0
Field Work: Weighing
up the Costs and
Benefits of GM crops
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Contents
Foreword by the Sponsor Minister.............................................................................................. 3
Executive Summary...................................................................................................................... 5
Chapter 1: Introduction .............................................................................................................. 18
ˇ 1.1 Project context........................................................................................................... 18
ˇ 1.2 Definitions of GM crops and GM food ....................................................................... 20
ˇ 1.3 Recent events and policy processes......................................................................... 22
ˇ 1.4 Project participants and process ............................................................................... 24
ˇ 1.5 Scope and limitations of this report ........................................................................... 27
ˇ 1.6 Structure of the report................................................................................................ 29
Chapter 2: The backdrop for GM crops: science, regulations, public attitudes and wider
policy............................................................................................................................................ 30
ˇ 2.1 GM crops in their scientific context............................................................................ 31
ˇ 2.2 The fundamentals of GM crop regulatory policy........................................................ 38
ˇ 2.3 Public attitudes .......................................................................................................... 43
ˇ 2.4 The wider policy context............................................................................................ 45
ˇ 2.5 Summary ................................................................................................................... 59
Chapter 3: Analysis of costs and benefits ............................................................................... 60
ˇ 3.1 Introduction................................................................................................................ 60
ˇ 3.2 Impacts on the economics of agriculture................................................................... 61
ˇ 3.3 Practicalities of the supply chain: providing consumer and farmer choice................ 70
ˇ 3.4 Wider impacts on the rural economy and society...................................................... 77
ˇ 3.5 Agriculture, the environment and human health ....................................................... 78
ˇ 3.6 Impacts on the science base in the UK..................................................................... 85
ˇ 3.7 International impacts ................................................................................................. 89
ˇ 3.8 Applying the analysis to the scenarios ...................................................................... 92
Chapter 4: Scenario analysis and conclusions ...................................................................... 93
ˇ 4.1 Introduction................................................................................................................ 94
ˇ 4.2 Scenario Analysis...................................................................................................... 95
ˇ 4.3 Potential disrupters ­ the impact of shocks and surprises...................................... 107
ˇ 4.4 Overall conclusions ................................................................................................. 114
Chapter 5: Next steps ............................................................................................................... 117
ˇ 5.1 Recommendations for further analytical work ......................................................... 117
ˇ 5.2 What happens next?................................................................................................ 120
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Annex A: The role of the Strategy Unit................................................................................... 121
Annex B: Project team, Sponsor Minister and Expert Groups............................................. 122
Annex C: Organisations consulted and submissions received........................................... 125
Annex D: The GM Dialogue: links with the Public Debate and the Science Review.......... 130
Analysis papers
The following analysis papers, which accompany the main report and expand on its analysis, are
available on the project web site at www.strategy.gov.uk. Paper copies of the collated papers are
also available on request from the Strategy Unit (telephone: 020 7276 1881):
ˇ Regulations and GM crops: Key Questions Answered
ˇ Analysis of the Costs and Benefits of GM crops in Product Chains
ˇ Analysis of the Costs and Benefits of GM crops to the Environment and Human Health
ˇ Analysis of the Costs and Benefits of GM crops to Industry and Science
ˇ Potential UK impact of GM crops on the decision-making contexts of developing
countries: Analysis Paper
ˇ GM foods in the late 1990s ­ an overview of events and the media reaction.
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Foreword by the Sponsor Minister
From food to clothing, from medicines to fuel, plants are essential for
sustaining human life. Plants, of course, evolve without human intervention.
But man has developed a variety of techniques ­ from plant-breeding to
organic pest control ­ that can give a helping hand to this process. Little of
what we grow on our farms today has not benefited in some way from these
techniques.
A new technique to develop novel crops is genetic modification. Genetic
modification has a range of applications for both plants and animals, but has
also been central to many recent advances in biotechnology research. GM
micro-organisms, for example, already produce a variety of vaccines, as well
as insulin for the treatment of human diabetes. Along with many other aspects
of biotechnology, these applications are likely to expand rapidly over the
coming decades, and I am pleased to say that the UK is at the forefront of this
research.
GM crops could offer significant benefits to both farmers and consumers, and
even the environment. Herbicide-tolerant and insect-resistant crops have
proved very popular with farmers where they are available, while drought- and
saline-resistant crops are likely to offer further benefits in future. Consumers
may be able to choose foods with higher nutritional value or a longer shelf-life.
GM crops could also be used to produce pharmaceuticals or as a source of
renewable energy.
But as with any new technology these potential benefits are also
accompanied by risks and uncertainties - and these in turn bring about public
concern. In the case of genetic modification, particular attention has been paid
to potential impacts on consumer choice, to the possibility of risks to health
and the environment and to the speed of technological development. The
challenge for any government is to regulate the use of this new technology in
a way that safeguards the public and our planet, commands public
confidence, but also ensures that our society does not unnecessarily throw
away the benefits science can provide. This is no easy task.
It was because of this challenge that the Government last summer launched a
wide-ranging public dialogue on all the issues raised by genetic modification.
The aim has been to provide more evidence on the potential risks and
benefits and to draw together all the conflicting opinions on GM. In parallel
with the public debate `GM Nation?', and the review of scientific issues, I
asked the Strategy Unit to carry out this study into the overall potential costs
and benefits of GM crops.
As I believe people who read this report will discover, the Strategy Unit has
drawn on expertise and opinions from a wide spectrum of viewpoints.
The Strategy Unit is making this report to Government. It has sought to
provide a comprehensive and impartial analysis of the costs and benefits of
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different scenarios for the banning or commercial planting of GM crops in the
UK. Along with a great deal of other material including the results of the `GM
Nation?' debate, the report will help Government decide about the overall
direction of its policy towards GM crops. I look forward to receiving views on
both the report's analysis and implications.
Rt. Hon Margaret Beckett MP
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Executive Summary
OBJECTIVES OF THE STUDY
The Strategy Unit's study is one strand of a wider public dialogue on GM
issues
1. The Government has initiated a dialogue on the issues raised by genetic
modification (GM). In Summer 2002, it commissioned three inter-linked
strands of work:
ˇ a public debate ("GM Nation?");
ˇ a review of the scientific issues; and
ˇ a study into the overall costs and benefits of GM crops.
2. The aim of all three strands has been to improve the evidence-base, and
to create a dialogue between all aspects of opinion on GM. In parallel with this
work, the Food Standards Agency (FSA) has carried out its own programme
to assess people's views on GM food.
3. The Public Debate, Science Review, FSA work and Strategy Unit (SU)
study of costs and benefits will all be taken into account by the Government in
developing policy on GM crops.
This report provides an assessment of the costs and benefits of GM
crops
4. This report sets out the Strategy Unit's (SU's) analysis of the overall costs
and benefits of GM crops. The main objective of this study has been to
provide a comprehensive and balanced analysis of the costs and benefits of
the possible commercial cultivation, or otherwise, of GM crops in the UK. The
study focuses on crops that are currently available, as well as possible
developments in the next 10-15 years, and develops scenarios to explore a
range of possible futures.
5. The study looks at costs and benefits which may arise in a broad range of
areas, and not just at those whose value can be measured in monetary terms.
SETTING THE CONTEXT
GM crops represent just one application of GM technology, and one
approach to plant-breeding
6. GM crops are widely grown across the world and have been available for
human and animal consumption for almost ten years. However, GM crops
represent just one application of GM technology. Genetically Modified
Organisms (GMOs) are already in common use for other purposes ­ such as
the use of GM microbes as factories for insulin and for enzymes used in food
processing (such as the manufacture of vegetarian cheese). At the same
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time, GM crops represent just one approach to plant-breeding, and are in
addition to other approaches ­ such as marker-assisted breeding or radiation-
induced mutation.
GM crops need to be considered in context
7. GM crops are not an end in themselves. They therefore need to be
considered in the context of the government's objectives in a number of policy
areas:
ˇ Agricultural policy and the environment;
ˇ Rural policy;
ˇ Science, innovation and competition policy;
ˇ Policy on food safety and quality;
ˇ International development policy.
8. The analysis in this report has attempted to assess the costs and benefits
of GM crops in the light of their impact on these policy objectives. Could GM
crops help or hinder achievement of the objectives? What alternatives are
available? And how might the situation change over time? Both domestic and
international contexts are relevant.
Public attitudes will be important in determining the future of GM crops
and foods
9. Surveys over the past few years have generally revealed negative public
attitudes towards GM food. However, public attitudes are complex and can
evolve. There is also some evidence that attitudes may vary between GM
crops and GM foods, and between different types of GM produce and GM
traits.
10. Initial focus group work for the Public Debate has helped the process of
exploring the complex set of attitudes that lie behind such results. It showed
that views on a wide variety of issues frame overall attitudes towards GM
crops, including individuals' views on food and health, choice and information,
progress and uncertainty, the environment, and ethics. Further complexity
arises from the interaction between public attitudes and the activities of other
groups and organisations, including NGOs, the media, retailers and
Government.
There is a wide-ranging regulatory framework in place
11. Regulatory authorities have already taken steps to tackle potential
environment and health issues that could arise from the development of GM
crops, and to respond to public concerns. Regulatory policy is largely
determined at the level of the European Union (EU), with decisions taken
collectively by Member States under a system of supervision which dates
back to 1990, and has recently been significantly strengthened. Any new GM
crop or food is subject to an approvals process which looks in detail at
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potential impacts on the environment and human health, both of the crop and
of the food it is used to make.
12. Other elements of the system govern the use of crops and foods after they
have been approved, such as rules on the traceability and labelling of GM
crops and ongoing monitoring of environmental impacts. Some of these
regulations are still being developed.
13. The UK Government has an important role to play in this, both as part of
the policy-making process, and in implementing regulatory policy on the
ground. Government will need to make some important policy decisions on its
approach to GM crops. Key milestones include the upcoming publication of
the Farm Scale Evaluation results, and the end of the current voluntary
agreement with industry not to grow the crops.
14. Attitudes to risk and regulatory approaches need to be put in context.
Non-GM agriculture is not risk-free ­ indeed there is strong evidence that past
changes to agricultural practice have had some negative environmental
impacts. The risks associated with GM crops therefore need to be seen
alongside the risks involved in any type of agriculture.
This study looks both at the current generation of GM crops, and those
which could be brought to market in the next 10-15 years
A relatively narrow range of crops and traits is currently available...
15. Despite rapid take-up during the last few years, GM crops still make up
less than 5% of the total global area of crop growing. 66% of the global area
of GM crops can be found in the US ­ other major users are Argentina,
Canada and China. Four GM crops dominate. These are cotton, soybeans,
maize and oilseed rape. Over 99% of these have one (or both) of two traits:
herbicide tolerance and insect resistance. Other crops have been developed,
but are not grown widely. Examples include GM sugar beet, and a very limited
number of GM fruits.
16. On the basis of decisions made in 1996, the UK already imports some GM
products for use here, almost all for non-food uses (mainly cotton), or for
animal feed (mainly soya).
17. However, only some of these crops are likely to be relevant for actual
cultivation in the UK. Soybeans and cotton are not suitable for the UK climate.
The insects targeted by existing insect-resistant GM crops are not currently a
significant problem here. Only the herbicide tolerant varieties of crops such as
maize, sugar beet and oilseed rape are likely to be of interest.
...although the range could expand significantly over the next 10-15 years
18. Looking ahead, a wider range of GM crops could be developed that are
relevant to the UK. Possibilities include:
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ˇ the application of GM technology to a wider range of crop types suitable
for UK conditions, such as GM wheat and GM potatoes;
ˇ a range of more valuable agronomic traits, such as resistance to common
UK pests and plant diseases, or improvements to the efficiency with which
crops can absorb nutrients;
ˇ GM foods with consumer benefits, such as longer shelf life, or health
benefits, such as improved nutritional content or reduced allergenicity;
ˇ a wide range of non-food crops, which could include crops used as
"factories" for a range of goods, such as the production of
pharmaceuticals, industrial oils, or renewable materials; as well as crops
which could be used directly in the production of energy or fuel.
19. Whilst the rate and success of development of these crops is far from
guaranteed, they offer the potential for some valuable new products which
could contribute to policy goals in a number of areas. However they may also
bring additional uncertainties and risks, which the regulatory system would
need to take into account.
Crop developments could also come from conventional and organic
techniques
20. Non-GM methods will also continue to produce new developments. Our
increased understanding of plant genomics is helping to accelerate many
aspects of agricultural research, and conventional methods of plant breeding
may deliver some of the benefits which GM approaches are aiming to
achieve. The ability of these methods to deliver improvements would depend
both on the science, and on the amount of money devoted to such research. It
may also be the case that there are some traits ­ such as those which deliver
high levels of biomedical and industrial products ­ which can only be
delivered to a commercial scale using GM.
APPROACH TO THE STUDY
This study has been informed by experts, the public, science, and the
best available economic data
21. The study has sought to take on board:
ˇ the views of stakeholders, experts and the wider public ­ particularly as
expressed through the preparatory phase of the Public Debate;
ˇ information on the economic impacts of GM crops where they are already
in commercial cultivation in other countries;
ˇ information on the science of GM, partly drawn from the Science Review.
22. Stakeholders and experts have been involved in key aspects of the work,
and the Strategy Unit has worked closely with both the Public Debate Steering
Board and the Science Review. Interim outputs have also been published for
comment.
23. This report goes as far as possible in bringing together the evidence on
costs and benefits of GM crops. But it does not draw definitive conclusions or
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put forward policy recommendations. This is due to the general nature of the
study, as well as to a number of limitations to the evidence base.
There are limitations to the analysis
The study provides a general analysis of the issues
24. Many of the issues to do with GM crops ­ such as their potential impacts
on farming, the environment, human health, and economic activity ­ are
highly specific to individual crops and traits. This is the basis for the current
EU regulatory system, which takes a case-by-case approach to regulatory
approval.
25. This study recognises that generalisations about the impacts of GM crops
are not always possible, and many areas where the analysis differs according
to the particular crop variety are highlighted. However, the overall report is at
a general level. Its intention is to provide an overview of the issues, and to
inform the direction of policy towards GM crops as a whole, rather than to
inform individual decisions about specific crops.
The evidence base on the costs and benefits of GM crops is limited ­ as is the
evidence on alternatives
26. There are limitations to the available data:
ˇ although there is a large body of international research on the commercial
growing of GM crops, some of this is subject to contradictory
interpretations, and its applicability to the UK needs to be treated with
caution. It also covers a relatively short time period. As there has been no
commercial-scale cultivation of GM crops in the UK, there is also limited
domestic evidence of agronomic or environmental impacts;
ˇ there is very little research on the economic and environmental impacts of
conventional and organic farming. This makes it hard to establish a
baseline against which the impacts of GM crops may be assessed;
ˇ there are also significant uncertainties inherent in looking forward over the
10-15 year time horizon considered in this study. For instance, the UK and
international policy environment, public attitudes, and the state of science
may well change over this period.
In response to the limitations in the evidence base, and to future
uncertainties, the SU has used a scenario analysis to look at different
possible futures for the UK with or without GM crops
Scenarios allow consideration of a range of possible futures
27. To take into account these areas of uncertainty, the SU has worked with
stakeholders to develop a range of scenarios. These cover plausible possible
futures with and without commercial cultivation of GM crops in the UK, over a
10-15 year time period.
