequent disconnect between national food production figures and the nutritional status of a countryís population.

3. Omission of the negative impacts of the Green Revolution

The report completely omits to mention many of the negative impacts of the Green Revolution. The Green Revolution paved the way for an increased loss of biodiversity and genetic erosion, and it important to note that the loss of biodiversity also threatens food security, particularly for the poor who depend on biological products for 85-90% of their livelihood needs.

More than 7,000 plant species have been used by humankind since agriculture began more than 10,000 years ago, according to the UN Food and Agriculture Organization. Yet it has been estimated that 75% of the genetic diversity of cultivated plants has been lost since the beginning of the 20th century.
The intensive technologies of the Green Revolution have contributed to the fast pave of biodiversity loss. This drastic reduction in biodiversity has been accompanied by an expansion in intensive agrochemical use, which has contributed inter alia to soil degradation, contamination of ground water. The Green Revolution model also transformed and destroyed many local farming and local-knowledge systems based on the management of the vast biodiversity present in our countries. The social consequences have been significant since the dependence on chemical inputs and commercial seeds has brought millions of farmers to indebtedness, landlessness and further impoverishment. In addition, farmers and farming families have also been exposed to the hazards brought by chemical pesticides to human health.

4. Endorsing an African New Green Revolution?

The UN Millennium Project recommends that the world community adopt a Ten-Year Plan to achieve the MDGs. Action Point 25 in the draft action plan states that it will ìendorse the recommendations of the Secretary-General for a ì21st century green revolution in Africaî.

It is disturbing that the shorthand of an African Green Revolution is constantly employed throughout the action plan in a manner that is misleading and which also suggests an underlying agenda aimed at the support of high-input agriculture and unproven, extremely expensive technologies, such as genetic modification.

Throughout the draft action plan, the ëneedí for a green revolution for Africa is constantly repeated, yet this is in opposition to key findings from the InterAcademy Council report ìRealizing the Promise and Potential of African Agricultureî, published in July 2004 and about which Kofi Annan made his recommendations. In fact, the IAC report did not recommend a new Green Revolution, but what it termed ìrainbow evolutionsî ñ in other words, bottom up, location and farming system specific developments, rather than a simple, technology based approach applied uniformly across the continent, as is implied by the action plan. The IAC report specifically states that:

"The transformation of smallholder diversified systems into more specialized systems may not be expected to occur within one generation; an evolutionary increase in productivity for the majority of the farmers is more likely, with many 'rainbow evolutions' across the many farming systems rather than one green Revolution, as in Asia. This development pathway can meet local food and income needs while fulfilling social and cultural desires. In addition, diversified systems offer favourable options for minimizing adverse environmental consequences".

This is completely at odds with the underlying message of the action plan, which appears to be that this new African Green Revolution should simply be a reworking of the original, by the introduction of a prescriptive list of new technologies and commercial agricultural practice. Not only this, but the draft action plan repeats in several places the specious argument that the industrialization of agriculture and urban/industrial development are linked, with one leading to the latter, when in fact there is no good historical evidence that this is the case.

Industrial agriculture uses expensive technologies, including unproven genetic modification in some cases, and is characterized by large scale, specialized production using simple rotations and high levels of external inputs. However, the IAC report states that a transition to such specialized production will not occur within the time scale proposed for the action plan (5 to 10 years). The short scale of the action plan requires that it focus on approaches that will address the real immediate needs of resource poor and food insecure farmers, rather than on agricultural issues that may not be relevant for another 25 years.

There is a large amount of evidence to show that a farmer-led approach, utilising known and proven agricultural techniques and practices, can transform the livelihoods of farmers, increase food security and reduce malnutrition while also preserving the environment. An approach based on sustainable technologies and participatory research, development and extension may not be as ëhi-techí or exciting sounding for donors as a new Green revolution, but it is proven, has been shown to work and would ensure that aid was actually useful and relevant to the people it is directed at.

