In section 5.4.8 to 5.4.8.7 of the document on biotechnology, the World Bank does what it is best at, namely, promoting the interests of rich countries and their trans-national corporations while claiming to help the poor. The document itself contains all the propaganda that has been circulated by public relations companies employed by the corporations. To coat thousands of gold bullets with genetic material and use a gene gun to shoot these into the cell of the target organism can hardly be called a precise technology. It can often take between 5,000 and 10,000 experimental gene insertions to achieve the desired result. Nevertheless you make this claim in the second paragraph that this is a precise technology.

The renowned English zoologist, Colin Tudge presents a very different picture. He writes, "genetic engineering, even at its simplest, implies the ad hoc introduction of exotic genes into the genome of established organisms; and this, in principle immediately suggests a hierarchy of possible problems. Most obviously, the newly introduced gene could disrupt the host genome in undesirable and quite unpredictable ways. The theoretical problem can readily be seen through an analogy. It's often said that the genetic code is 'digital', so in a general way it is. Each gene and so, by implication, each functioning length of DNA corresponds to some specific 'bit' of information. We get closer to reality, though if we compare genes to language as in the title of Steve Jones's 1993 book The Language of Genes. Individual genes are then compared to words. But the meaning of individual words is not to be captured in a stripped-down dictionary definition. Anyone who tries to speak a foreign language out of a dictionary knows how droll the natives find such efforts. The meaning of words depends very much on their context what words are they surrounded by. Behind the dictionary definition of individual words lies the syntax of the language, and the actual use of it; the colloquialism, the cross-references, the historical allusions, the puns. Genes work in this way too because genomes evolve, trailing their history behind them. They are not simply 'digital', but work to rules that are in part logical and in part a matter of historical accident. If genes are compared to words, then the genome of any particular creature as a whole should be compared to literature. Genetic engineering is not really engineering. It is more like gardening, in you plant and then stand back, and watch; or, to pursue the present metaphor, it is more like editing. Every writer knows that the injudicious alteration of a single word can change the import of a text absolutely and prays for a gentle and competent editor.

At present, after 100 years of formal Mendelian genetics and a few decades of genomics, we have some small insight into the functioning of a few genes in a few genomes (including for human genes). For some organism, in short we have the beginnings of a dictionary. But the genome of an organism any organism might be compared in literary terms, to some sacred poetic text written in a language of which we have virtually no inkling; medieval Tibetan, or Linear B. Would you, or anyone who was halfway sane, undertake to edit such a text if all they had to guide them was a bad dictionary?

You continue that paragraph with another half-truth that it is an extension of traditional breeding practices. It is nothing of the sort; recombinant DNA technology is new and radically different technique that has no semblance to any previous breeding methods used by humankind. It circumvents the barriers that exist between completely different species and does this with the aid of bacteria and viruses. 5.4.8.1

In March 2007 it was revealed at a Paris news conference that Monsanto maize (MON863) caused serious damage to the liver and kidney of rats which consumed it during feeding trials. The rats showed signs of heptorenal toxicity, symptoms of poisoning and liver and kidney damage. According to Professor Gilles-Eric Seralini who conducted the study at the University of Caen in France, these revelations are profoundly disturbing from a health perspective. They are sufficient to require new and more carefully conducted feeding studies and an immediate ban from human and animal consumption of GM maize MON836 and all its hybrids. In spite of this study which was published in the Archives on Environmental Contamination and Toxicology in March 2007, MON 863 which was formally approved by the EU in August 2005 was not withdrawn from circulation.

In his book, Genetic Roulette: The Documented Health Risks of Genetically Engineered Foods, Jeffry M. Smith presents 65 health risks of eating genetically engineered food. The author argues that infants and children are most at risk from potential allergens, toxins and other nutritional products associated with GM foods. Despite studies like these the World Bank does its special pleading on behalf of its corporate friends in the last 3 paragraphs of 5.4.8.2. The truth is that the regulatory framework is much too lenient, mainly because of the enormous political power yielded by large corporations. In 1997 two reporters from The Guardian in Britain were very critical of the regulatory agencies on a number of fronts. They found a revolving door between the US government and the biotech industry. They also found that the biotech industry has succeeding in rewriting the world food safety standards to suit their own financial gain. They referred to new laws protecting the US food industry from criticism and the fact that GMO food is not labelled in the US. They claimed that the agribusiness corporations were using leading PR companies to massage the debate in favour of countries adopting genetic engineering. Furthermore, that they were attempting to use international organisations like the World Trade Organisation (WTO) to brow beat governments who were opposed to GMOS. And here now we have the World Bank doing its part to push GMOs.

You give no data on the negative impact of GMOs on biodiversity. A study carried out for the United Kingdom Department of Agriculture in March 25, 2005. This was the largest study ever conducted on genetically-modified crops and it concluded that they can harm wildlife. In the GMO fields there were fewer seeds, bees and butterflies. In the GMO crop's fields there were also fewer broad-leaved weeds - considered important because they feed insects - even though there were some grass weeds and soil insects remaining. Why was that study not listed to counter the Qaim and Traxler study?