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THE FIVE SCENARIOS
28. The scenarios use different assumptions about possible public attitudes to
GM and the nature of the regulatory regime as the main determinants of
different futures. The five scenarios, which cover a wide range of possibilities,
are summarised in the box below.
The five scenarios
UK PUBLIC
ACCEPTS GM
UK PUBLIC
REJECTS GM
GM-SPECIFIC
REGULATIONS
NON-GM-SPECIFIC
REGULATIONS
Tangled
threads
Bare
minimum
Separate
weave
Part of the
fabric
Not made
in the UK
ˇ Scenario 1: `Part of the fabric' ­ the public largely accepts GM crops and
foods, and therefore significant cultivation of GM crops occurs, with the
regulatory regime increasingly treating GM crops and foods much like any
other novel foodstuff.
ˇ Scenario 2: `Separate weave' ­ the public increasingly accepts GM crops
and foods, and GM crops are gradually introduced under a strict GM-
specific regulatory regime including a stringent approvals process, post-
market monitoring and labelling.
ˇ Scenario 3: `Bare minimum' ­ public attitudes are largely against GM crops
and foods, and there is a strict regulatory system, leading to very little GM
cultivation in the UK in the short-term.
ˇ Scenario 4: `Tangled threads' ­ there is a breakdown between negative
public attitudes and regulations which fail to maintain a separation
between GM and non-GM crops grown in the UK.
ˇ Scenario 5: `Not made in the UK' - an explicit decision is made against the
commercial cultivation of GM crops in the UK, with the public preferring
conventional or organic produce.
29. The scenarios are not predictions, but they are useful in illustrating how
costs and benefits may differ in different futures for the UK with or without GM
crops.
The report also looks at how unexpected events may throw these scenarios
off course
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30. The scenario analysis has limitations. In particular, it is hard for such an
analysis to look at the possible impact of uncertain-probability, but potentially
high-impact, events. The Strategy Unit has therefore analysed how robust the
scenarios may be to "shocks and surprises", which could either support or
damage the delivery of particular policy objectives.
31. A range of developments which are, on the surface, unrelated to GM
crops may have an impact on how the costs and benefits play out. There are
many examples, ranging from elevated concerns about general food safety,
through effects of climate change, to changes to the social environment.
32. In addition, GM crops themselves could be associated with unexpected
outcomes. These could be positive, such as a surprising breakthrough in GM
technology delivering a desirable new crop characteristic. Many people are
more concerned, though, about the possibility of a negative shock, such as
the discovery of a new allergen associated with a GM crop ­ particularly if the
impact is hard to reverse.
33. The aim of the GM crops regulatory regime is to prevent harm to human
health and the environment. Because there are uncertainties associated with
any new technology, some risks may be unique to GM crops and food. Others
also apply to other methods of plant breeding and agriculture.
34. These shocks and surprises would play out in different ways in different
scenarios. In scenarios with a more stringent regulatory framework, for
instance, it might be easier to deal with an unexpected negative impact on the
environment arising from a GM crop ­ but it might also be harder to capitalise
on any new developments in GM technology. In contrast, a scenario with
minimal regulation and significant GM crop growing may deliver a wider range
of benefits, but might find it harder to deal with risks.
COSTS AND BENEFITS IN THE SCENARIO ANALYSIS
The SU has carried out a detailed analysis of the potential costs and
benefits of GM crops
35. The Strategy Unit's scenarios are used to analyse the range of possible
costs and benefits that may be associated with the cultivation of GM crops.
36. The study identifies the following key areas of cost and benefit:
ˇ Impacts on the economics of agriculture. The current generation of GM
crops has been designed to offer specific cost or convenience savings to
farmers. International evidence suggests that some savings have been
realised from the current generation of GM crops, and in some cases
these savings have been accompanied by increased yield. However, this
evidence needs to be treated with some caution ­ the regulatory context,
market conditions (e.g. consumer demand) and physical characteristics
(e.g. farm size) differ between the UK and those countries where GM
crops have been grown commercially.
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Applying this to the UK context, the study suggests that some farm-level
savings might be expected in areas such as spending on pesticides, along
with advantages in terms of convenience of farm management and ­ in
some circumstances ­ increased yields. These would have to be set
against the costs associated with commercial cultivation, including the cost
to farmers of buying the technology, and some additional costs of
compliance with regulations.
The balance of costs and benefits would vary between crops and between
types of farm. Some GM crops may only offer advantages to farmers with
particularly serious weed problems, for example; others may offer more
general benefits, for example GM sugar beet might allow farmers to make
significant cuts in herbicide costs. Future crops and traits may offer more
valuable benefits than current generations.
Farming practice will also influence the balance of costs and benefits.
Farmers' decisions will depend critically on the demand for the GM crop. If
the price they received for GM crops was much lower than that for non-
GM, then this could easily outweigh any cost savings. Ultimately, farmers
would have to make individual decisions on whether to adopt the
technology.
ˇ Practicalities of the supply chain. Many European consumers continue to
demand a choice between GM and non-GM food. Reflecting this, some
costs are already incurred in the UK in order to maintain separate non-GM
lines of some imported products. These are likely to rise as the range of
available GM foods increases, whether or not GM crops are grown in the
UK.
Additional costs may arise if GM crops were cultivated in the UK,
particularly in keeping crops separated at the farm level. The nature of
any measures which may need to be put in place ­ and hence their likely
cost ­ is not yet clear. The cost may also vary significantly from crop to
crop, depending, for example, on the characteristics of the crops and on
the extent to which organic varieties are grown. But the analysis suggests
that many of the measures that could be required are consistent with
existing farm practice, or could be achieved through co-operation between
farmers. This means that these costs could be relatively small as a
proportion of the total costs of crop growing. However, the detailed design
of any measures will have a significant impact on costs for GM,
conventional and organic agriculture.
ˇ Wider developments in agriculture are likely to be more important in the
short-term. Any cost savings or increased yields offered by GM crops
could contribute to improved competitiveness in UK agriculture. However,
any economic benefits from the commercial cultivation of current GM
crops are likely to be outweighed by other developments, at least in the
short-term. UK farmers do not operate in a fully competitive market, and
hence their future profitability is more likely to be determined by national
and EU policy decisions ­ for example, on the Common Agricultural Policy
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(CAP) ­ rather than smaller-scale cost savings arising from the use of
current GM crops.
ˇ Wider impacts on the rural economy and communities. There have been
concerns that the introduction of GM crops to the UK might have impacts
on rural economies more generally, such as effects on the reputation of
rural areas. However, there is little evidence in this area.
ˇ Agriculture, the environment and human health. This study has not looked
in detail at the scientific evidence on the environmental and human health
impacts from GM crops. Some people have concerns about these impacts
and the broader uncertainties associated with GM crops. These issues
have been dealt with by the Science Review, and are already a key
element of the risk assessment procedures applied to all applications for
the release of GM crops.
However, the study does consider how the changes to farm management
associated with GM crops could have an impact. The assessment is
inevitably preliminary in nature, particularly in advance of the results of the
Farm Scale Evaluations (FSEs), which are looking at one aspect of this
issue. There is scope for both positive and negative effects, although the
exact scale and nature of these are hard to judge, as the relationship
between agriculture and the environment is complex and relatively poorly
understood. Impacts would also depend on farmer behaviour, which may
vary from individual to individual.
In the short term, the biggest changes could come from the use of
herbicide-tolerant crops, and resulting changes in patterns of herbicide
use. These changes could have environmentally beneficial effects, for
example by replacing persistent or high toxicity herbicides with more
benign ones. However there is also scope for costs. Low cost herbicides
that can be used with little or no damage to the main crop could lead
farmers to increase herbicide use, to the detriment of biodiversity.
Future GM crops could also directly address environmental or human
health objectives, such as the production of renewable materials, or of
foods with reduced allergenicity. However, non-GM techniques might
achieve some of the same goals ­ for example, a broccoli with enhanced
levels of a cancer-preventing substance has been developed using non-
GM techniques. And future developments may also increase risks and
uncertainties.
ˇ Impacts on the science base in the UK. What happens with GM crops over
the next few years will have an important influence over the long-term
options available to the UK ­ for example in affecting the UK's expertise in
GM and non-GM technologies, the UK's ability to capitalise on future
developments and the signals sent to wider biotechnology and science-
based industries.
Commercial GM crop research in the UK has declined, and is a small
component of overall scientific activity, with one multinational crop
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research facility being based in the UK, and very few small businesses
working in the area. The direct economic impacts of GM crop policy that
reduced this sector further would therefore be fairly limited in the short
term.
However, UK academic crop research is still strong, and the commercial
sector has the potential to expand. Significant economic benefits might
accrue to companies providing GM crop technologies ­ and it may be in
the UK's interest for these companies to be sited in the UK. There would
be a significant opportunity cost if the UK lost its ability to research,
develop and bring GM crops to market.
ˇ International impacts. UK policy towards GM crops will have international
repercussions, and the stance taken by the EU as a whole is likely to have
a still greater impact. Differences in approach between the EU and some
other countries on GM policy are already causing trade tensions.
There may also be specific impacts on the UK's policy of ensuring that
developing countries should be free to decide for themselves whether to
adopt GM crop technology. UK and EU policy towards GM crops may
impact on the context in which developing countries make these choices
about GM crops.
CONCLUSIONS OF THE STUDY
The scenarios illustrate the trade-offs inherent in any future for the UK,
with or without GM crops
37. None of the scenarios are universally good or bad. Instead, they all
represent trade-offs between costs in one area and benefits in another.
Different individuals will have different views on the desirability of each
scenario outcome. Value judgements and "weighting" of different factors will
therefore be required to assess how costs and benefits should be traded off
against one another.
38. The Government is particularly interested in whether GM crops can help
to achieve policy objectives. The analysis shows that different objectives may
be supported more or less in different scenarios.
The scenario outcomes could be shifted by interactions between
policies and attitudes
39. The scenario outcomes could be shifted by interactions between different
factors. Dynamic relationships between, for example, regulatory policy, public
attitudes and global developments could affect the overall outcome in any
scenario. These interactions are unpredictable and the uncertainty
surrounding their potential impacts should be noted when assessing the
overall conclusions to this study.
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The scenarios show that the nature of the regulatory system will have an
important bearing on our ability to deal with any risks to the
environment and human health...
40. The current EU regulatory system has been designed to limit adverse
effects as far as possible ­ and as the regulatory system evolves over time, it
will continue to retain this aim. But no procedures can be 100% effective, and
there will always be the possibility ­ however small, or disputed ­ that some
unforeseen (and possibly unforeseeable) adverse impacts to the environment
or human health may occur, particularly in the longer-term. The potential
irreversibility of some of these impacts also has to be taken into account when
considering this possibility.
41. In light of this, a key trade-off will be between the costs and burden of
regulation, and its effectiveness in anticipating and handling risk. A regulatory
system which required large amounts of information, such as many years'
worth of testing, might be more effective in anticipating problems or in dealing
with unexpected events should they arise. But it could also be expensive and
may discourage biotechnology firms from developing potentially valuable new
crops in the UK.
...as well as on the impact of GM crop cultivation on non-GM and
organic farmers
42. The nature of the rules on the growing of GM crops will determine how
effectively they can be kept separate from non-GM crops at the farm level,
and to what extent non-GM and organic farmers may have to incur costs
themselves in ensuring the integrity of their products. Whether they could
pass on any such costs would depend on the relative demand for their goods,
which would be higher in scenarios where the public has negative views about
GM produce.
They also illustrate the central importance of public attitudes in
determining the impacts of GM crops
43. Consumer attitudes are a very important determinant of the impact of GM
crops. In scenarios with negative attitudes, there is only a limited market for
GM crops, and hence low take-up. Attitudes are complex and heterogeneous,
and may vary between different uses of GM crops ­ the use of crops for
industrial purposes or animal feed, for instance, might prove to be more
acceptable than their use in food.
In the short term, negative consumer attitudes can be expected to limit
the demand for products containing GM foods, and therefore the
economic value of the current generation of GM crops
44. Applying this to the current situation in the UK means that if consumer
attitudes towards GM foods are negative in the short term, then any net cost
and/or convenience savings associated with the current generation of GM
crops would be likely to be outweighed by the lack of a market, limiting their
16
economic value. Interest from farmers may be limited to goods destined for
export markets, or for the production of animal feed.
But there is significant potential for benefits from future developments
in GM crop technology...
45. The availability of GM crop technology may help in the development of
new and potentially beneficial crops in the future, such as those with
particularly useful agronomic traits which make agricultural production easier
or cheaper. These traits may be important in maintaining competitiveness in
internationally-traded commodities. GM crop technology may also help the
development of products with health or consumer benefits. And the potential
for GM crops to be used in the production of a range of non-food products,
such as renewable materials or pharmaceuticals, could provide benefits
outside the farming and food industry.
46. However, this potential needs to be balanced against the possibility that
new GM crops could introduce new risks. Much would depend on the ability of
the regulatory system to keep up with the technology in the future, and to
anticipate and manage risks and people's concerns effectively.
...as well as the potential for impacts on wider science and industry
47. GM crop policy may also have wider impacts on UK science and industry.
The UK has a leading position in biotechnology in Europe. The UK also has a
global reputation for wider scientific excellence, and science-based industries
as a whole make an important contribution to national output. This
contribution, and its future expansion, is likely to be affected if changes in GM
crop policy send signals, either positive or negative, about the UK's attitude to
biotechnology, science and industry.
The scenarios demonstrate that international implications could be
significant
48. The scenarios show that the global impact of UK or EU GM policy should
not be underestimated. The ability of developing countries to choose whether
or not to adopt GM crop technology may be affected by considerations about
the possible impact on exports to the EU. And taking a significantly different
policy direction from other countries could cause serious trade tensions.
NEXT STEPS
49. Your views on the report and on the study as a whole would be welcome,
particularly in light of the emerging issues coming out of the "GM Nation?"
Public Debate and the Science Review. Please send your comments to:
17
GMCrops@cabinet-office.x.gsi.gov.uk
GM Crops Project Team
Strategy Unit
4th
Floor, Admiralty Arch
The Mall
London SW1A 2WH
to arrive by Friday, 17th
October 2003.
All responses received before this date will be published by the Strategy Unit
and passed on to DEFRA.
18
Chapter 1: Introduction
Summary
ˇ The Strategy Unit study is one strand of a wider public debate on GM
issues.
ˇ The main objective of the study is to provide a comprehensive and
balanced analysis of the costs and benefits of the possible commercial
cultivation, or otherwise, of GM crops in the UK.
ˇ The report focuses on crops that are currently available, as well as
possible developments in the next 10-15 years, and develops scenarios to
explore a range of possible futures.
ˇ The SU study does not attempt to provide a single figure for total costs
and benefits; neither does it attempt to make policy recommendations or to
set out potential implementation strategies.
ˇ The project was carried out by a multi-disciplinary team, including team
members with experience in economics, science, policy-making and
working in developing countries.
This introductory chapter sets out the context of government initiatives and
other studies in which the Strategy Unit GM crops project was conducted
(section 1.1). It then describes some key terms used in the report (section
1.2). Section 1.3 outlines some of the significant recent events and policy
developments which set the background for any study of GM crops. Details of
how the project was conducted and who participated are provided in section
1.4. Section 1.5 describes the scope and limitations of this report, and section
1.6 outlines the way in which the report is structured.