For example, a survey of 208 separate projects in 52 countries, covering almost 9 million farmers, found that improvements in food production can be achieved through the use of one, or a combination, of the following techniques:

'i. intensification of a single component of farm system (with little change to the rest of the farm) - such as home garden intensification with vegetables and/or tree crops, vegetables on rice bunds, and introduction of fish ponds or a dairy cow;
ii. addition of a new productive element to a farm system, such as fish or shrimps in paddy rice, or agroforestry, which provides a boost to total farm food production and/or income, but which do not necessarily affect cereal productivity;
iii. better use of natural capital to increase total farm production, especially water (by water harvesting and irrigation scheduling), and land (by reclamation of degraded land), so leading to additional new dryland crops and/or increased supply of additional water for irrigated crops (so increasing cropping intensity);
iv. improvements in per hectare yields of staples through introduction of new regenerative elements into farm systems (eg legumes, integrated pest management);
v. improvements in per hectare yields through introduction of new and locally-appropriate crop varieties and animal breeds.'

The authors state that, based on their survey of these projects,

'There is extensive evidence to indicate that sustainable agriculture can lead to: i) substantial increases in per hectare cereal production, typically up 50-100%, and in some projects rising to 200% increases; ii) increases in diversity of systems - as cereal productivity increases, so commonly farmers reduce the area under cereals and increase diversity of alternative crops and animals, such as vegetables, fruit and livestock.'

These kinds of yield increases are in the range required by the draft action plan, and there is a secondary benefit in terms of increasing the diversity of the diet. Crucially, such improvements can be achieved using existing approaches, experience and technologies.

The report further highlights the need for participatory approaches, rather than a prescriptive list of solutions, as is set out in the draft action plan. Even in the case of proven, successful technologies these could fail if they were not introduced through participation with farmers. The authors of the survey noted that

'If "integrated" systems are entirely designed (or even imposed) by external professionals with little regard to local people's needs, desires and constraints, then they are more likely to fail3. But if "redesign" emerges from a participatory process, then it is much more likely to be robust and sustainable.'

The IAC report notes that 'Most farming systems in Africa are based on a multitude of crops, often in combination with animals.' Increasing food productivity should incorporate increases in diversity of crop production and take advantage of the existing diversity of agricultural production in Africa, rather than seeking to erode it.

II. GM crops to contribute achieving the MDG?

1. Introduction

The Plan of Action also calls for the Secretary General to establish an Office of Science and Technology, to support the integration of science and technology advice in the implementation of the MDGs, and also calls on the Secretary General to develop a future list of recommendations to mobilize science for the poor.

In this context, Friends of the Earth would like to express its serious concerns about the recent report from October 3rd of the Task Force on Science, Technology and Innovation of the UN Milleniumm Project titled 'Forging ahead: Technological Innovation and the MDGs', where it is suggested that GM technology can be used to address malnutrition and the problems of resource poor farmers.

Friends of the Earth believes that such an approach would constitute a costly diversion of funds into an unproven technology that would be unlikely to produce any meaningful improvements within the timescale of the plan, if at all.

This technology is completely unsuitable for the problems faced by developing countries. To understand this, it is important to consider the decade-old history and current status of commercial GM crops, not just the promises being made for potential future applications of this technology. We would argue that the record of this technology to date provides a much better indication of its potential value to developing countries than early-stage research projects or mere proposals, the great majority of which will never be realized.

2. Lessons learnt from a decade of GM crops

First, over 99% of commerical GM crop acreage worldwide is confined to just four countries, three of them highly industrialized and export-oriented: the U.S., Canada, Argentina and China. Secondly, over 99% of commercial GM crop acreage is comprised of just four crops used mainly for animal feed (soybeans & corn), oil (canola) or fiber (cotton), not for hungry or malnourished people. Finally, over 99% of commercial GM crops feature just two traits (singly or in combination) - herbicide-resistance and insect-resistance - designed for the needs of developed country farmers. In short, the history of GM crop cultivation clearly demonstrates that this technology is best-suited to development of animal feed, oilseed and fiber for farmers in developed countries that practice a highly industrialized, export-oriented mode of agriculture. This excludes the great majority of farmers in the developing world.

