25 October 2002
GREENPEACE ON PM'S SCOPING NOTE - "WORSE THAN USELESS"
"The Scoping Note and Strategy Unit work are thus set not to bring "rationality" to the debate about GM, but to inflame existing concerns and exacerbate current tensions without providing any empirical evidence commanding confidence across different sectors. It is, therefore, quite literally, worse than useless."
GREENPEACE Response to the Prime Minister's Strategy Unit Scoping Note "The costs and benefits of genetically modified (GM) crops"
1. Greenpeace welcomes the opportunity to comment upon "The Costs and Benefits of Genetically Modified (GM) Crops: Scoping Note" prepared by the Prime Minister's Strategy Unit (SU). As part of the broader public debate, Greenpeace will be interested to learn how the proposed study on costs and benefits "will be taken forward alongside and will link up with a review of the scientific issues... Both the SU study and the science review will feed into the public debate led by an independent steering board including members of the Agriculture and Environment Biotechnology Commission (AEBC). The nature of the relationship of these strands of the debate is not apparent, but even without knowing the precise nature of that relationship there is much within the SU”šs strategy document that raises serious questions.
2. An economic analysis has not been the dominant part of the extensive public discussion on GM crops in the UK, but the economic benefits of GM are among the major drivers identified by both Government and the SU in advocating the introduction of GM technology in this country. Yet even in the United States, where public debate on GM crops has been extremely limited, the economic justification for GM  has been questioned:
3. One often hears the statement that agriculture is changing and we must adapt to the changes. Few persons who repeat the statement really understand the magnitude of the changes and the implications of them for agriculture and for the long-term sustainability of the food system. It is almost heresy to ask if these changes are what the people of our country really want or, if they are not what is desired, how we might redirect the change. The changes are the result of notoriously short sighted market forces and not the result of public dialogue, the foundation of a democracy. Neither are the changes the result of some mystical figure or an "invisible hand."
4. As the UK enters into the public debate on the future of GM crops, it is important to acknowledge the extent of the unease surrounding the introduction of GM crops. It is also crucial to recognise that the customary use of science to support political decisions - such as the introduction of GM crops - is no longer adequate. This realisation needs to be extended to economic analysis as well. Without the participation of the public in the framing of the questions of all the aspects of this debate, the results of all three of its strands are likely to be flawed.
5. The analysis of the SU Scoping Note is framed on the basis of a seemingly straightforward set of assumptions that in fact reveal a very limited understanding of the nature of the public concern surrounding GM technology. The Scoping Note also includes many inaccurate projections of what the technology may or may not deliver in either economic or agronomic terms in the future. Both of these characteristics undermine the utility of the proposed study.
6. Many assumptions within the Scoping Note are built into the analysis on the basis that adopting GM technology will inevitably deliver positive outcomes. The whole of section 5 as well Section 2 is based on a variety of desired outcomes or projected benefits. The Scoping Note (and the Strategy Unit) assume that all benefits attributed to GM crops (higher yields, less intense use of agricultural chemicals, even enhanced nutritional values and an increase in the leisure time for farmers growing GM - among many others peppered throughout the Scoping Note) either currently exist, or will be realised in the very short term. This is not the case and the positive economic outcomes attributed to these benefits are unlikely to be realised.
7. Potentially negative economic outcomes resulting from the commercialisation of GM crops however are neglected. The consolidation and concentration in the seed industry Ë† already occurring in the United States - will have potentially negative effects in the UK as well.
8. Equally worrying is the characterisation of the SU study as a "scenario exercise"; this is extremely misleading. The conventional interpretation of a scenario-driven process is that it is based on a particular objective or outcome: by following a variety of pathways, one can examine the potential impacts of policy decisions that might lead to that outcome. The only objective apparent in the Scoping Note is that GM crops will inevitably be commercialised. This undermines the effectiveness of the SU study in two important ways. First, scenarios are frequently both misrepresented or at least misinterpreted as "prediction". Other stakeholders in the public "debate" on GM are unlikely to welcome such bogus predictions. Secondly, by misrepresenting the nature the of scenario exercise, the SU is effectively eroding its claims to a transparent and open process.