1.1 Project context
The GM dialogue
The Government has decided to instigate a "GM dialogue", with several
components
1.1.1 The Secretary of State for the Environment, Food and Rural Affairs,
Margaret Beckett, announced on 26th
July 20021
that she was calling for three
inter-linked strands of dialogue on GM2
issues:
1
A press release is available at http://www.defra.gov.uk/environment/gm/debate/index.htm.
References in this document relate to material available to the project team up to and
including Friday 20
th
June 2003.
2
GM is variously used to stand for "genetic modification" or for "genetically modified".
19
ˇ A public debate;
ˇ A review of the scientific issues; and
ˇ A study into the overall costs and benefits of GM crops.
1.1.2 "GM Nation? The Public Debate" has been taken forward by an
independent Steering Board.3
The origins of the Public Debate lie in the
Agriculture and Environment Biotechnology Commission's (AEBC) "Crops on
Trial" report published in Autumn 2001, and the chair of the AEBC, Professor
Malcolm Grant, is also chair of the Public Debate Steering Board. The
Steering Board met for the first time in September 2002, and has been asked
to report to Government by September 2003. The aim of the Public Debate is
to help deepen public understanding and create a dialogue between all
aspects of opinion.
1.1.3 The review of the science of GM is being led by Professor Sir David
King (the Government's Chief Scientific Adviser) working with Professor
Howard Dalton (the Chief Scientific Adviser to the Secretary of State for the
Environment, Food and Rural Affairs), with independent advice from the Food
Standards Agency (FSA).4
An expert Science Review Panel, chaired by
Professor King, has reviewed and summarised the state of scientific
knowledge and areas of uncertainty over GM science issues.
1.1.4 The Science Review Panel is due to publish its first report in late July
2003. The Science Review Panel is expected to re-convene in September
2003, to take into account the results of the Public Debate.
1.1.5 The study into the overall costs and benefits of GM crops is the
subject of this report by the SU.5
The specific role of the SU study within the
overall GM dialogue has been to provide a comprehensive and balanced
analysis of the costs and benefits of the possible commercial cultivation, or
otherwise, of GM crops in the UK, as a contribution to future decisions about
GM crops.
1.1.6 The Public Debate, Science Review, SU study of costs and benefits
(and the FSA work described below) will all be taken into account by the
Government in developing policy on GM crops. More information about the
inter-relationships between the three strands of the overall GM dialogue is
provided in Annex D.
There have been other initiatives and studies relating to GM crops
1.1.7 In parallel with the three strands of the GM dialogue, the Food
Standards Agency has been independently assessing consumer views on
the acceptability of GM foods and how these views relate to consumer
choice.6
Activities have included surveys of the attitudes to GM foods of
young people and people on low incomes ­ to ensure that their views are fully
represented in the debate ­ and a Citizen's Jury broadcast live on the internet.
3
Full details of the Public Debate are available at http://www.gmnation.org.uk.
4
Full details of the Science Review are available at http://www.gmsciencedebate.org.uk.
5
An explanation of the origins and role of the Strategy Unit is set out in Annex A.
6
Full details of the FSA's activities are available at http://www.foodstandards.gov.uk.
20
The FSA Board has discussed the issues arising from these activities at an
open meeting held in May 20037
.
1.1.8 The AEBC is conducting a study on the important issues of co-existence
and liability as they relate to GM crops. Their report is expected to be
published later in summer 2003.
1.1.9 In addition to the Science Review, an important source of scientific
information on four specific GM crops will be the results from the "Farm Scale
Evaluations" (FSEs), described in Box 1.1 below. The results are expected to
be published in the autumn.
Box 1.1: The Farm Scale Evaluations
The Farm-Scale Evaluations are a three-year programme allowing
independent researchers to study the effect, if any, that the management
practices associated with Genetically Modified Herbicide Tolerant (GMHT)
crops might have on farmland wildlife, when compared with weed control used
with non-GM crops. Four crops are involved:
ˇ oilseed rape (spring sown);
ˇ oilseed rape (winter oil seed rape);
ˇ beet (fodder and sugar varieties); and
ˇ maize.
Trial sites have been situated in England, Wales and Scotland, and there
have been a total of 60-75 fields of each crop type, over three years. The
consortium of research institutions involved in the research is looking at
indicators of biodiversity in the GM and non-GM areas of each trial.
Comparison of these indicators will form the basis of published results. If the
analysis meets appropriate scientific standards, then the FSE results for the
three spring sown crops will be made available in autumn 2003. Results for
winter oil seed rape, which is a year behind the spring crops, will follow in
2004.
1.2 Definitions of GM crops and GM food
Terminology reflects the many different uses of GM crops
1.2.1 GM crops, like non-GM crops, have a range of current and potential
applications: human food, animal feed, textiles (e.g. cotton), and a range of
industrial uses (e.g. to make pharmaceuticals or health products). Many crops
are used for more than one purpose. Furthermore, GM crops are one
application of biotechnology, and in the USA they are often referred to as
"biotech crops".
7
See http://www.food.gov.uk/aboutus/ourboard/boardmeetings/pastmeetings/118783
21
1.2.2 The overall effect of this situation is the existence of a potentially
confusing array of terms. Many of these are described in more detail in
Chapter 2. However, some basic terminology is outlined in Box 1.2 below.
Box 1.2: GM definitions
Genetic modification (GM): The technology of altering the genetic material
of an organism by the direct introduction or removal of deoxyribonucleic acid
(DNA).
Genetically modified organism (GMO): An organism in which the genetic
material has been altered by the direct introduction (or removal) of DNA.
GM crops: One type of GMO: crop plants whose genetic material has been
altered by the direct introduction or removal of DNA in order to confer
particular characteristics on the plant.
GM food: A less well-defined term that applies with different degrees of clarity
to a range of foodstuffs. Regulations that will determine how these are
classified within the EU are outlined in Chapter 2. GM foods include:
ˇ Any food produced from a GM crop, and in which the altered DNA is still
present and detectable. E.g. food containing maize flour from GM maize,
or whole foods such as GM tomatoes.
ˇ Foods containing ingredients derived from GM crops but not themselves
containing the altered DNA, e.g. sugar from GM sugar beet or oil from GM
oil seed rape.
There are also some foodstuffs that are not commonly classed as "GM food"
although GMOs have some part in their production. These include:
ˇ meat or dairy products from animals fed with GM crops;
ˇ foodstuffs that use products derived from GM microbes either as
ingredients (some riboflavin is produced in GM microbes) or as processing
aids (a version of chymosin ­ the active ingredient in rennet ­ is derived
from GM microbes).
GM seed for sowing or GM grain for food use: Although they could grow into
GM crops they are not strictly speaking GM crops themselves. They are
generally described by the more generic term "GMO". GM crop grain which
has been milled into flour, and could not grow into a GM crop, would be
classed as GM food.
GM feed: GM crops used to provide animal feed.
GM non-food crops: a subset of GM crops that are not used in food or feed.
One significant example is GM cotton.
22
1.3 Recent events and policy processes
The recent history of GM crop controversies in the UK helps set the project
context...
1.3.1 Genetically modified crops ­ and the issues raised by their possible
cultivation and consumption ­ have attracted considerable controversy and
debate. For a short period in February 1999, these issues became front-page
news. Some of the events relating to those controversies are outlined in Box
1.3.
Box 1.3: GM food in the late 1990s8
Genetically modified tomato puree was assessed and approved for
consumption in the UK in 1995. In February 1996, shortly after this approval
was granted, tins of the puree began to appear on the shelves of two British
supermarkets ­ Sainsbury's and Safeway.9
The puree was the result of over
20 years of research and development on GM tomatoes. It was made from
GM tomatoes that contained more solids and less water than conventional
varieties10
. The product was sold between 10% and 15% cheaper than
traditional puree.11
There was little or no controversy attached to the product launch. The product
was clearly labelled, and a non-GM alternative remained available. Early
sales were good ­ at its peak, the GM tomato puree was outselling the
conventional tins by two to one.12
However, in 1998 the media reported some studies that appeared to show the
potential for damaging effects on the environment and human health from GM
crops and foods.13
At the same time, ingredients derived from GM crops
began to be used in a multitude of processed foods which were not labelled
as `GM'. The reaction by NGOs, consumers and the media was such that the
major retailers and food manufacturers acted to remove GM food from their
shelves ­ including the GM tomato puree that had sold so well.
8
A more detailed assessment of these events is available in the analysis paper: GM foods in
the late 1990s ­ an overview of the events and the media reaction (available on the project
website (www.strategy.gov.uk) or on request from the SU).
9
http://members.tripod.com/~ngin/tom.htm
10
Parliamentary Office of Science and Technology (1998), "Genetically Modified Foods ­
Benefits and Risks, Regulation and Public Acceptance".
11
Harvey M (1999), "Genetic Modification as a bio-socio-economic process: One Case of
Tomato Puree" CRIC Discussion Paper No 31.
12
Coombs T (1997), "Marketing Genetically Modified Foods", Lecture to `Future Foods '97',
Auckland, New Zealand.
13
Since then, there have been a variety of other reports, which have made similar claims. All
of these issues are being dealt with in the Science Review, but will not be addressed here.
23
...as does the rapid take-up of GM crops in other countries
1.3.2 Whilst GM crops and food have been particularly controversial in
Europe, their take-up in other parts of the world has been rising rapidly. The
total area planted with GM crops has grown by more than 10% every year
since their commercialisation in 1996 (see Figure 1.1 below). Between 2001
and 2002, the increase was 12%. Over 99% of the GM crops grown are
varieties of maize, soybeans, cotton and oil seed rape. Over 99% of these GM
varieties are herbicide tolerant and/or insect resistant.14
1.3.3 Sixteen countries worldwide currently grow GM crops commercially.
66% of the global area of GM crops can be found in the US. Nine developing
countries15
also have commercial GM crops: Argentina, China, South Africa,
India, Uruguay, Mexico, Indonesia, Colombia and Honduras. Of the area of
crops grown in developing countries, Argentina dominates with over 80% of
the growing area. China is next with about 13%, followed by South Africa with
about 2%. The other countries (plus Romania and Bulgaria) all have less than
100,000 hectares.
Figure 1.1 Global Area of GM crops from 1996 to 2002.16
Developments in policies and policy processes are highly significant to the
project context
1.3.4 Although the SU study has looked ahead to a 10-15 year time horizon,
current policy developments and processes play an important role. The wider
14
International Service for the Acquisition of Agri-Biotech Applications (ISAAA), "GM Crop
Update 2002", http://www.isaaa.org/.
15
Based on the OECD list of those countries in receipt of aid. See DfID (2002) "Statistics on
International Development".
16
ISAAA (2002) op cit.
0
10
20
30
40
50
60
70
1995 1996 1997 1998 1999 2000 2001 2002
GlobalareaGMcrops(Hamillion)
Total
Industrial Countries
Developing Countries
24
policy context is described in Chapter 2, but some recent events and trends
are worth highlighting here, in order to put the study into perspective:
ˇ Since 1998, a number of European Union (EU) Member States (not
including the UK) have pursued a moratorium effectively blocking
approvals for new applications for marketing consents for genetically
modified organisms (GMOs). This includes consents for the
commercial cultivation of GM crops. The regulatory framework has
recently been strengthened with the entry into force of Directive
2001/18/EC. However, some Member States consider that additional
traceability and labelling rules need to be in place before any decisions
on marketing of further GM products in the EU can be taken under this
framework.
In May 2003 the US, Canada and Argentina announced their intention
to file a complaint at the World Trade Organisation (WTO), on the
grounds that the failure of the EU to implement its approvals legislation
constitutes a barrier to trade.
ˇ In 1998, the UK Government reached a voluntary agreement with the
agricultural biotechnology industry that no GM crops would be grown
commercially in the UK until the results of the FSE trials had been
assessed.17
Irrespective of the uncertainty surrounding the EU
approval process, one of the crops in the FSE trials (herbicide-tolerant
maize) already has a marketing consent for commercial cultivation
anywhere in the EU. Apart from the voluntary agreement, and subject
to the FSE results, the only remaining legal obstacles to commercial
cultivation of this GM herbicide tolerant maize in the UK are the need to
secure approval under seeds legislation and under pesticides
legislation (for the associated herbicide use).
1.4 Project participants and process
Composition of the Strategy Unit team
1.4.1 The study was carried out by a multi-disciplinary team, including team
members with experience in economics, science, policy-making and working
in developing countries.18
None of the team had previously worked for
organisations with a financial interest in GM crops or GM foods, neither had
they been associated with campaigning activities on GM issues.
Links with other Government activities and external groups
1.4.2 Throughout the study, the team has worked closely with the Public
Debate Steering Board, and has reported regularly to the Board ­ often in
some depth ­ on work in progress. The team has also been in regular contact
17
Voluntary agreement with the Supply Chain Initiative on Modified Crops (SCIMAC),
November 1999
18
Membership of the project team, and more detailed information on working processes, is
given in Annex B
25
with the secretariat of the Science Review, and has attended meetings of the
Science Review Panel. In addition, the SU appointed Expert Advisory Groups
to assist with different aspects of its analysis.19
Although the input and
assistance of the Public Debate Steering Board, the Science Review Panel
and the Expert Advisory Groups have played a crucial part in the project,
because their role has been advisory, this report does not necessarily reflect
their views.
1.4.3 The team has held a number of meetings and discussions with a wide
range of stakeholders and experts from among NGOs, industry, farmers,
academia and elsewhere.20
The team has also had regular contact with
representatives from the key government departments with an interest in this
area, as well as with representatives from the Devolved Administrations. In
addition to contact with officials, the team has had regular meetings with the
study's Sponsor Minister, Margaret Beckett (Secretary of State for the
Environment, Food and Rural Affairs).
The Strategy Unit study had three phases
1.4.4 The study had three main phases, outlined below.
1. An extended period to determine the scope of the project. During this
phase the SU published a scoping note for comment (25 September
2002) and met a number of stakeholders and experts from inside and
outside Government. The SU received over 150 responses to its scoping
note, from a wide range of organisations and individuals. These
responses were published on the website, along with a summary of the
issues raised.21
2. An interim phase, during which the SU undertook an assessment of the
issues that it would need to address in its analysis, and developed a
methodology by which it could take these issues into account. The SU
made extensive use of its Expert Advisory Groups and discussions with
stakeholders, as well as holding a discussion with experts on "risk and
uncertainty".
These discussions highlighted the need for the SU project to be able to (i)
take into account a range of different potential futures for GM crops; (ii)
draw together the many disparate types of cost and benefit that might
arise; and (iii) explicitly take account of uncertainty in the analysis.
Scenarios provided one way to address these needs, and a workshop
with stakeholders and experts was held to develop a range of different
scenarios for the SU project. A brief description of the scenarios is given
in box 1.4 below; they are described in detail in chapter 4.
19
The function and membership of the Expert Groups is described in Annex B.
20
Annex C contains details of organisations consulted during the course of the whole study
(August 2002 ­ June 2003).
21
The scoping note, responses and summary of responses are available on the project
website.
26
On 30 January 2003, the SU published an overview methodology paper
and a series of working papers. Over 60 responses were received, and
these have been published on the project website.22
3. A final, analytical phase, in which the SU put its methodology into practice
in analysing the costs and benefits that could arise under the different
scenarios. This report, together with the analysis papers available on the
project website, was produced at the end of this analytical phase.