Another characteristic feature of GM crops is suggested by the predominance of the herbicide-resistance trait. Fully 83% of global GM crop acreage involves plants engineered for resistance to the respective biotech companyís patented herbicide. Herbicide-resistant crops are favored by large farmers in industrialized countries as a means to reduce labor on weed control. Labor-saving, however, is not a high priority in most developing countries, where the typically high rates of rural unemployment or underemployment often make labor-saving a detriment rather than a boon. Even if desired, most developing country farmers would be unable to afford the higher costs of the more expensive, herbicide-resistant GM seeds and the patented herbicide without which they are pointless. With 5/6 of global GM crop acreage devoted to crops bearing a trait (herbicide-resistance) with no relevance to the needs of farmers of the South, it becomes extremely difficult to believe in biotech industry rhetoric about ìfeeding the worldî or ìcuring malnutritionî as a justification for this technology.

One might argue that experimental applications of plant biotechnology will be relevant to farmers in developing countries in the future. Yet any such argument must overcome a strong presumption against GM, given the historical record of irrelevance described above. One approach often used to evaluate the future of agricultural biotechnology is to read the press releases of the biotechnology companies, their trade groups (e.g. the U.S.-based Biotechnology Industry Organization), or the U.S. government agencies under their sway (e.g. the U.S. Agency for International Development). Another, perhaps more objective, approach is to examine evidence rather than public relations. The best available evidence does not come from experiments conducted in a laboratory, because for each gene or trait explored in the discovery stage, the odds are only about 1 in 250 that it will make it to market. A better gauge of future success is provided by those GM crops that have graduated from laboratory to outdoor field trial. And since the United States is the acknowledged leader in GM crop development, field testing of GM crops in the U.S. will provide the best indication of the future direction and prospects of this technology.

As of September 14, 2004, 32% of the GM traits listed for GM crop field trials currently underway in the U.S. involved resistance to herbicides. In other words, one-third of the most likely future applications of GM technology involve resistance to patented weed-killers. In contrast, just 1.52% of experimental GM traits being field-tested involved drought-tolerance, an application of GM technology highly-touted for use in developing countries. Just 0.48% (6 of 1252 GM traits) involved production of pharmaceuticals or vaccines, another much-heralded use of GM plant technology in the context of developing countries. Only 0.24% of GM traits presently being field-tested in the U.S. involved salt-tolerance (3 of 1252), possibly the most heavily promoted justification for genetic modification as a tool for agriculture in developing countries. Much more prominent than any of these latter uses was radical nutritional alterations to soybeans and corn to increase their 'feed efficiency' when fed to animals in factory farm operations. In contrast, we did not find one field trial for a GM crop designed for enhanced human nutrition.

3. The cost of GM crops, and alternative approaches

Even in those rare cases where a GM trait of potential relevance to developing countries is being field-tested, one must ask whether the GM route is cost-effective. It can cost between $80 and $300 million to develop a GM crop from the laboratory to the market, a process that can take up to 12 years. And as we noted above, for each gene or trait explored in the discovery stage, the odds are only 1 in 250 that it will make it to market.

Dr. Hans Herren, executive director of the Nairobi, Kenya-based International Centre of Insect Physiology and Ecology (ICIPE), won the prestigious World Food Prize in 1995 for saving African cassava (a staple for over 200 million Africans) from a devastating pest ñ the cassava mealy-bug. He accomplished this through introduction of the mealy-bugís natural predator, a parasitic wasp. Dr. Herren maintains not only that recombinant DNA technology is not cost-effective for African needs, but also that it diverts scarce funds from more cost-effective approaches:

'Today, I probably would not get the money for such a big programme [biological control of mealy-bug]. Today, all funds go into biotechnology and genetic engineering. The genetic people would try to construct a cassava that is resistant against the mealy-bug. Biological pest control, as we do it here at ICIPE, is not as spectacular, not as sexy. I see a big problem here.'