9. There is no consideration of a scenario that does not end in the commercialisation of GM crops. The potential economic and non-economic benefits of a non-GM status for UK crops, products and agricultural production are completely neglected. As the costs incurred for conventional and organic farmers resulting from GM contamination are well recognised, failure to recognise the benefits avoiding such contamination is perverse, and significantly undervalues the quantifiable benefits of a "GM-free" UK.
10. The Scoping Note seems to be built on the assumption that whatever happens in the UK GM crops will be commercialised everywhere else, at least in Europe. The current robust nature of the "moratorium" on the approval and commercialisation of GM crops in the EU calls into question that assumption.
11. Conversely, the proposed scenarios are limited to what happens in the UK but the UK is only one player in the global agricultural market in which GM crops may play a part. This is clearly an inadequate analysis. Examining these scenarios in terms of a wide range of outcomes across the rest of the world would have a huge number of variables, many of which would have an impact on costs in the UK.
12. Further, the section on costs draws no conclusions regarding a potential liability regime for GM crops. Such a regime is likely to be part of future suite of legislation regulating GM from the European Union. The potential impacts of the inevitable contamination upon the commercial prospects of either a conventional or organic farmer in terms of lost markets and the loss of future income implies a product liability that must be born by either a GM farmer or the manufacturer of the GM seeds. These costs may be very high. For example, maize exports from the US to the EU (valued at $305 million in 1996) collapsed almost completely by 2001.
13. Conversely, inadvertent contamination of conventional crops by GM may impose costs on conventional and organic farmers beyond revenue lost because of the lost markets or the potentially high costs of segregating GM and non-GM crops. In Canada, conventional farmers whose crops have been contaminated by Monsanto GM oil seed rape have incurred significant penalties and court costs (the Percy Schmeiser effect).
14. The Scoping Document is littered with unsubstantiated assumptions and assertions, but the section on the Implications of UK and EU Policy for GM Crops in developing countries is particularly distorted. The debate of which this study is on one part is geared to determine the future trajectory of agriculture in the UK. While Greenpeace is among the first to recognise the relationships of world agricultural practice and markets, the decision whether to commercialise GM crops in the developed world cannot be justified in terms of the potential importance of the technology to the developing world. Representatives of both Governments and Civil Society in the developing world have consistently and repeatedly asserted that the introduction of GM crops in the North must not be justified by the challenges of food security in the South. Hunger is rarely caused by a shortage of food, but is most often the result of poverty (itself caused by a mixture of factors) or conflict. GM crops cannot solve these problems. Further, to imply that GM crops grown in the developed world will address such problems in the developing world is at best disingenuous and at worst intentionally misleading.
15. While acknowledging that GM is not a "silver bullet" for the developing world, the Scoping Note continues to make misleading assertions about the increased productivity of GM crops, further implying that bio-diversity in the developing world will be enhanced as a result of less land being taken by agricultural crops. There are many locally appropriate technologies for increasing agricultural productivity in the developing and developed world. Conversely there is now evidence that adopting GM crops, combined with an export-led agricultural model can both undermine local food security as well increase the amount of land taken for agricultural production.
16. The Scoping Note fails to acknowledge the impact of key international legal instruments on the commercialisation of GM crops in the UK. While the UK is a significant player in the negotiations defining the WTO (the Agreement on Agriculture) and the Cartagena Protocol of the Convention on Biodiversity, neither are identified within the Scoping Note. Both instruments will have profound implications on both costs and benefits for the UK if GM crops are adopted here.
17. Finally, the Scoping Note's most significant omission seems to be one of understanding. The need for a public debate in the UK emerged as a result of pressure from a variety of public sectors Ë† environmentalists, consumers and even social scientists. (The economic impact of the behaviour of consumers both in the UK and elsewhere is also neglected in the Scoping Note.) These concerns represent a complex matrix of influences, yet the Scoping Note is seductively simple in its implications: if one adds up a limited number of identified costs and benefits, the decision to adopt GM crops appears to becomes a simple one. But as this submission shows, this assumed simplicity is illusory.