Meetings and correspondence with stakeholders and experts remained
important during this phase of the study, and the SU also held a seminar
on 3 April 2003 in which stakeholders and experts debated possible
"shocks and surprises" that could disrupt the scenarios.23
The shocks and
surprises are described in detail in chapter 4.
Box 1.4: Scenarios used in SU study
UK PUBLIC
ACCEPTS GM
UK PUBLIC
REJECTS GM
GM-SPECIFIC
REGULATIONS
NON-GM-SPECIFIC
REGULATIONS
Tangled
threads
Bare
minimum
Separate
weave
Part of the
fabric
Not made
in the UK
ˇ Scenario 1: `Part of the fabric' ­ the public largely accepts GM crops and
foods, and therefore significant cultivation of GM crops occurs, with the
regulatory regime increasingly treating GM crops and foods much like any
other novel foodstuff;
ˇ Scenario 2: `Separate weave' ­ the public increasingly accepts GM crops
and foods, and GM crops are gradually introduced under a strict GM-
specific regulatory regime including a stringent approvals process, post-
market monitoring and labelling;
ˇ Scenario 3: `Bare minimum' ­ public attitudes are largely opposed to GM
crops and foods, and there is a strict regulatory system, leading to very
little GM cultivation in the UK;
ˇ Scenario 4: `Tangled threads' ­ there is a breakdown between negative
public attitudes and regulations which fail to maintain a separation
between GM and non-GM crops grown in the UK;
ˇ Scenario 5: `Not made in the UK' ­ an explicit decision is made against
the commercial cultivation of GM crops in the UK, with the public preferring
conventional or organic produce.
22
The overview methodology paper, working papers and responses are available on the
project website, along with a note of the scenarios workshop.
23
A note of the "shocks and surprises" seminar is available on the project website.
27
1.5 Scope and limitations of this report
Scope of the Strategy Unit project
1.5.1 In its assessment of the overall costs and benefits of GM crops, the SU
study has focused on a 10-15 year time horizon, though data availability has
meant that much of the analysis has centred on the types of GM crop that
may be available over the next few years.
1.5.2 The SU study has recognised that there are uncertainties in many areas
relevant to the costs and benefits of GM crops. The incorporation of scenarios
and "shocks and surprises" into the project has played an important role in
helping the SU to explore and take into account different types of uncertainty.
The scenarios allowed the SU to consider some of the uncertainties that are
involved in looking forward 10-15 years ­ uncertainties that arise from the
interactions between a range of currently-identified variables. "Shocks and
surprises" allowed the SU to think how different potential futures might be
disrupted - not by predictable changes to identified variables, but by events
that are currently unforeseen.
1.5.3 There are also uncertainties that arise from absences in data availability
or from disputed interpretations of existing information. The Science Review
has played an important role in seeking to clarify some of the scientific
uncertainties. But numerous other uncertainties remain, and these are
reflected in the many qualitative ­ as well as quantitative ­ elements to the
study. Some of the key areas are outlined below.
ˇ Although there is a large body of international research on the commercial
growing of GM crops, some of this is subject to contradictory
interpretations, and its applicability to the UK needs to be treated with
caution. It also covers a relatively short time period. As there has been no
commercial-scale cultivation of GM crops in the UK, there is also limited
domestic evidence of agronomic24
or environmental impacts.
ˇ There is very little research on the economic and environmental impacts of
conventional and organic farming. This makes it hard to establish an
analytical baseline against which the economic and environmental impacts
of GM crops may be assessed.
ˇ There are also significant uncertainties inherent in looking forward over the
10-15 year time horizon considered in this study. For instance, the UK and
international policy environment, public attitudes, and the state of science
may well change over this time period.
1.5.4 In this context, it is important to be clear exactly what the SU study has
not done:
24
i.e. relating to soil management or crop production.
28
There is no attempt to provide a single "net present value" of
total costs and benefits; neither has the study attempted to make
policy recommendations.
This report is general, not specific, in nature
1.5.5 Many of the issues that relate to GM crops ­ their potential impacts on
farming, the environment, human health, and economic activity ­ are highly
specific to individual crops and traits. In some cases, the potential for
differences are obvious: the potential impacts of a GM herbicide tolerant oil
seed rape variety for use in cooking oil will be different from those of a GM
potato containing starch for use in industrial manufacturing. In other cases,
superficially similar GM crops may have very different impacts: a GM
herbicide tolerant sugar beet variety could have different impacts from a GM
herbicide tolerant wheat variety.
1.5.6 Consequently, many analyses of GM crops need to be highly specific.
This is the basis for the current EU regulatory approach, where individual GM
crops are assessed on a case-by-case basis.
1.5.7 The SU analysis has recognised that generalisations about the impacts
of GM crops are not always possible, and many areas where the analysis
differs according to the particular crop variety have been highlighted.
However, the overall report is positioned as far as possible at a general level.
Its purpose is to look forward over a 10-15 year timescale and to inform the
overall direction of policy towards GM crops as a whole. This in turn dictates
the level of assessment in the report, and the focus (in the main) on broad
trends and qualitative descriptions, rather than on quantitative data.
1.5.8 The report should thus be seen as a complement to ­ not a substitute
for ­ more specific analysis of individual issues and decisions.
The analysis presented in this report cannot be regarded as definitive
1.5.9 This report is presented not as a statement of Government policy or
thinking, but as a contribution to future policy decisions on GM crops and
food.
1.5.10 It will be for Government to take a view on policy implications after it
has received the full suite of outputs from the GM dialogue ­ including the
report presented by the Public Debate Steering Board, the final assessment of
the Science Review, the results of the FSEs and the work carried out by the
FSA.
1.5.11 This report should be seen as a first attempt to take an overview of the
costs and benefits associated with GM crops. There appears to be scope for
and value in continuing the kind of analysis contained within this report. An
overall understanding of the economic impacts of the UK's approach to GM
crops is a valuable resource for decision-making. As technology develops,
some knowledge gaps are filled in, and new methodologies for assessing
costs and benefits are invented, improved understanding of these impacts will
29
become possible. However, there are some inevitable limits to a costs and
benefits approach ­ economics is unlikely to capture the ethical and social
issues which GM crops will raise.
But decisions can and must be made
1.5.12 Although more clarity is expected to emerge over time, this does not
mean that decisions affecting the UK's approach to GM crops cannot be taken
now. Combined with the results from other strands of the GM dialogue, the
FSE results and other relevant information, the analysis presented here ­
including the identification of areas of uncertainty ­ should provide sufficient
basis for such decisions.
1.6 Structure of the report
1.6.1 The remaining chapters of this report cover the following:
ˇ Chapter 2 sets out the broad backdrop of science, regulations, public
attitudes and wider policy objectives within which GM crops have
relevance;
ˇ Chapter 3 summarises the most important costs and benefits identified in
the Strategy Unit's analysis;
ˇ Chapter 4 compares costs and benefits in a range of different scenarios; it
also considers shocks and surprises and makes an overall assessment of
the results of the analysis; and
ˇ Chapter 5 explains what happens next.
1.6.2 Annexes provide further details on the processes behind the preparation
of this report. They cover:
ˇ the role of the SU;
ˇ the Project Team, Sponsor Minister, Expert Advisory Groups;
ˇ organisations consulted and submissions received; and
ˇ the GM Dialogue: links with the Public Debate and the Science Review.
1.6.3 There are also a number of analysis papers available on the SU web
site25
which expand on the analysis set out in this report - along with the
working papers published part-way through the project.
25
Paper copies of the analysis papers are also available on request from the SU
30
Chapter 2: The backdrop for GM crops: science,
regulations, public attitudes and wider policy
Summary
ˇ Biotechnology has a wide range of current and future applications.
Genetic Modification is one technique used in wider biotechnology. GM
crops are one type of GMO and one aspect of agricultural biotechnology.
ˇ There is a wide-ranging regulatory framework in place. Regulatory
authorities have already taken steps to tackle potential environment and
health issues that could arise from the development of GM crops.
ˇ Public attitudes will be important in determining the future of GM crops
and foods in the UK. Surveys on GM foods over the past few years have
generally revealed a negative public attitude towards GM food. There are
complex sets of issues that lie behind such results.
ˇ GM crops are not an end in themselves, they need to be considered in
the context of the Government's objectives in a number of policy areas.
They also need to be considered alongside alternative approaches.
ˇ The wider policy context for GM crops includes agricultural and
environmental policy; rural policy; science, innovation and
competitiveness policy; policy on food safety and quality; and
international development policy.
This chapter explains the general backdrop against which any assessment of
GM crops needs to be made. It starts by explaining how GM crops fit within
the wider context of biotechnology, and considers the different types of uses
to which GM crops ­ and their alternatives ­ may be put (section 2.1). The
regulatory regime that governs GM crops is then described (section 2.2), and
this leads to a discussion of public attitudes to GM (section 2.3).
The chapter then goes on to point out that GM crops and foods ­ and the non-
GM alternatives ­ need to be assessed in terms of their contribution to a
range of environmental, social and economic objectives ­ they are not an end
in themselves. In view of this, the chapter then explains the key objectives
relating to rural policy, agricultural policy, science policy and policy on food
safety (section 2.4) against which any impacts of GM crops need to be
assessed.
31
2.1 GM crops in their scientific context
GM crops and wider biotechnology
2.1.1 Biotechnology is a rapidly-expanding area of activity. It is a general term
that encompasses many different aspects of scientific research and industrial
applications. In many cases, the applications have more importance in terms
of their future potential than in their current contribution.
2.1.2 GM crops are only one set of biotechnology applications. In order to
describe GM crops in their wider context of related biotechnology activities,
the following sub-sections outline biotechnology at its most general, and how
genetic modification is used in biotechnology, before turning to look
specifically at GM crops, and how they fit into this overall picture.
Biotechnology has a wide range of current and future applications
2.1.3 Biotechnology can be defined as the application of knowledge about
living organisms, and their components, to make new products and develop
new industrial processes.26
The term covers a diffuse range of techniques,
many of which relate to recent advances in genetics research, and a wide
range of applications.
2.1.4 The principal areas where biotechnology has been applied to date
include medicine and health care (sometimes referred to as "red"
biotechnology) and agriculture ("green" biotechnology). The use of
biotechnology in industrial production - e.g. using enzymes in pulp, paper and
food processing - ("white" biotechnology) is also significant27
.
2.1.5 The European Commission has described biotechnology as "the next
wave of the knowledge-based economy" to follow information technology.
Biotechnology has the potential to generate skilled jobs28
and significant
sources of revenue, as well as delivering social objectives, by offering
"opportunities to address many of the global needs relating to health, ageing,
food and the environment, and to sustainable development".29
Some
indication of the economic significance of biotechnology is provided in box 2.1
below.
26
DTI (1999) "Genome Valley", a report on the economic potential and strategic importance
of biotechnology in the UK.
27
Europabio (2003), "White biotechnology: Gateway to a More Sustainable Future".
28
Tait, J et al (2001), "Policy Influences on Technology for Agriculture ­ Final Report".
European Commission DG XII Project No. PL 97/1280
29
COM (2002) 27, op cit.
32
Box 2.1: The economic significance of biotechnology.
Biotechnology lacks an agreed definition of its scope and boundaries that can
be used with industry classifications of national statistics30
. The main reason
for this is that biotechnology is an enabling technology not an end in itself ­
biotechnology is applied in many different sectors, from agriculture to
pharmaceuticals.
There are some companies (primarily small and medium-sized enterprises
(SMEs)) whose business can fairly be described as entirely biotechnology-
based. 2001 survey data indicate that the UK has almost 400 such firms,
employing more than 18,700 people, with revenues of over 1.8 billion31
.
However, biotechnology SMEs comprise a relatively small amount of activity
compared to large businesses and broad sectors of the economy where
biotechnology could find some uses. In 1999, the DTI stated that "the
industrial sectors which stand to benefit from biotechnology....employ over
1.75 million people in the UK and account for over 10% of UK GDP (i.e. 90
billion in 1999)".
The European Commission has estimated that by 2010, global markets for
sectors where biotechnology is likely to constitute a major portion of new
technology applied (excluding agriculture) could be worth over 2000 billion
(1300 billion).32
The USA is the world leader in biotechnology, but the UK is also well
positioned: it vies with Germany as the leader in the EU33
. The UK leads
Europe in terms of the market capitalisation of its biotechnology companies, in
terms of revenues generated, and in terms of the amount of venture capital
financing of the sector34
.
Genetic Modification is one technique used in wider biotechnology
2.1.6 The rapid expansion of biotechnology in recent decades has resulted
mainly from advances in the understanding of genes and how they function.
Some information about genes and genetic modification is given in box 2.2
below.
Box 2.2: Genes and Genetic Modification
All plants and animals contain genes ­ humans, for example, contain about
30,000 genes. Genes are lengths of DNA. They work by controlling the
production of proteins, which in turn determine the physical characteristics of
an organism and many of its responses to environmental stimuli.
30
M. Nawaz (2003) "Capturing the Economic Potential of all GM crops for UK plc".
31
DTI data; see http://www.wired-gov.net/WGLaunch.asp?ARTCL=15984
32
Life sciences and biotechnology ­ A Strategy for Europe COM (2002) 27.
33
Allansdottir, A et al (2002), "Innovation and competitiveness in European biotechnology",
Enterprise Directorate-General, European Commission Paper No. 7.
34
Ernst and Young (2003), "Endurance ­ the European Biotechnology Report".
33
Although the cells in an organism contain the same DNA, not all genes are
active in all the cells ­ allowing parts of an organism to differ from one
another. For example, cells in the liver express different genes to cells in the
brain. In addition, genes need other sequences of DNA (called promoters) to
switch them on, and it is these promoters that determine where in the
organism (and when in its life cycle) particular genes are active. The complete
set of DNA in an organism forms that organism's genome. Research to
understand the structure, function and evolution of genes is called genomics.
Knowledge of how DNA operates on a molecular level, and in particular how
its chemical sub-units can link, split and re-unite (known as recombinant
DNA technology) enables scientists to chop and splice DNA and to
manipulate individual genes. Any organism that has been manipulated in this
way is called a GMO. For the purposes of this report, genetic modification is
defined as altering the genetic material of an organism by the direct
introduction or removal of DNA.
2.1.7 One of the key ways that GM fits into wider biotechnology is as a tool in
fundamental research. GM enables scientists to make controlled changes in
genetic structures and so to test what each gene does. GM microbes, plants,
fish, insects, amphibians and mammals have all been created for research
purposes to understand gene function. GM animals (especially GM mice)
have been developed as models for humans in medical research.
2.1.8 Without the ability to genetically modify different organisms it would be
very difficult to interpret the mass of DNA sequence data (including human
genome data) that is being generated in laboratories around the world.
Genome sequence data itself is of little interest, but once the functions of
different genes and combinations of genes are identified, the relationships
between genetics and (for example) the causes of and susceptibility to
disease, or the productive yield of an agricultural crop, can start to be
explored.
2.1.9 Another important relationship between GM and wider biotechnology
comes from creating specific GMOs with marketable characteristics ­ this is
one way to generate commercial applications of biotechnology. Such GMOs
include:
ˇ GM microbes, GM crops and GM animals that act as "factories",
producing pharmaceutically-active proteins;
ˇ GM microbes that act as factories to produce enzymes for food
processing;
ˇ GM crops with modified agronomic or food quality traits; and
ˇ GM fish to increase growth rate in aquaculture.35
35
GM microbes producing pharmaceuticals and enzymes etc. are in widespread commercial
use. The products from GM microbes currently used in food include chymosin for cheese
production and riboflavin (vitamin B2). See Consumers' Association (2002) "GM Dilemmas".