Dr. Herren is not fundamentally opposed to genetic modification. It is just that he regards it as expensive and ineffective for the the pressing needs of African society and agriculture.
After considering the discussion above, it is not surprising that GM technology has a poor record of developing crops suitable for resource poor farmers. For example, a joint project of the Kenyan Agricultural Research Institute (KARI) and Monsanto to develop a GM virus-resistant sweet potato took 12 years, more than 19 scientists and $6 million, yet has failed to develop a single suitable variety . In contrast, conventional breeding of sweet potatoes in Uganda produced a well-liked virus-resistant variety with yield gains of nearly 100%. This took only a few years, and was accomplished with a very small budget.

The GM approach is also contrary to a participatory approach, as it is led by the availability of particular modified traits, rather than the real needs of farmers. For example, a project to develop insect-resistant maize varieties by KARI and supported by Syngenta was not based on demand from farmers but rather the availability of the technology. In a review of the project it is noted that 'When the project did survey 30 villages throughout the country, none identified stem borers as the most pressing constraint upon maize productionÖ project surveys found that many farmers were already using their own resistant varieties.'

Even if a GM trait is successfully incorporated into a crop, there is still enormous difficulty in assessing whether unexpected or unintended effects of the modification on the plant genome have caused changes to nutrition, agronomic performance, toxicity and so on. Furthermore, traits such as drought tolerance, nutritional enhancement and salinity tolerance are often controlled by more than one gene. This means that:

*such crops are in many cases still theoretical propositions
*successful modification of such traits will be extremely expensive and could take many years
the likelihood of unexpected changes occurring is greatly increased, as is the difficulty in detecting such changes.

Furthermore, such traits are exactly those that could cause competitive disadvantage if the crops escape or traits are passed to wild relatives. The IAC report points out that

'Africa is the origin of the center of diversity of several of the worldís most important crops, such as coffee, sorghum, lentil, wheat and barley, African rice (Oryza glaberrima), oil palm, yams and cowpeas.' and that 'Africa's genetic resources are inadequately known, valued and utilized.'

The experience of the contamination of maize varieties in Mexico as a result of the import of GM maize highlights the dangers that the introduction of GM crops pose. As yet, the effects of this type of genetic pollution, including introgression of modified genes into related wild plant populations, are poorly understood. The long term effects of GM contamination on the environment and future sustainability of Africa - and conceivably the rest of the world in the case of world staples such as wheat - mean that this is not a step that should be taken without proper consideration of its serious implications - especially as there is so little apparent likelihood of even reaching the stated aim of increasing food productivity by such an approach.

4. GM Enhanced Crops to tackle malnutrition?

The Science and Technology report places a great deal of emphasis on the development of nutritionally enhanced GM crops to tackle malnutrition. This is an extremely simplistic approach to a problem that is primarily to do with poverty and access to a healthy balanced diet. As has already been shown, a sustainable approach to agricultural development, focusing particularly on increased diversity of production, would also help to address malnutrition by broadening out the diet. However, it is necessary to address some of the specific difficulties inherent in relying on GM crops.

As is acknowledged in the Draft report, ìvery few developing countries have been able to formulate regulatory frameworks to deal with biotechnological issues and even fewer have the capability to carry out risk assessment on biotechnology productsî (p 180).

Yet it is being proposed that these countries introduce GM crops that would tax even the regulatory assessment authorities of the European Union. For example, in a review of the science and regulation of GM crops, conducted by the UK government in 2003, it was stated that:

'Testing of second generation nutritionally enhanced products will therefore not only need to build on the paradigm and methodologies of first generation GM crops and novel foods and regulations, but will also require new considerations and regulations in their own right. Their characterisation is likely to make increasing use of molecular profiling techniques, which are still the subject of much active research and development.'