The claim that GMOs and conventional crops can co-exist is open to serious question, particularly for plants like canola or rape seed oil that are wind pollinated. The pollen can affect plants 25 miles away from the GMOs crop. The reality is that all canola in Canada has now been contaminated. There many commentators who believe that this was government policy to allow the contamination to happen and say we now have fait accompli so let’s get on with it. This is exactly what the biotech companies want when they talk about choice. But they will accept no liability for contaminating conventional or organic crops.

In my experience in the Philippines the claim in 5.4.8.5 that GMOs will benefit small farmers is ludicrous. Let’s be quite clear, it was not in response to the cries of the poor and the hungry that biotech corporations began to experiment with plant and animal recombinant DNA technology. Rather it was to make even greater profits than they were already making. Corporations like Monsanto and Syngenta are implementing a strategy of attempting to control the seeds of the staple crops of the world. They are making sure that the genetic changes are linked to other products which they also market, thus creating various GMOs which are resistant to the weed killer Round-up, a product on which the patent was about to lapse. Forcing poor farmers to buy a seed and the herbicide package will not feed the poor. In fact, it will have the opposite effect. The document does not mention the fact that distribution is a more important and crucial element in solving world hunger than greater production of food crops. This means that social, political and economic policies are both the cause of hunger, and also potentially the solution to hunger. This will take creative economic policies that will promote research into organic agriculture, accessible credit schemes, fair markets and extensive land reform. Remember a huge amount of food is produced in Brazil, it is now the 4th largest exporter of food in the world, and yet, 35 million people go to bed hungry every night. The recipe of the World Bank and your sister agency the IMF of promoting a neo-liberal, economic agenda has had disastrous effects on the poor of the world and on the environment. This paper is totally rooted in those failed economic policies.

Your comments on the terminator gene, or in your sanitized language "genetic use restriction technology", once again show your bias of championing the cause of your corporate friends, against the needs of the poor. The Rev. Dr Samul Kobia who is the Secretary General of the World Council of Churches which has a membership of over 340 churches representing 560 million people, has a very different view which I share. He wrote that "applying technology to design sterile seeds turns life, which is a gift of God into a commodity. Preventing farmers from re-planting saved seeds will increase economic injustice all over the world and add to the burdens of those already living in hardship". This is why the terminator gene was developed to stop farmers replanting. Because of adverse publicity surrounding this morally reprehensible technology, the corporations back-off using the technology. Now they want to justify its use by claiming it will prevent genetic pollution. Once again you opt for their side of the argument, even though it has no basis whatever.

The claim that GMOs reduce pesticide use is also open to question. Charles Benbrook, formerly head of Northwest Science and Environment Policy Center at Sandpoint in Idaho carried out a comprehensive study using US government data on the use of chemicals on GMOs. He found that when GMOs were first introduced in the mid-1990s they needed 25% less chemical for the first three years. By 2001, however, GMOs received between 5% and 25% more spraying compared with conventional crops. Dr. Benbrook stated that: "the proponents of biotechnology claim that GMO varieties substantially reduced pesticide use. While this was true in the first few years of widespread planting ”¦ it is not the case now. There's now clear evidence that the average pound of herbicide applied per acre planted to herbicide tolerant varieties has increased compared to the first few years".

Finally, you buy the myth that GMOs give greater yield than seeds which are bred in a conventional way. Early in 2003 Aaron deGrassi, a researcher at the Institute of Development Studies at Sussex University in Britain published an analysis of GMO crops which biotech companies were developing for Africa. These included cotton, maize and sweet potatoes. He discovered that conventional breeding procedures and good ecological management produced far higher yield at a fraction of the cost of genetic engineering. The GM research on sweet potato was approaching its 12th year and had involved the work of 19 scientists at the cost of $6 million. The results indicate that the yield had increased by 18%. On the other hand, conventional sweet potato breeding, working with a much smaller budget, had produced a virus-resistant variety with a 100% yield increase. And perhaps, most important of all for small farmers, the non-transgenic sweet potato had no patent. Corporations want patents and use every mechanism from courts to international agencies like the World Trade Organisation (WTO) to impose their corporate agenda on the poor of the world. Patenting give them the power to control the seeds of the staple crops of the world. The profits from such control would be enormous and guaranteed into the future.

One final comment. The Green Revolution, which you laud and the new biotech technology, is only viable in a world where petrochemicals are cheap and readily available. We know that oil is a finite resource and that it is becoming more scarce. Many geologists, who have worked for the oil companies, like Dr. Colin Campbell, believe that "peak oil" will happen within the next few years. Where will poor farmers get the petrochemical involved in biotech farming? If the World Bank were really interested in the welfare of the poor they would use their money to promote research into organic agriculture which is not dependent on fossil fuel. Remember agriculture, and not transport will be the first casualty of peak oil.