34
2.1.10 However, it is important to stress that applications of biotechnology are
not limited to the use of GMOs. Much of the knowledge that genetics and
other biological research has generated about living organisms can be applied
in other ways. For example, understanding how microbes can take up and
process pollutants has led to a number of uses for non-GM microbes in
cleaning up polluted soil.36
Within agriculture, biotechnology is also used to
develop diagnostic techniques to improve targeting of pesticide applications.
Fungicides based on biodegradable products have also been developed using
biotechnology.
GM crops are one type of GMO and one aspect of agricultural biotechnology
2.1.11 Thus there are two contexts that relate GM crops to wider
biotechnology. First, GM crops are one type of genetically modified organism,
and have potential uses in common with other GMOs e.g. as research tools
and as potential producers of specific valuable biomolecules. When assessing
costs and benefits of GM crops in this context, it makes sense to compare GM
crops with other GMOs or with alternative technological methods of producing
new materials or synthesising complex molecules.37
2.1.12 Second, GM crops are one of the ways that advances in biotechnology
can be applied to agriculture ­ that is, they are one element of agricultural
("green") biotechnology. To be more specific, they represent one way that
biotechnology can be used to support the development of new crop varieties.
When assessing costs and benefits of GM crops in this context, it makes
sense to compare GM crops with other types of crop rather than other GMOs.
Box 2.3 sets out a number of techniques of producing new crop varieties,
including genetic modification.
Box 2.3: GM and other methods of plant breeding
There is a wide range of methods through which genes conferring desirable
characteristics can be introduced into crop varieties; traditional plant breeding
is at one end, GM is at the other.
ˇ Traditional plant breeding, whereby different varieties of crops are cross-
bred to create a number of different offspring. Those that possess
desirable characteristics are selected and multiplied up.
ˇ Marker-assisted breeding, whereby offspring from crossing experiments
are screened to see if they contain desired genes at an early stage in the
breeding programme.
GM crops with agronomic and food quality traits have been commercialised in a number of
countries around the world. GM crops and animals for pharmaceutical production, and GM
fish in aquaculture, are at the research and development stage and are yet to be
commercialised.
36
All commercial uses of bio-remediation in the USA use naturally-occurring micro-
organisms. Biotechnology Indicators and Public Policy, OECD Directorate for Science,
Technology and Industry May 2002, DSTI/EAS/STP/NESTI(2002)8.
37
Some examples of such comparisons are provided in the analysis paper: Analysis of the
Costs and Benefits of GM crops to Industry and Science (available on the project website or
on request from the SU).
35
ˇ Induced mutation, whereby doses of radiation or mutagenic chemicals are
used to make random changes to the DNA within plant cells. The
alterations in the DNA can confer novel characteristics on the plants.
Plants with new, valuable characteristics can be used in traditional plant
breeding programmes.
ˇ Protoplast fusion, whereby individual cells with their outer walls removed
are fused, and the resulting single cell grown in a culture medium.
ˇ Embryo rescue, whereby plant embryos created from cross-fertilisation are
removed and grown outside the parent, allowing the creation of offspring
from crosses that might otherwise fail to produce viable seed.
ˇ Tissue culture selection, whereby a nutrient medium is used to grow many
millions of individual plant cells, which are then exposed to damaging
conditions or chemicals (e.g. herbicides) ­ only cells which happen to
possess elevated levels of resistance to the hazard will survive.
ˇ Genetic modification, whereby specific genes are inserted or removed into
/ from the plant genome in order to confer desirable characteristics on the
plant. Inserted genes can come from any species.
Developments in new techniques may increasingly mean that the boundary
between GM and non-GM crops will be blurred. Genetic modification already
shares some similarities with other techniques ­ for example, marker-assisted
breeding ­ which are based on genomics.
GM crops and alternative approaches
GM crops are currently limited to a small number of crop and traits
2.1.13 Although some of the first GM crops to be sold were GM tomatoes,
there have been very few GM fruits or vegetables brought to commercial
cultivation. Most GM crops are broad acreage commodity crops. To date there
have been just two main traits expressed in the vast majority of commercially
cultivated GM crops:
ˇ Herbicide tolerance: this trait renders the crop tolerant to a particular
herbicide, and means that a field can be sprayed with that herbicide
without risk of damage to the crop.38
ˇ Insect resistance: this trait renders the crop resistant to certain types of
insect that would otherwise damage the crop.
2.1.14 This study has looked closely at the current generation of herbicide
tolerant and insect resistant crops ­ especially those that are likely to be
relevant to the UK. Because these crops have been commercially cultivated
elsewhere, there is a body of evidence about them which is readily available.
However, because this study has considered a 10-15 year timescale, it has
38
Herbicides are a form of pesticide that is used to kill weeds. The term "pesticides" is used
generically to cover all chemical treatments aimed at the destruction of living organisms that
would otherwise damage crops (or animals or people). As well as herbicides, this includes
fungicides (used to kill fungal diseases) and insecticides (used to kill insects).
36
been important to consider also the potential future generations of GM crops
that may be suitable for commercial cultivation in the UK.
A wider set of crops and traits may become available in the future39
2.1.15 Looking ahead, a wider range of GM crops could be developed that are
relevant to the UK. Possibilities include:
ˇ the application of GM technology to a wider range of crop types suitable
for UK conditions, such as GM wheat and GM potatoes;
ˇ a range of more valuable agronomic traits, such as resistance to common
UK pests and plant diseases, or improvements to the efficiency with which
crops can absorb nutrients;
ˇ GM foods with consumer benefits, such as longer shelf life, or health
benefits, such as improved nutritional content or reduced allergenicity; and
ˇ a wide range of non-food crops, which could include crops used as
"factories" for a range of goods, such as pharmaceuticals, industrial oils, or
renewable materials; as well as crops which could be used directly in the
production of energy or fuel.
2.1.16 Any benefits or costs from these crops could in principle accrue to a
wide set of interests, including food manufacturers, retailers, consumers and ­
especially for non-food applications - a diverse range of industrial sectors.
GM may have a unique role in some circumstances, but alternative
approaches could deliver similar traits and outcomes
2.1.17 GM techniques are not the only means by which desirable traits for
crops can be developed. Non-GM breeding techniques have already delivered
crops that are tolerant to broad spectrum herbicides.40
Such crop varieties are
not subject to the controls imposed by the GMO legislation.41
However, GM
may sometimes be the only way of breeding a particular characteristic. This is
most likely to be the case with characteristics that are governed by a small
number of genes, particularly in circumstances where:
ˇ the required genes are not found in the gene pool of related plants. For
example, crop plants developed to produce commercially viable amounts
of novel high value industrial chemicals will often need to be GM;42
or
39
A list of traits ­ and the crops to which they may be applied ­ was included in the Strategy
Unit's "Background Working Paper for the Analysis of the Costs and Benefits of Industry and
Science", available on the project website.
40
For example, oil seed rape tolerant to sulphonylurea herbicides.
41
However, the Government's Advisory Committee on Releases to the Environment, ACRE,
has said that, "We have no reason to believe that conventionally bred crops with novel traits
such as tolerance to broad-spectrum herbicides would not pose similar risks as those
produced via genetic modification techniques." (ACRE (1999) "The Commercial Use of
Genetically Modified Crops in the United Kingdom: the Potential Wider Impact on Farmland
Wildlife", available at http://www.defra.gov.uk/environment/gm/wildlife/index.htm.)
42
DEFRA (2002) Annual report of the Government-Industry Forum on Non-Food Crops.
37
ˇ the required genes need to be rapidly introduced into elite crop varieties.
For example, genes conferring resistance to rapidly-evolving pests might
be present in old cultivars but cross-breeding these might result in the
elite variety losing many of its other desirable characteristics.
2.1.18 GM may be less helpful in enhancing quantitative traits that depend on
the action of many genes, each of which has a relatively small impact on the
trait. Examples include complex phenomena such as the dependence of crop
yield on environmental conditions.43
2.1.19 Different approaches to farming are also relevant. Organic farming
aims to produce food of good nutritional quality by using management
practices which aim to avoid the use of agrochemical inputs and to minimise
damage to the environment and wildlife.44
While there are some pesticides
approved for use in these systems, organic farmers seek to use non-chemical
alternatives ­ for example, natural predators to kill damaging insects; crop
rotations to maintain soil fertility; or companion planting to avoid build-up of
pests.
2.1.20 A related approach ­ though without the same underlying ethos and
principles of organic farming ­ is integrated pest management (IPM). IPM
involves a combination of methods to achieve effective pest control whilst
minimising pesticide use and adverse effects on non-target species. GM
crops could form part of IPM approaches. The use of IPM is being
encouraged as best practice in farming through initiatives such as LEAF ­
Linking Environment And Farming.45
The agronomic utility of GM crops and their alternatives is only a small part of
the story
2.1.21 GM crops raise many more issues than simply how to introduce a
particular trait into a particular crop variety. Like any new technology,
applications of biotechnology and genetic modification, including GM crops,
could possibly cause some unwanted effects. Attempting to avoid the
potential "downside" of any new technology is (in part) the job of government
regulatory regimes. The regulations that cover GM crops (often part of
regulations governing all GMOs) are described in the following section.
43
See the Industry and Science Analysis Paper, available on the project website.
44
See, for example, http://www.defra.gov.uk/farm/organic/default.htm for more details.
45
See http://www.leafuk.org/leaf/
38
2.2 The fundamentals of GM crop regulatory policy46
The regulation of genetic modification reflects concerns about a number of
potential adverse effects
2.2.1 Regulations governing research and uses of genetic and reproductive
science were developed because of concerns about the increasing ability to
change the genetics of living creatures. In broad terms, these concerns reflect
three areas of adverse effects that could arise as a result of genetic
modification:
ˇ effects on biodiversity as a result of releasing GMOs into the environment;
ˇ human health effects of GMOs; and
ˇ ethical issues raised by the kinds of changes scientists could make ­
particularly in respect of humans and higher mammals.
2.2.2 Regulations are required because the costs of harm would generally not
be borne by those causing the damage.
2.2.3 Apart from general support to overcome barriers to R&D, there is no
direct regulatory intervention to promote GMOs with desirable traits or
characteristics ­ the presumption is that the market will be willing to pay the
going rate for these innovations.
There is a framework of EU and international regulations
2.2.4 The import and cultivation of GM crops has been regulated at EU level
since 1990. Overall, current EU regulatory policy for GM crops seeks to
ensure that they:
ˇ present no unacceptable adverse risks to human health and the
environment; and
ˇ can circulate freely as products on the EU single market, provided all
appropriate measures are taken to avoid adverse effects.
2.2.5 The basis for the regulation for GM crops is Directive 2001/18/EC on the
deliberate release into the environment of genetically modified organisms,
described in Box 2.4 below.
46
An overview of the regulatory context pertaining to GM crops is available - see the analysis
paper Regulations and GM crops: Key Questions answered (available on the project web site
or on request from the SU).
39
Box 2.4: EU regulations on the release of GMOs into the environment
Directive 2001/18/EC on the deliberate release into the environment of
genetically modified organisms was adopted by the Council of Ministers in
February 2001.47
It aims to strengthen the safety assessment of GMOs, and
to improve transparency and public consultation. The new regime applies to
applications for commercial releases of GMOs, including cultivation within the
EU as well as imports of commodities produced outside the EU, and to
research trial releases.
As with the previous Directive, decisions to approve GM crops are taken on a
case-by-case basis, following a scientific assessment of any risks to human
health and the environment. Ethical and socio-economic issues are not
directly taken into account in assessing individual consent applications, but
the Directive contains provision for these issues to be considered at a general
level. The regulations also require a plan for post-market monitoring to be put
in place.
Following the entry into force of Directive 2001/18/EC, a number of new
applications have been made for the commercial importation and cultivation of
GMOs within the EU. These applications have entered into a formal process
of assessment by Member States, as laid down in the Directive, which sets
out procedures and deadlines for decisions to be taken by Member States
and the European Commission. If a consensus on any application can not be
reached, decisions can be made by qualified majority voting.
2.2.6 EU and UK decisions about GM regulations are influenced by
international agreements. Regulations need to be consistent with broader
multilateral obligations embodied in a number of key agreements summarised
in table 2.1.
Table 2.1: Multilateral Agreements Relevant to UK and EU Decisions on
GM Crops
Policy Description
The role of the
World Trade
Organisation
(WTO)
ˇ WTO agreements cover goods, services, intellectual property, dispute
settlement and policy review;
ˇ Countries bring disputes to the WTO if they think their rights under the
agreements are being infringed;
ˇ No trade dispute over GMOs has yet been examined by a WTO panel
but one has been recently filed and is in the consultation stage
48
.
The Cartagena
Protocol on
Biosafety
ˇ The Cartagena Protocol on Biosafety is a multilateral environmental
agreement focussing on the transboundary movements of GMOs;
ˇ The key provisions of the Protocol set out internationally-agreed
operative procedures under which countries can decide whether to
allow imports of GMOs that may affect biodiversity.
ˇ 103 countries have signed the Protocol, and over 50 countries have
47
It was transposed into national legislation in England in October 2002, in Scotland and
Wales in December 2002 and in Northern Ireland in April 2003.
48
References in this document relate to information available to the project team up to and
including 20
th
June 2003.
49
http://www.biodiv.org/biosafety/
40
now ratified it. It will enter into force on 11 September 2003
49
. The UK
will complete ratification during 2003 once the relevant implementing
EU measures are in place.
Codex
Alimentarius
ˇ Codex Alimentarius is a set of international codes of practice,
guidelines and recommendations pertaining to food safety and quality
­ it includes principles (currently in draft) for risk analysis of GM foods
and related guidelines for the safety assessment of foods from GM
plants.
Overall, there are a wide range of regulations that affect GM crops in the UK
2.2.7 Specific regulations for GM crops in the UK apply at a number of
different levels, related to different types of use. The following list indicates the
main types of use, all of which are regulated under EU directives.
ˇ Contained use, i.e. GM crops being researched inside laboratories,
industrial production plants or greenhouses. As with all contained use of
GMOs, this is regulated by the Health and Safety Executive (HSE) under
the Genetically Modified Organisms (Contained Use) Regulations (2000).
ˇ Field trials, i.e. GM crops that are being grown in small-scale non-
commercial research trials in the field. These must be approved under
Directive 2001/18/EC. Release of GMOs into the environment is regulated
by DEFRA and by the Devolved Administrations, with guidance from the
Advisory Committee on Releases to the Environment (ACRE).
ˇ Market release, i.e. GM crops that are intended for commercial release
onto the EU market. These are also governed by Directive 2001/18/EC,
and approval is required for crops that are going to be imported into the
EU, cultivated in the EU and / or processed in the EU. Approvals are again
based on a risk assessment, but apply across the whole of the EU.
ˇ Food and food ingredients. In addition to gaining approval under
Directive 2001/18/EC, any GM crop that is intended for use as human food
or as a food ingredient must meet Novel Food regulatory requirements.
The focus of the assessment is on differences compared with existing
foods that are otherwise "substantially equivalent". The FSA is the
competent authority, advised by the Advisory Committee on Novel Foods
and Processes (ACNFP).