If the UK authorities are unsure whether they have the ability to test these crops, it seems irresponsible to recommend their adoption by countries that have fewer resources. The importance of ensuring the safety of nutritionally enhanced crops would be great, as they are being proposed for groups of people for whom they would make up most of the diet. This means that any risk from a difference in nutritional content or toxicity would be amplified by the high exposure rates. The danger of ignoring this issue is highlighted by the fact that malnutrition in many parts of Asia is, in part, linked to the lower micro-nutrient content of the green revolution staple crop varieties, which have displaced local fruit and vegetables from the diet .

Institutional support and strengthening would need to be prioritized were such an approach to be taken. Experience from developed countries show that even a purely science based risk assessment of such complex transformations would take several years even after the institutional systems were in place, and this does not account for the economic and social debate that would also be necessary. Considering that there are already many cheaper alternative methods for addressing malnutrition, and that nutritionally enhanced crops produced by conventional breeding are already available , the GM approach appears to be excessively costly and unlikely to reap significant benefits within the timescale of the action plan.

5. Golden Rice is not the answer to malnutrition

The report explicitely mentions Golden Rice as a well known example of nutritionally enhanced GM crops. So-called 'golden rice' is being genetically modified to increase its beta-carotene content (a precursor for vitamin A that is absorbed and converted into vitamin A in the body).

Vitamin A deficiency (VAD) is an important cause of illness in developing countries, resulting in night blindness, total or partial blindness, and reduced resistance to infection. In 1994, the World Health Organisation (WHO) reported that 3 million preschool age children had eye damage due to vitamin A deficiency. VAD is also thought to contribute to the 1.1 million childhood deaths from measles each year.

Vitamin A is obtained either by eating foods containing the vitamin (e.g. eggs, whole milk or meat) or by its production in the body from the precursor beta-carotene, found in plant foods and especially in green leafy vegetables and fruit. The majority of people with VAD are in those countries where rice predominates in the diet - south and southeast Asia - since polished rice is low in beta-carotene because the naturally beta-carotene rich husk is removed during milling.

GM ëgolden riceí produces beta-carotene, as a result of the introduction of three genes from a narcissus plant which complete the biochemical pathway needed for production in the rice endosperm (the rice grain remaining after milling has removed the outer layer which naturally contains beta-carotene). But such a significant change to the plantís metabolism increases the likelihood that the production of beta carotene may alter the levels of other components in the endosperm or even the production of unexpected compounds that prove harmful. Dr. David Schubert of the Salk Institute in California warns that retinoic acid (vitamin A) and its derivatives influence mammalian development at ultra-low concentrations, and that GM crops producing vitamin A might also produce derivatives that cause direct toxicity or abnormal embryonic development in those exposed to them. The same may be true of crops producing the pro-vitamin A (beta carotene). Furthermore, there is as of yet no information as to how well the pro-vitamin A is absorbed from the GM rice, as absorption varies enormously according to the type of food involved. According to Dr. Marion Nestle, nutritionist at New York University, absorption of beta-carotene is dependent on adequate levels of fat and protein in the diet. Those suffering from VAD, of course, are often malnourished in other ways and thus often lack adequate levels of these macronutrients in their diets. The tests required to establish whether golden rice is both safe and effective as a source of vitamin A would be likely take several years themselves.

As with other serious mineral deficiencies - such as iodine and iron - alternative, proven methods of reducing VAD already exist, including supplementation, fortification of foods and dietary diversification - it is not a lack of solutions to this problem that has caused ëhidden hungerí to continue. If the political will is there, such approaches could be implemented straight away, rather than relying on an unproven, expensive GM crops which could not be safely introduced without significant additional investment in institutions to manage GM crop introduction, and which anyway might not even be available within the next decade.