18. The history of cost benefit analysis Ë† for example, nuclear power stations or the impact of new motorways in the UK Ë† reveals that decisions taken on the basis that what appear to be present trends are often counter intuitive or just plain wrong. What is unknown cannot be part of a cost-benefit exercise, because it is impossible to put a cost on ignorance. Yet ignorance of the unexpected impacts of GM crops is exactly what has created the widespread unease amongst the wide range of stakeholders now participating in the "official" public debate sanctioned by DEFRA of which the proposed economic study is just one part.
19. The impact of the failure of the Strategy Unit to include the potential of these broader economic concerns on the debate on GM crops in turn undermines confidence that the participation of the public in the wider debate will ultimately have a detectable effect on Government decisions on GM crops. This in turn is likely (again) to alienate most stakeholders (and of course members of the public) because the over-riding impression will be that Government and it's advisors are ignoring their real concerns while appearing to validate the ideas that they (Government) already have formed.
20. The subsequent loss of trust in Government and official institutions will have considerable costs (in terms of difficulties implementing policy, additional public communications spend etc). None of these has been taken into account but represent a general erosion in social capital that is also leading to declining turnouts in elections etc. These effects are certainly difficult to quantify but undoubtedly highly significant in modern society. The scoping note demonstrates no recognition of such effects, or that the limited nature of the proposed exercise will make the situation worse.
21. The Scoping Note and Strategy Unit work are thus set not to bring "rationality" to the debate about GM, but to inflame existing concerns and exacerbate current tensions without providing any empirical evidence commanding confidence across different sectors. It is, therefore, quite literally, worse than useless.
2.Consolidation in the food and agriculture system - a report for the National Farmers Union. Heffernan W et al. University of Missouri-Columbia. 5th February 1999 http://www.nfu.org/images/heffernan_1999.pdf
3.Crops on trial. Agriculture and Environment Biotechnology Commission. September 2001 http://www.aebc.gov.uk/aebc/crops.pdf
4.New EU gene-crop approvals at least a year away. Ends Environment Daily. 18th October 2002 http://www.environmentdaily.com/articles/index.cfm?action=3Dissue&No=3D1311
5.Augmentaire on co-existence of GM crops with conventional and organic crops. European Commission Joint Research Centre. May 2002
6.EEC special trade since 1988. European Statistical Office
See also: Seeds of doubt: North American farmers' experiences of GM crops (Soil Association, 2002 http://www.soilassociation.org/sa/saweb.nsf/9f788a2d1160a9e580256a71002a3d2b/9ce8a24d75d3f65980256c370031a2d0?OpenDocument)
7.Scenarios for existence of genetically modified, conventional and organic crops in European agriculture. Bock AB, Lheureux K, Libeau-Dulos et al. European Commission Joint Research Centre. May 2002 http://www.jrc.cec.eu.int/download/GMCrops_coexistence.pdf
9.For example, see Let the Harvest Continue! a statement from all African Delegates (except South Africa) to the FAO Negotiations on the International Undertaking on Plant genetic resources, June 1998 (http://www.argonet.co.uk/users/john.rose/africa.html) or the open letter sent in October 2002 to biotechnology companies by Tewolde Berhan Gebre Egziabher, Ethiopian representative at the negotiations on the Convention on Biological Diversity
10.For examples, see www.farmingsolutions.org
11.Record Harvest, Record Hunger: Starving in GE Argentina. Greenpeace, June 2002 http://a520.g.akamai.net/7/520/1534/release1.0/www.greenpeace.org/multimedia/download/1/11328/0/recordharvest.pdf
12.Public perceptions of Agricultural Biotechnologies in Europe. Final report of the PABE research project funded by the European Commission. December 2001 http://www.lancs.ac.uk/depts/ieppp/pabe/docs/pabe_finalreport.pdf