ˇ Seeds and varieties. New varieties ­ whether GM or conventional ­ can
only be marketed to farmers if they are shown to be distinct, uniform and
stable and have been added to the UK National List or the EU Common
Catalogue (an amalgam of the National Lists of Member States).
ˇ Pesticides. Pesticide approvals are limited to uses with specific crops for
specific purposes at specific times of the year. Any new pesticide/crop
combination needs to be approved by the Advisory Committee on
Pesticides. Such approvals would be needed for many new crops,
including some herbicide tolerant GM crops.
41
2.2.8 Looking to the future, there are a number of new regulations currently in
negotiation:
ˇ Regulation on Food and Feed. This would replace the existing approvals
procedures for GM foods and introduce new rules for the approval of GM
animal feed. Its main impact will be to take the approvals process into a
"one stop shop", operated by a new European Food Safety Authority. It
would also introduce new authorisation requirements for products derived
from GMOs, but containing no GM material, and specify stricter labelling
requirements for food and feed.
ˇ Regulation on Traceability and Labelling. This would extend the rules
currently set out in Directive 2001/18/EC, by seeking further harmonisation
of systems to trace and label GMOs. It also contains requirements for
identification of bulk shipments of GM commodities. Like the food and feed
measure, it would for the first time apply requirements to GM-derived
products.
ˇ Commission Proposals on Adventitious Presence.50
These would
tighten the rules for the extent to which a product or seed may still be
classed as "non-GM", even if it contains some adventitious presence of an
approved or non-approved GMO. These rules would be introduced under
the two measures above and under existing seeds directives.51
ˇ Regulation on Transboundary Movements of GMOs. This would
complete EU implementation of the Cartegena Protocol on Biosafety,
mainly by supplementing the existing rules on imports of GMOs under
Directive 2001/18/EC with new rules on exports of GMOs to third
countries.
There are different national approaches to GM crop regulation around the
world
2.2.9 All existing regulatory systems governing the uses of GM techniques in
food and agriculture are based broadly on assessments of safety for human
health and the environment. There is general agreement that such systems
"need to be science-based, transparent and involve community participation,
and that safety assessments should be undertaken on a case-by-case
basis".52
2.2.10 Within such overall agreement, two distinct approaches have emerged:
regulations based on the safety of the product, versus regulations based on
the process by which the product is produced. Essentially, this splits
regulations into ones which assess GMOs and their products because they
are novel (USA, Argentina, Canada, China, Japan) and those that assess
GMOs and their products because they have been created using genetic
50
Adventitious (or accidental) presence of GMOs occurs when GMOs are found to be in what
is ostensibly a non-GM product or seed.
51
See the Regulations Analysis Paper, available on the project website, for further details.
52
International Council for Science (2003) "New Genetics, Food and Agriculture: Scientific
Discoveries ­ Societal Dilemmas".
42
modification (EU, Australia).53
In addition, the interpretation of risk
assessment and management differs amongst countries and regions.54
2.2.11 Within each major grouping there are different mechanisms through
which the assessments are made. In the USA it was decided that no new and
specific biotechnology regulation system was required, and existing
assessments of food and agriculture could be applied to GM crops. In
Canada, a new regulatory framework for biotechnology was developed, but
this assesses all plants or products with new traits or attributes, irrespective of
whether these were developed using GM or more traditional plant breeding
methods. In China, product-based assessments also contain explicit
consideration of "the economic interest" of the GM crop.55
2.2.12 Regulations based on process also vary. The EU approach is outlined
in 2.2.6 and 2.2.7 above. Australia passed a Gene Technology Act in 2001 to
regulate research, manufacture, production and importation of all organisms
that have been genetically modified. The Act created a new Office of the
Gene Technology Regulator to oversee and enforce all regulations relating to
the use of GMOs.56
Not all relevant regulations relate directly to GM Crops
2.2.13 Another set of regulations that is important for GM crops ­ and for
biotechnology more generally ­ is the regulatory regime governing patents
and Plant Breeders' Rights. These different forms of intellectual property
protection affect the ability of those involved in developing new crop varieties
to derive financial returns from their research, and help shape the kinds of
research that is conducted. They are described in Box 2.5.
Box 2.5: Patents and Plant Breeders' Rights
Patents are "an exclusive right given to an inventor to exclude all others from
making, using and/or selling the invention".57
The exact right afforded
depends on which country issued the patent. Patents can be given for
products and processes. They are limited to a fixed period ­ at least 20 years
under the TRIPS agreement58
­ after which the invention moves into the
public domain and can be exploited by anyone.
It is not possible to patent a plant variety in its own right. However, it is
possible to patent the use of an invention within a plant ­ such as a GM plant.
53
J-P Nap et al (2003) The release of genetically modified organisms into the environment.
Part 1. Overview of current status and regulations. The Plant Journal, Vol. 33, pp1-18.
54
International Council for Science (2003) op cit.
55
J-P Nap et al (2003) op cit.
56
J-P Nap et al (2003) op cit.
57
Taken from entry on "Patent(s)" in Table 1 of Kowalski, Stanley P., Ebora, Reynaldo V.,
Kryder, David R. and Potter, Robert H. (2002) "Transgenic crops, biotechnology and
ownership rights: what scientists need to know", The Plant Journal 31(4), pp 407-421.
58
The TRIPS (Trade-Related aspects of Intellectual Property Rights) Agreement is one of
three pillars of the World Trade Organisation (WTO), alongside trade in goods and trade in
services. All parties to the WTO are required to comply with TRIPS ­ though some
(developing) countries have a derogation until 2006.
43
For example, a patent could be granted on a gene for frost resistance. The
patent might cover the gene in its isolated form, and the gene when in a plant
variety.59
Plant Breeders' Rights (also known as Plant Variety Rights, PVRs) are a form
of intellectual property designed to protect new varieties of plants. Once
protection has been granted, it lasts for 25 years (30 years for trees, vines
and potatoes). As with patents, the owner's consent is required for most uses
of the propagating material of the plant variety (usually granted in return for
royalties on seed sales).
There are some important differences between patents and PVRs. For
example, there are no restrictions on the use of PVR-protected plants for
breeding programmes, nor for private or experimental purposes. There is also
an exemption that allows farmers to save seed from many PVR-protected
varieties in return for reduced payments.
2.3 Public attitudes
2.3.1 This report (see paragraph 2.2.1) has already observed the way in
which regulations have been driven by a set of concerns emerging from the
development of GM technology. Many of these concerns are at the root of
public attitudes to GM. Public attitudes are particularly important- and
particularly complex ­ in the context of GM crops.
Opinion poll evidence reveals that public attitudes are complex
2.3.2 There have been a number of opinion poll surveys of public attitudes to
GM crops and food in the past few years (Box 2.6). Whilst such surveys are
widely referred to and provide important snapshots of how people regard the
issues, they must also be interpreted with care ­ outcomes can be influenced
by factors such as the size of sample, level of interaction with survey
participants, and the design and phrasing of the questions.60
Box 2.6: Recent evidence from opinion polls on GM
A wide variety of organisations have published opinion poll data on the
public's attitudes to GM.
ˇ MORI Environment Research (2003) found that 56% of people in the UK
are opposed to the introduction of GM food ­ more people than are opposed
to nuclear power or congestion charging. 14% support their introduction, and
25% neither support nor oppose their introduction.
ˇ The Food Standards Agency (2003) have found that consumer concerns
about GM food fell from 43% to 36% between 2000 and 2002. In discussion
59
Source: UK Patent Office.
60
See, for example House of Lords Science and Technology Committee (2000) "Science and
Society" 3
rd
Report Session 2000-1.
44
groups with young people and people on low incomes, a minority held firm
views either way ­ most were relatively neutral.
ˇ The Consumers' Association (2002) found that 32% of consumers were in
favour of growing GM crops for commercial purposes in the UK at the present
time. In contrast, 58% were against, and cited lack of information as the
primary reason. 50% thought that GM could offer benefits for food production
­ but at the moment, these benefits are seen to be going to those developing
the technology, not to consumers. 57% had concerns about the use of GM in
food production, these concerns relating mainly to not knowing enough about
GM, or to fears of tampering with nature.
ˇ Eurobarometer (2002) found that support for GM food and crops had
stabilised across Europe between 1999 and 2002. Support by the UK public
had grown in that time, with the position now one of "weak support" for GM
crops and "weak opposition" to GM food.
2.3.3 The main message coming from the opinion poll data is that public
attitudes are complex, though there does seem to be some evidence that
attitudes towards GM crops and foods are generally negative. In addition,
there appears to be some evidence that attitudes may vary between GM
crops and GM foods, and between different types of GM produce (food, feed
and non-food) and GM traits (agronomic benefits, environmental benefits,
etc.).
The public will "frame" GM issues in different ways
2.3.4 One reason for this complexity is the fact that the public will "frame" GM
issues in different ways, depending on their primary point of contact with GM
technology. For example, any one individual could view GM crops and foods
from the point of view of a consumer, a parent, a tax-payer, an
environmentalist or an employee. The GM Public Debate has been designed
in part to clarify public concerns and to inform government about them.
Results from early work commissioned by the Debate indicate some of the
key frames (Box 2.7).
Box 2.7: How the public frames issues relating to GM
One of the aims of the Public Debate's "Foundation Discussion Workshops" ­
held during November 2002 ­ was "to allow the public to frame the issues"
that would be used in the main part of the Debate. The organisers of the
workshops (Corr Wilbourn) suggested the following headings as
representative of the way in which the public frames GM issues:
ˇ Food ­ including health issues, aesthetics, product characteristics,
economics, political issues and impacts on production processes.
ˇ Choice ­ including the extent to which a choice exists, issues of timing,
labelling and impacts on organic farming.
ˇ Information needs ­ including information on GM and on those with a
stake in GM.
45
ˇ Progress ­ including science, technology, medicine, economics, ideology
and the way in which these fit with the trajectory of GM.
ˇ Uncertainty ­ including the potential for catastrophe, liability and potential
mis-use.
ˇ Targets ­ including plants, animals, humans and micro-organisms.
ˇ Ethics ­ including questions of why GM is happening at all, and how / by
whom it is being controlled.
2.3.5 Another complexity in public attitudes arises from their inter-dependency
with the views, policies and campaigns of other groups and organisations,
including the Government. The events surrounding the introduction and
subsequent withdrawal of GM foods in the late 1990s provide a good
example.61
The retailers and food manufacturers took steps to engage with
and inform their consumers and the media before introducing GM tomato
paste in the UK. However, they were in turn heavily influenced by subsequent
"anti-GM" campaigns by Non-Governmental Organisations (NGOs) and the
media, which also helped to shape consumer attitudes.
2.3.6 Members of the British Retail Consortium (BRC), including all the major
UK supermarket chains, currently have a policy of not stocking foods sourced
from GM materials and ingredients.62
The BRC highlights the importance of
consumer attitudes in determining how this policy may evolve in the future. In
its policy statement of October 2002, it states that "Retailers will consider the
sale of GM foods or foods containing GM ingredients, provided they have
approval from the regulatory authorities and where they have confirmed a
clear consumer demand."
2.4 The wider policy context
GM crops are not an end in themselves
2.4.1 Neither GM crops, nor the alternatives to GM crops, can be considered
as ends in themselves. GM crops are useful only if they are able to play a role
in meeting desirable objectives ­ environmental, social and economic ­
without imposing unacceptable costs. Hence the analysis of costs and
benefits associated with GM crops makes sense only in the context of those
wider objectives, particularly as reflected in Government policy. That is why
this report's analysis is focused on addressing the following questions, across
a range of different scenarios:
ˇ How will GM crops impact on the Government's policy objectives?
ˇ Are GM crops likely to have a positive role to play, perhaps as part of the
solution to current problems?
ˇ Are GM crops likely to exacerbate current problems or create new ones?
61
These events are discussed in Box 1.3 and in the GM Foods in the late 1990s Analysis
Paper.
62
"New food products and processes", BRC Food Briefing (October 2002)
46
ˇ Or are GM crops irrelevant to meeting the main objectives in each policy
area?
ˇ What are the alternatives to GM crops, and how do they compare in their
ability to deliver on objectives?
ˇ How might the answers to these questions change over time?
2.4.2 The remainder of this section sets out which of the Government's wider
policy objectives may be affected by GM crops.
Agricultural policy and the environment
UK agriculture is strongly influenced by international developments
2.4.3 In the mid-part of the 20th Century, the focus of farming in the UK was
on delivering some degree of self-sufficiency in food production. But during
the latter part of the century, with the introduction of the Single Market and the
creation of the WTO (and its fore-runners "GATT" and "GATS"), imports
became much more readily available, often at a lower cost than domestic
agriculture could deliver.
2.4.4 The latter part of the 20th
Century also saw the establishment of the
Common Agricultural Policy (CAP), and the associated system of subsidies
and quotas. Notwithstanding the reduction in price support that has been seen
in the ongoing reforms of CAP, it is important to be clear that UK farmers do
not operate in a fully competitive market: in 2001, gross output from farming in
the UK was 15 billion; CAP funding to the UK was 3 billion.63
2.4.5 CAP has established a complex set of incentives, and this means that
the impact of a new development such as GM crops is not easy to predict.
The difficulties of making firm predictions are exacerbated by the fact that
CAP is in the middle of a mid-term review, and also by the expected
accession of ten new Member States in 200464
­ most of which have large
agricultural sectors and could have a major impact on farming across the EU.
2.4.6 Market reform and trade liberalisation are key elements of the UK
Government's position on CAP reform.65
They also form part of the PSA
target to promote trade opportunities for the UK and developing countries.66
63
DEFRA/ONS Summary of UK food and farming and
http://www.defra.gov.uk/farm/capreform/indetx.htm
64
Bulgaria and Romania to follow in 2006 or 2007.
65
DEFRA (December 2002) "Strategy for Sustainable Farming and Food - Facing the Future",
available at http://www.defra.gov.uk/farm/sustain/newstrategy/index.htm
66
DTI/DfID/FCO joint Public Service Agreement target to "Secure agreement by 2005 to a
significant reduction in trade barriers leading to improved trading opportunities for the UK and
developing countries". See http://www.hm-
treasury.gov.uk/spending_review/spend_sr02/psa/spend_sr02_psaindex.cfm
47
The economic significance of agriculture has diminished
2.4.7 Despite some limited recovery in the last two years, farm incomes have
fallen very substantially since 1995. This has been due to a number of
difficulties:
ˇ Exchange rate changes, which affect subsidy payments and value of
farming outputs;
ˇ Weak world commodity prices;
ˇ One-off crises, such as BSE and the 2001 outbreak of Foot and Mouth
Disease (FMD).
2.4.8 However, the food chain as a whole (including agriculture) remains
economically significant in the UK. Some statistics outlining the UK
agricultural and food sector are shown in Box 2.8 below.
Box 2.8: Economic Significance of UK Agriculture and Food
There has been a long-term decline in the contribution of the agricultural
industry to the UK economy. Agriculture currently accounts for less than 1% of
GDP, down from a level of 2.1% in 1983.67
Agriculture's share of total
economic gross value added is at its lowest in England at 0.6% and highest in
Northern Ireland at 2.9%.
Agriculture's share of the total workforce is falling, having experienced a drop
of 20% over the last 10 years to its current level of 2% of the labour force.68
Its
share of total regional employment varies considerably throughout the UK,
with the lowest proportion of 1.9% in England and the highest of 7.6% in
Northern Ireland.