If ill-judged enthusiasm for GM modified rice, and other GM crops with a particular nutritional content, lead to them becoming the focus of attempts to tackle malnutrition, then the sheer expense is bound to cause a diversion of resources away from other approaches. If resources are diverted away from projects that would have multiple benefits, such as direct poverty alleviation or a general improvement in the diversity of the diet, then it is entirely possible that the net effect would be detrimental.

III. Conclusions

Friends of the Earth International strongly believes in the necessity to urgently strength the efforts to eradicate extreme poverty and hunger, and the need for a renewed global effort to achieve this. However, FoEI strongly disagree with using a 'green revolution', as the key strategy to tackle rural poverty and hunger. In this sense FoEI calls for the removal of the Action Point 25 of the draft report to endorse a '21st Century Green Revolution in Africa'.

The draft report contradicts itself by recognizing that there is no silver bullet for poverty alleviation, and that every country faces distinct challenges and therefore requires distinct solutions, but nevertheless overemphasises a single common-global approach to tackle rural poverty and hunger via a Green Revolution.

The draft report omits to mention many negative impacts of the Green Revolution, which paved the way for an increased loss of biodiversity and genetic erosion. It important to note that the loss of biodiversity also threatens food security, particularly for the poor who depend on biological products for 85-90% of their livelihood needs.

Throughout the draft action plan, the 'need' for a green revolution for Africa is constantly repeated, yet this is in opposition to key findings, such as the ones from the InterAcademy Council report 'Realizing the Promise and Potential of African Agriculture', published in July 2004 and about which Kofi Annan made his recommendations. In fact, the IAC report did not recommend a new Green Revolution, but what it termed 'rainbow evolutions' - in other words, bottom up, location and farming system specific developments, rather than a simple, technology based approach applied uniformly across the continent, as is implied by the action plan.

Friends of the Earth profoundly disagrees with the recent report from October 3rd of the Task Force on Science, Technology and Innovation where it is suggested that GM enhanced crops can be a meaningful tool in tackling malnutrition in the framework of the MDGs.

Friends of the Earth believes that to invest on Genetically Enhanced crops in the context of the MDG would constitute a costly diversion of funds into an unproven technology that would be unlikely to produce any meaningful improvements within the timescale of the plan, if at all. Friends of the Earth believes that today the use of GM crops is not cost-effective for African needs, and that by using it will mean to divert scarce funds from more cost-effective approaches.

References

UN Millennium Project. 2004. A Global Plan to Achieve the millennium development goals. 23 September 2004.

United Nations Millennium Project. 2004. Forging Ahead: Technological Innovation and the Millennium Development Goals. Report of the Task Force on Science, Technology and Innovation. 3 October 2004.

World Bank. 1986. Poverty and Hunger: Issues and options for food security in developing countries. World Bank Policy Study, Washington, DC. World Bank.

As cited in testimony of Brian Halweil, staff researcher with the Worldwatch Institute, before the U.S. Senate Subcommittee on International Economic Policy, Export and Trade Promotion, at the hearing on 'The Role of Biotechnology in Combating Poverty and Hunger in Developing Nations,' July 12, 2000.

Food First. 2000. Lessons from the Green Revolution.

Testimony of Brian Halweil (op. cit.)

The Crucible II Group. 2000. Seedling Solutions. Volume 1. Policy options for genetic resources: People, Plants, and Patents revisited.

International Development Centre/International Plant Genetic Resources Institute/Dag Hammarskjold Foundation.

Menini, U.G. 1998. Policy Issues for the Conservation and utilization of horticultural Genetic resources for food and Agriculture. World Conference on Horticultural Research. 17-20 June 1998 in Rome, Italy.