Downward trends in employment and contribution to GDP are common to
most developed countries, and are more pronounced in most other EU
countries.69
The UK currently has the fastest growing organic market in Europe. Organic
produce make up 1.4% of the total value of sales of food and drink in the UK
and in 2002, 4.3% of the total agricultural land area in the UK was managed
organically.70
The UK is a world leader in added value food and drink production and
marketing.71
The UK food chain of agriculture, horticulture, food and drink
manufacturing, food and drink wholesaling, food and drink retailing and
67
DEFRA (2001), op cit.
68
DEFRA (2001), op cit.
69
DEFRA (2002) "Farming and Food's Contribution to Sustainable Development: The Current
Situation and Future Prospects".
70
See background working paper for the analysis of the costs and benefits in the product
chain.
71
See http://www.dti.gov.uk/sectors_food.html
48
catering industries provides 12.5 % of total employment and exports goods
worth 9 billion (some 3 % of total exports).72
The food chain accounts for nearly 8 % of UK GDP73
(i.e. about 65 billion).
The largest contribution is from manufacturers (19.4bn), followed by retailers
(16.6bn)74
. The UK retail sector is characterised by a certain degree of
concentration: five supermarket chains account for about 70% of grocery
sales in the UK. This has given rise to concerns about the imbalance of
power between large retailers and their smaller suppliers.75
Few producers
supply supermarkets directly, but there are similar concerns about the
balance of power further down the chain.
2.4.9 A further concern for UK agriculture is the rate and efficiency with which
new knowledge and technology is applied. This is an important component in
explaining the sector's slow productivity growth.76
Links between agriculture and the environment are seen as increasingly
important
2.4.10 Agriculture has had a significant effect on the environment for many
hundreds of years. In the UK, impacts range from the ancient (e.g. downland
from sheep farming), through the historical (e.g. patchwork field patterns
dating back several centuries) to the relatively recent (e.g. the bright yellow
fields of oil-seed rape). 75% of the UK land area is currently managed by
farmers77
, and in recent years there have been a number of important trends
(good and bad) in agriculture's impact on the environment, shown in Box 2.9
below.
72
DEFRA (2002) "Farming and Food's Contribution to Sustainable Development: The Current
Situation and Future Prospects".
73
DEFRA (2002) op cit. GDP figures based on 2000 data.
74
DEFRA (2002) op cit. See also background working paper for the analysis of the costs and
benefits in the product chain.
75
This has been a recurrent theme in the Strategy Unit's meetings with stakeholders involved
in farming and food production. The subject was addressed in a report by the Competition
Commission, following which the Office of Fair Trading has drawn up a code of practice which
defines the principles and practices that apply in order to achieve fair and balanced trading
relationships between the largest supermarkets and their suppliers. See DEFRA (2002) op
cit.
76
DEFRA (December 2002) "Strategy for Sustainable Farming and Food - Facing the Future".
77
DEFRA (2001), "Agriculture in the United Kingdom ­ 2001", online at
http://www.defra.gov.uk/esg/work_htm/publications/cf/auk/current/auk_pdf.htm
49
Box 2.9: Trends in environmental impacts of agriculture78
Pesticide residues in water have fallen: the number of monitoring sites where
the Environmental Quality Standard was not met fell from 10 in 1995 to 4 in
1997 in England, Wales and Northern Ireland.
Farmland bird numbers have fallen sharply: farmland and woodland birds
have generally been declining from the mid-1970s to 1998. Populations of
some farmland birds such as the skylark and corn bunting, and of woodland
birds such as the song thrush and bullfinch, have fallen by more than half in
that time.
Vegetation groups associated with agriculture have decreased: the average
number of species in fields, woods, moorland, hedges and streamsides,
especially in lowland landscapes has fallen. The changes in the different
types of plants suggest that the decline reflects an overall shift towards more
intensively-managed and nutrient-rich vegetation.
Characteristic countryside features have deteriorated: hedges, walls and
ponds have been in decline through the 1980s and early 1990s, mainly due to
lack of appropriate management. Now more hedges are being planted than
uprooted, but the problem of maintenance remains. In England and Wales,
the length of managed hedgerows decreased by nearly a third between 1984
and 1993.
2.4.11 In addition, concerns have been expressed about the future impacts of
climate change on the relationship between agriculture and the environment
in the UK.
Policy-makers have taken the changing situation into account
2.4.12 The UK Government's priority reflects environmental and economic
concerns:
"to secure an environment in which a competitive and
sustainable agricultural industry with a strong market
orientation can flourish".79
2.4.13 That priority is mirrored in the European Commission's mid-term review
of CAP, which recognises that:
78
See http://www.sustainable-development.gov.uk/sustainable/quality99/package/agricult.htm
79
http://www.defra.gov.uk/farm/ag2000.htm
50
"besides supporting farming incomes, [CAP] must yield more in
return regarding food quality, the preservation of the
environment and animal welfare, landscapes, cultural heritage,
or enhancing social balance and equity." 80
Changing pressures and priorities require changes in the farming sector
2.4.14 Within England, the "Curry report" (published in January 2002) set out
a vision for the future of food and farming.81
The report described its central
theme as "reconnection", and made over 100 policy recommendations aimed
at:
ˇ Reconnecting farmers with their market and the rest of the food chain.
ˇ Reconnecting the food chain with a healthy and attractive countryside.
ˇ Reconnecting consumers with what they eat and where it has come
from.
2.4.15 The Government has now published its response to the Curry report.82
The key element of the policy response is the publication of a "strategy for
sustainable farming and food" in England.83
In parallel, the UK Government
has put together an action plan to develop organic food and farming in
England.
2.4.16 The strategy makes clear that the success of the industry ultimately
lies in its own hands. The overarching aims provide "a framework for the
future", not "a single blueprint ­ a master plan ­ for all to follow"84
. Individual
farmers and other companies in the food product chain will continue to have a
range of options for developing their businesses.
2.4.17 The devolved administrations have their own agriculture and food
strategies, each reflecting the particular circumstances of agriculture
(conventional and organic) in those administrations.85
80
http://www.europa.eu.int/comm/agriculture/mtr/index_en.htm
81
The "Curry report" is the common term used for the report of the Policy Commission on the
Future of Farming and Food, chaired by Sir Donald Curry. Details are available at
http://www.defra.gov.uk/farm/sustain/default.htm.
82
DEFRA (December 2002) "Response to the Report of the Policy Commission on the Future
of Farming and Food by HM Government", (CM 5709) available from
http://www.defra.gov.uk/farm/sustain/newstrategy/index.htm.
83
DEFRA (December 2002) "Strategy for Sustainable Farming and Food - Facing the Future".
84
DEFRA (2002) "Strategy for Sustainable Farming and Food - Facing the Future".
85
In Scotland, the Scottish Executive has published "A Forward Strategy for Scottish
Agriculture" (2001), available from http://www.scotland.gov.uk. The Scottish Executive
Organic Action Plan is at http://www.scotland.gov.uk/library5/agri/orap-00.asp. In Wales,
agriculture is a key element of the "Rural Development Plan for Wales 2000-2006" (2001), op
cit. Organic farming is covered in
http://www.wales.gov.uk/keypubassemcomagriandrural/content/organicfarming/English%20T
ext%20&%20Cover.pdf.
In Northern Ireland, a vision for the future of the agri-food sector is described at
http://www.dardni.gov.uk/.
51
Increasing provision of environmental goods from agriculture is a major theme
2.4.18 Efforts have been made to minimise any adverse environmental
impacts from agriculture through the introduction of agri-environment
schemes, which offer financial rewards for farmers observing good
environmental practice. The main government-led schemes in England are
currently the Countryside Stewardship Scheme and the Environmentally
Sensitive Areas scheme. Similar measures are in place in Scotland, Wales
and Northern Ireland.
The role of GM crops in the future of farming is not yet clear
2.4.19 New technologies, such as increased mechanisation, have played an
important role in promoting agricultural productivity. The potential role of GM
technology, however, is not yet clear.
2.4.20 The Government's Strategy for Sustainable Food and Farming states
that
"The techniques of genetic modification, if applied safely and
responsibly, have the potential to contribute to sustainable food
and farming. But genetically modified organisms (GMOs) may,
as well as bringing benefits, pose an as yet unknown risk ­ not
to human health ­ but to other biodiversity."86
2.4.21 Chapter 3 attempts to assess the potential costs and benefits that GM
crops might bring in relation to the objectives for agriculture in the UK. It also
considers the interaction between GM crops and other approaches, for some
of which ­ for example, organic farming ­ there is already rather more clarity
in the role they are expected to play.
Rural policy
2.4.22 Impacts of GM crops on agriculture and the environment may affect
rural areas of the UK. Such impacts would need to be seen against the
backdrop of overall rural policy, and some statistics outlining UK rural
economies and communities are shown in Box 2.10 below.
86
DEFRA (2002), op cit, p35.
52
Box 2.10 Rural economies and communities
The past 20-30 years have seen significant economic changes in rural
economies. Some key trends have been:87
ˇ A decline in agricultural employment in rural areas from 6% to 4% of total
rural employment, and an increase in employment in the service sectors
from 60% to 71% (between 1981 and 1996);
ˇ An increase of 24% in the population of rural England between 1971 and
1996, compared to 6% across England as a whole;
Rural tourism is worth nearly 14 billion a year and supports 380,000 jobs88
.
Rural policy is an important issue in England and in the devolved
administrations
2.4.23 The challenges facing rural policy in England were highlighted in the
Performance and Innovation Unit report on "Rural Economies",89
the themes
of which were taken up in a White Paper setting out the Government's policies
for rural England.90
The vision for rural England, set out in that paper, is of:
ˇ a living countryside, with thriving rural communities and access to high
quality public services;
ˇ a working countryside, with a prosperous and diverse economy, giving
high and stable levels of employment;
ˇ a protected countryside, in which the environment is sustained and
enhanced, and which all can enjoy; and
ˇ a vibrant countryside which can shape its own future and whose voice is
heard by government at all levels.
2.4.24 A number of policy initiatives are in place to seek to achieve this. A
central element is the England Rural Development Programme (ERDP).91
Under this programme, 1.6bn is being made available to farmers over seven
years, for environmental protection and improvement and rural development.
In England, a further 48 million has been made available over three years
through the Countryside Agency's Vital Villages scheme.92
87
Performance and Innovation Unit (December 1999) "Rural Economies", available from
http://www.strategy.gov.uk.
88
Countryside Agency (2002) "State of the Countryside Report"
89
Performance and Innovation Unit (1999) op cit.
90
DEFRA (November 2000), "Our Countryside: The Future ­ A Fair Deal for Rural England",
available at http://www.defra.gov.uk/wildlife-countryside/ruralwp/index.htm.
91
Details are available at http://www.defra.gov.uk/erdp/erdphome.htm.
92
http://www.countryside.gov.uk/vitalvillages/
53
2.4.25 Rural policy is just as important in the devolved administrations.93
As in
England, both Wales and Scotland attach special importance to their "clean,
green" image, which impacts on the marketability of their food produce and
the attractions of their countryside environments. For the whole of the UK, GM
crops ­ and the alternatives to GM ­ could potentially have important
implications for rural economies, rural communities and rural employment.
Science, innovation and competitiveness policy
Science and technology are important for future UK productivity and
competitiveness
2.4.26 Many of the policies relating to science and innovation seek to address
the wider issue of UK productivity and competitiveness, summarised by the
Treasury94
as follows:
"The UK's productivity performance has been poor for a long time in
comparison to other major economies. As a result, the UK now has a
productivity gap, measured in output per worker, that is substantial on
all measures in comparison to the US, Germany and France....At the
national level, the UK has a shortfall against its major competitors in
terms of investment in physical and human capital and in terms of
technological progress."
2.4.27 Whilst there are many macro-economic and micro-economic factors
involved in overall productivity and competitiveness, science and technology
is highlighted as one of the main areas out of which improvements could
arise.
The UK is aiming to build on its science policy successes
2.4.28 Science-based industries linked to biotechnology, information
technology and nanotechnology are expected to be at the forefront of future
economic growth. This makes it important that the UK is involved in these
industries and the associated science ­ particularly in the context of a
competitive international environment in which other countries are also
seeking to support scientific research in order to deliver future prosperity.
2.4.29 The UK has a good track record in some important areas:95
ˇ attracting investment from multi-national companies working in science-
based industries;
93
The vision for rural policy in Scotland was set out in "Rural Scotland: A New Approach"
(May 2000), available from http://www.scotland.gov.uk. In Wales, the key document is the
"Rural Development Plan for Wales 2000-2006" (2001), available from
http://www.wales.gov.uk. In Northern Ireland, the Rural Development programme strategy
2001-2006 was published in 2001.
94
HMT (2000) Productivity in the UK: The Evidence and the Government's Approach
95
DTI (1999) Genome Valley, a report on the economic potential and strategic importance of
biotechnology in the UK.
54
ˇ generating clusters of small businesses and start-ups working at the
cutting-edge of these new industries;
ˇ public research institutions and universities that are respected the world
over.
2.4.30 It is important that the UK continues to build on these strengths ­ and
that it also seeks to improve performance in areas where it has historically not
done so well, such as bringing new products to market and hence enjoying
the "early-mover advantages".
2.4.31 One area of concern is the UK's lower-than-average expenditure on
R&D. The Government's strategy for science, engineering and technology
Investing in Innovation96
highlighted the fact that between 1981 and 1999 "the
UK is the only country to experience a significant decline in total R&D
spending as a share of GDP compared with its competitors". The UK currently
spends 1.83% of its GDP on R&D (17.5 billion: one-third public sector, two-
thirds private sector). This compares to a G7 average of 2.10% GDP97
.
2.4.32 The recent government spending review reflects the priority given to
science: planned expenditure on science is set to increase by 1.25 billion
between 2002/3 and 2005/6, with the DTI budget for science increasing by
10% in real terms year on year. This additional funding has been provided in
the expectation that it will lead to economic gain - the associated public
service agreement (PSA) target is to:
"improve the relative international performance of the UK's
science and engineering base, exploitation of the science
base, and the overall innovation of the UK economy".98
2.4.33 In addition to measures aimed at improving the science base and
creating better links between academia and business, the recent Government
White Paper on science policy, "Excellence and Opportunity",99
emphasises
the key role of consumers and the public:
"an innovation will only succeed if it is desired and accepted
by consumers and members of the public ... Science and
innovation need a stable and transparent framework of public
support within which they can develop".
2.4.34 This introduces a further aspect of science policy related to the
relationship between scientists and wider society. The scientific community
has been placed under increasing scrutiny as scientific developments have
become more visible and more pervasive. Government policies aim to
achieve greater public involvement in debates about the place of science in
society100
.
96
HM Treasury (July 2002).
97
From SET Statistics 2003 on www.ost.gov.uk.
98
See the Industry and Science Analysis Paper, available on the project website.
99
Cm 4184
100
http://www.ost.gov.uk/society/index.htm
55
GM crops could be an important test case
2.4.35 Multinational companies, small and medium sized enterprises (SMEs)
and academic researchers have all contributed to the development of GM
crops. Thus GM crops cut across many of the Governments' priority issues for
science ­ the ability of UK to attract inward investment in high-technology
industries; the ability of the UK to generate and support new technology-
based SMEs; and the ability of the academic community to generate valuable
intellectual property and work closely with commercial organisations.