SAOUMA. 1993. Message from the FAO Director-General Edouard Saouma on the occasion of the World Food Day 1993. Diversity 9 (3), 5. See also Hammer, K. 2003. Resolving the challenge posed by agrobiodiversity and plant genetic resources - an attempt. Journal of Agriculture and Rural Development in the Tropics and Subtropics, kassel university press GmbH.
See also UN Secretary General. 2004. Secretary General Calls for 'Uniquely African Green Revolution' in 21st Century to end continent's plague of hunger, in Addis Ababa remarks. Press Release SG/SM/9405. AFR&988. 6/07/2004
www.interacademycouncil.net

Pretty J and R Hine, 2001. Reducing Food Poverty with Sustainable Agriculture: A Summary of New Evidence Centre for Environment and Society, University of Essex,UK

Figures on countries, crops and traits from James, Clive. 'Global status of commercialized transgenic crops: 2002,' ISAAA Briefs No. 27, 2002. ISAAA = The International Service for the Acquisition of Agri-Biotech Applications, a biotech industry funded group that promotes genetically engineered crops around the world.

75% herbicide-tolerant + 8% herbicide-tolerant and insect-resistant = 83%. 2002 figures from Clive, J. (2002) op. cit.

Graff GD& Newcomb J. Agricultural biotechnology at the crossroads. Bio-era Economic Research Associates. 2003.

Graff GD& Newcomb J. Agricultural biotechnology at the crossroads. Bio-era Economic Research Associates. 2003.Statistics in the paragraph from: ìStatistics on Permits Currently in Effect for Field Trials of Genetically Engineered Crops,î data downloaded September 14, 2004 from Information Systems for Biotechnology (U.S. Dept. of Agriculture Database of GE Crop Field Trials), HYPERLINK "http://www.nbiap.vt.edu/cfdocs/fieldtests1.cfm" \t "_parent" http://www.nbiap.vt.edu/cfdocs/fieldtests1.cfm , compiled by Bill Freese, Research Analyst, Friends of the Earth

Graff GD & Newcomb J. Agricultural biotechnology at the crossroads. Bio-era Economic Research Associates. 2003. See also Action Aid. 2003. GM crops ñ going against the grain. May 2003. http://websrv.actionaid.org/wps/content/documents/gatg_2462004_1524.pdf

See biography of Dr. Herren at: University of Florida, Institute of Food and Agricultural Sciences, February 22, 2003, at: HYPERLINK "http://yorklecture.ifas.ufl.edu/Herren.htm" \t "_parent" http://yorklecture.ifas.ufl.edu/Herren.htm .

As quoted in: ìPush-and-Pull: An Innovative and Low-tech Solution to Control Stemborers in Africa,î Part 1 of Genetic Engineering versus Organic Farming ñ The Fact and the Fiction, by Florence Koechlin, International Federation of Organic Agriculture Movements (IFOAM), IFOAM Brochure 2002, http://www.blauen-institut.ch/Tx/tT/ttGenEngOrgFarm.html.

De Grassi A, 2003 Genetically Modified Crops and Sustainable Poverty Alleviation in Sub-Saharan Africa An Assessment of Current Evidence http://www.twnafrica.org/docs/GMCropsAfrica.pdf?twnID=377

Ibid

GM Science Review First Report An open review of the science relevant to GM crops and food based on the interests and concerns of the public Prepared By The Gm Science Review Panel (July 2003) http://www.gmsciencedebate.org.uk/report/pdf/gmsci-report1-pt3.pdf

Seymour, J. Hungry for a new revolution. New Scientist pp 30-37., 30th March, 1996.

International Rice Research Institue Press Release Rice essential to achieving Millennium Development Goals October 27, 2003

Schubert, D. (2002). 'A different perspective on GM food,' Nature Biotechnology 20, 969.

Nestle, M. (2001). "Genetically Engineered ëGoldení Rice is Unlikely to Overcome Vitamin A Deficiency," Letter to the Editor, Journal of the American Dietetic Association 101, 289-90.
www.interacademycouncil.net