2.4.36 Some commentators see GM crops as an important test case for
decision-making about science-based industries in the UK in general.
Furthermore, the issues relating to GM crops and food have been, and seem
set to continue to be, an important "testing-ground" for the relationship
between science and society.
2.4.37 GM crop development is a small activity both in the context of UK
scientific activity, and in the context of the global industry. Some figures are
shown in Box 2.11 below. Whilst the UK has maintained a number of centres
of excellence in the public sector,101
commercial research has been cut or
passed into foreign ownership in the past two decades, with the greatest
reductions between 1999 and 2001.102
2.11: UK activity in agricultural biotechnology and GM crop
development.103
Data on the extent of GM crop R&D in the UK are not precise nor especially
complete. The boundaries of the various scientific activities involved are not
clear cut, and there is a range of activity in both the public and private sector.
Many of the figures available look at the agricultural biotechnology sector.
This sector includes, but goes wider than, GM crops.
The commercial agricultural biotechnology industry in the UK employs just
under 1,300 people in R&D.104
This is just under 1% of the total commercial
R&D employment in the UK (153,000).105
Syngenta ­ the only multinational agricultural biotechnology company with a
major research station in the UK ­ spends about 120 million in the UK on
R&D106
. The main public sector sponsor of GM crop development, the
BBSRC107
, invests about 55 million on agricultural biotechnology research,
101
See background working paper on industry and science on the project website.
102
See the Industry and Science Analysis Paper, available on the project website.
103
See the Industry and Science Analysis Paper, available on the project website.
104
Poole NJ (2001) The competitiveness of R&D in the UK ­ the agrochemical and
biotechnology sector
105
www.ost.gov.uk/setstats
106
Expenditure figures in Box 2.11 are per annum.
107
Biotechnology and Biological Sciences Research Council.
56
of which nearly 18 million is in GM crop research.108
Total UK spending on
all R&D is 17.5 billion; one-third public, two-thirds private sector.109
Estimates of global GM crop R&D are about $4.4 billion (2.7 billion),
composed of roughly 3/4 private and 1/4 public sector research.110
It is difficult
to split this into national contributions, but one indicator of R&D activity in GM
crops is the number of field trials. There were 11 GM field trial notifications
and permits in issued in the UK in 2001, compared to 61 across the whole
EU, and 1189 in the USA.111
2.4.38 Chapter 3 considers the potential impact of GM crops on future
development of the UK science base, and also considers what might happen
to the other scientific approaches that might offer alternatives to GM crops.
Policy on food safety and quality
Recent scares and controversies have focused attention on food labelling
2.4.39 Food safety and quality has been a major issue over recent years, due
to a number of high-profile scares and controversies, including:
ˇ The links between Bovine Spongiform Encephalopathy (BSE) ­ more
commonly known as "mad cow disease" ­ and variant Creutzfeldt-Jakob
Disease (vCJD).
ˇ Outbreaks of E. coli food poisoning traced to a number of different food
manufacturers and retailers.
ˇ Concerns about levels of pesticide residues on fresh fruit and
vegetables.112
ˇ Allergenicity linked to various foods, such as nuts and kiwi fruit.
2.4.40 These have led consumers to pay much more attention to the food
they eat, including what it contains and how it is produced. An important result
has been the increased focus on labelling. In addition to basic informational
labelling, this comes in two main forms:
ˇ "Negative" labelling, which conveys a warning, such as "may contain nuts".
108
See the Industry and Science background working paper, available on the project website.
109
www.ost.gov.uk/setstats
110
James C (2002) Global review of transgenic crops: 2001 feature: Bt cotton. ISAAA Briefs
No 26, Ithaca, NY
111
Data from JRC (http://www.jrc.es/home/index.html) and USDA (http://www.usda.gov/).
Note that US regulations require repeat notifications each year; EU regulations require one
notification only for trials lasting more than one year ­ average is 2.6 years
112
About 30% of the food we eat contains detectable pesticide residues (2000 data).
However, the vast majority (98%) of samples tested since 1998 do not contain residues
above legal limits and do not contain non-approved pesticide residues. In almost all cases
where a legal limit was exceeded or non-approved use was found, no risk to health was
presented.
57
ˇ "Positive" labelling, which conveys a sense of quality ­ such as "farm-
assured", "premium" or "organic".
2.4.41 One other area that has come under attention is the nutritional value of
processed foods, and concerns about potential links to obesity and poor
health, especially among children. Some data on UK food and nutrition are
given in box 2.12 below.
Box 2.12: UK food and nutritional data113
Although people are eating more fruit and vegetables than they were 15 years
ago, the FSA's recommendation to consume at least five portions of fruit and
vegetables each day is met by only 14% of the population. 35% of the
population take dietary supplements of multivitamins and multiminerals.114
Levels of obesity have tripled since 1980 in England, and there is no sign of
the upward trend stopping. Currently, over 1/2 of women, and about 2/3 of
men are either overweight or obese. Deaths linked to obesity shorten life by 9
years on average.
About 20 to 30% of people in the UK believe they are intolerant to one or
more foods. However, tests show that only about 5 to 8% of children and 1 to
2% of adults actually have a food intolerance. It is estimated that 10 deaths a
year in the UK are caused by food allergy.
The Food Standards Agency (FSA) plays the key role in promoting food
safety and quality
2.4.42 Collectively, concerns such as these were an important factor in the
creation of the FSA. The FSA was established by an Act of Parliament in
2000, and its purpose is to protect the public's health and consumer interests
in relation to food. The objectives of the FSA reflect Government's policy
objectives for food safety and quality.115
They include: reducing foodborne
illness by 20%; helping people to eat more healthily; and promoting honest
and informative labelling to help consumers.
GM foods will impact on food quality and safety
2.4.43 A wide range of different technical, commercial and social changes will
affect all these objectives. There can be no doubt that GM foods have the
potential to effect some of them, and Chapter 3 considers the potential
impacts GM crops might have. It also assesses the contribution of GM crops
alongside other approaches ­ for example "quality assured" schemes, and
organic produce.
113
Data from Food Standards Agency unless stated otherwise. See www.food.gov.uk.
114
National Diet and Nutrition Survey (2002).
115
FSA aims for 2001 to 2006, taken from http://www.food.gov.uk/aboutus/.
58
International Development Policy
International development policy focuses on the UN Millennium
Development Goals
2.4.44 The UK Government's international development policy is based on the
1997 and 2000 White Papers on International Development. There is an
overarching commitment to promote sustainable development and eliminate
world poverty.
2.4.45 The specific focus for Government policy is a commitment to the
internationally agreed Millennium Development Goals. These Goals, to be
achieved by 2015, were adopted by the United Nations at the 2000 General
Assembly. They seek to:
ˇ Eradicate extreme poverty and hunger
ˇ Achieve universal primary education
ˇ Promote gender equality and empower women
ˇ Reduce child mortality
ˇ Improve maternal health
ˇ Combat HIV/AIDS, malaria and other diseases
ˇ Ensure environmental sustainability
ˇ Develop a global partnership for development
There is considerable controversy about the role of GM crops in
developing countries
2.4.46 The role of GM crops in developing countries is subject to many
competing claims. On the one hand, GM crops are argued to be a major
solution for world hunger ­ for example, through their potential ability to help
developing countries grow crops in poor conditions (such as drought or
salinity); through their potential to increase yields; or through other potential
benefits such as improved nutritional value. On the other hand, it is argued
that GM crops do not meet the needs of the poorest farmers in developing
countries for a number of reasons. These include the cost of the technology,
challenges to risk management and control over the food chain.
Government policy emphasises the potential benefits but stresses that
developing countries should make their own decisions
2.4.47 GM crops have not so far been a major focus of Government policy in
this area. The policy on GM crops in developing countries states that:
"GM technologies have the potential to provide significant
benefits for poor farmers if applied safely and responsibly to
the crops they rely on."
"Developing countries need to be able to make their own
informed choices about whether to adopt GM technologies or
59
not and build the capacity to manage their safe development
and use."116
2.4.48 The extent to which GM crops could increase in importance in this
policy area depends whether current and, in particular, future GM crops are
relevant to the needs of poor farmers in developing countries; and whether
they are available to them.
2.5 Summary
2.5.1 Even a narrow description of the current state of play regarding GM
crops involves a range of background technical information and intricate
regulatory detail. Any forward projection needs to consider that GM crops and
their alternatives could touch on a number of major policy areas ­ agriculture,
environment, rural communities, science, food safety, and international
development ­ each of which could have consequences for many other
aspects of policy.
2.5.2 By affecting so many areas of activity, a wide range of stakeholders will
be affected in turn. There are many different ways in which these
stakeholders might respond to developments in GM crop technology or
changes in GM crop regulations, and many ways in which costs and benefits
might arise. These are analysed in the following chapter.
116
DFID (May 1999) "Genetically Modified Organisms and developing countries"
60
Chapter 3: Analysis of costs and benefits
Summary
ˇ The Strategy Unit has carried out a detailed analysis of the potential costs
and benefits of GM crops and has identified a number of key areas:
ˇ Impacts on the economics of agriculture, which include the potential cost
and convenience implications of growing GM crops, for both current and
future varieties.
ˇ Consumer demands for segregation of GM and non-GM products
throughout the product chain, which could affect cost and current practices
in the food supply industries.
ˇ Wider impacts on the rural economy and communities.
ˇ The interaction between agriculture, the environment and human health.
This includes the possible impact of GM crops on pesticide use and farm
management. The options for monitoring systems to look at the impacts of
GM crops are considered, as well as the potential for future traits to deliver
environmental or human health benefits.
ˇ Impacts on the science base in the UK, including the potential impacts of
GM crops on multinational and SMEs in the UK. There may also be effects
on other biotechnology industries, and the wider science base.
ˇ It is also important to consider the international context for the UK and GM
crops, especially the potential impact of UK action on developing
countries.
3.1 Introduction
Purpose of the chapter
3.1.1 This chapter summarises the Strategy Unit's analysis of the costs and
benefits that could be associated with commercially cultivating GM crops ­ or
choosing not to cultivate them, in the UK. It provides a summary of the
analysis set out in the report's accompanying analysis papers, which provide
more detail on the individual subject areas.
3.1.2 In many areas, the conclusions of this chapter are tentative. There are
many reasons for this. Whilst there is a large body of international evidence
on the impacts of cultivating GM crops, for instance, the different
environmental, economic and other conditions in the UK mean that the
findings may not be directly applicable here. And there are also considerable
61
complexities surrounding the science of GM crops, which are being explored
in the Science Review.
3.1.3 Within this context, this study has not attempted to attach overall
monetary values to the costs and benefits associated with commercialisation.
The Strategy Unit has concluded that any attempt to do so would rely too
heavily on some arbitrary assumptions, and would be potentially misleading.
Instead, the aim has been to give a mainly qualitative analysis of the nature of
the impacts that may occur in the UK under different assumptions for the
commercial use of GM crops. This analysis is illustrated with quantitative
information wherever this is available.
3.1.4 Rather than looking at costs and benefits in isolation, the analysis
focuses on the question of whether GM crops or food could help in the
achievement of policy goals. Throughout the analysis, we have also
attempted, where possible, to identify whether there are alternative ways of
achieving these goals.
3.1.5 This chapter covers the following issues:
ˇ Section 3.2 considers the variety of ways in which GM crops might impact
on the economics of agriculture ­ from direct cost implications, to
regulatory costs, to impacts on farmer income;
ˇ Section 3.3 discusses the practicalities and costs of keeping GM crops
and foods separate from their non-GM counterparts;
ˇ Section 3.4 looks at wider impacts on the rural economy and communities,
including possible impacts on rural cohesion and on society;
ˇ Section 3.5 considers the possible environmental and human health
implications of introducing GM crop cultivation to the UK;
ˇ Section 3.6 looks at how the future direction of GM crop policy may affect
the UK science base;
ˇ Section 3.7 considers how the UK's policy on GM crops may have a range
of important international implications;
ˇ Finally Section 3.8 concludes.
3.2 Impacts on the economics of agriculture
Different types of farm are likely to be affected by GM crops in different
ways
The UK farming sector is very varied...
3.2.1 There are a wide variety of farms in the UK. Broadly speaking, they can
be categorised into grassland farming; arable farming; upland farming; and
mixed farming (that is, a mixture of livestock and crops).117
Within these
categories, farmers may use a range of farming practices.
117
This is the categorisation used, for instance, in DEFRA's pilot entry level agri-environment
scheme. See http://www.defra.gov.uk/erdp/reviews/agrienv/entrylevel.htm
62
3.2.2 There are also regional differences. Farms in East Anglia, for instance,
tend to be large in size, and specialise in large-scale production of arable
crops. Those in Wales and Scotland tend to be more mixed, and Northern
Ireland's farms largely concentrate on livestock production.
...and so the impacts of GM crops could be just as varied
3.2.3 GM crops would therefore impact on, or be of interest to, different
farmers in different ways. Farmers using non-organic but low-input systems,
for instance, would be interested in GM crops if they offered a way to control
pests with reduced chemical use. Farmer with large farms may be less
worried about issues to do with the spread of GM materials to their
neighbours, as they could keep crops more contained within their own farm.
3.2.4 Livestock farmers are already affected by GM crop growing worldwide.
The UK imports a large amount of animal feed, including 2 million tonnes of
soya ­ some of which comes from countries that grow GM soya. Farmers,
therefore, already have to decide whether to use feed which is guaranteed to
be non-GM ­ and is therefore more expensive ­ or whether to use unlabelled
feed, which may or may not have a GM content.118
Were commercial
cultivation of GM crops to be allowed in the UK, they could also choose to
grow GM feed themselves.
3.2.5 Finally, the impact of GM crops would also be felt by farmers not
choosing to grow them, including organic farmers, mainly through the
unintentional transfer of GM material into non-GM crops (see Section 3.3).
GM crops have been designed to offer specific cost or convenience
savings; the scale of these will vary, and may be offset by other costs
There are a range of factors which will determine the magnitude of any cost or
convenience savings
3.2.6 The scale of any cost impacts arising from changes to agronomic
practices associated with the growing of GM crops will depend on a number of
factors:
ˇ The scale of the problem which the crop is designed to address. Bt corn,
for instance, is popular in countries which have a problem with the corn
borer insect, such as the US; however, the corn borer is not present in UK
agriculture, and so current varieties of Bt corn are unlikely to be of any
benefit here. In contrast, potato blight can cause significant damage to the
UK potato crop. If GM technology could deliver a blight-resistant potato, for
instance, then there could be significant benefits to UK farmers.
ˇ Effectiveness of the trait. Some herbicide tolerant crops, for instance, do
not suffer at all when the relevant herbicide is sprayed on them. Others
may suffer a degree of "knock-back" (a period of stunted growth following
118
GM feed currently does not have to be labelled, although this is in the process of changing
under a forthcoming EU directive on food and feed. See the Regulations Analysis Paper,
available on the project website, for further details.
63
spraying). Over the longer term, the development of pests or weeds which
are resistant to the control methods used by the GM crop could also
impact on its effectiveness ­ although it should be noted that this is also a
problem in other methods of agriculture.119
ˇ Incidental costs or benefits. GM crops may have a range of secondary
impacts which could affect farm management. These could include, for
instance, greater hybrid vigour;120
easier harvesting, due to the lower
incidence of weeds; or physiological changes such as changes to lignin
content that could make harvesting more difficult.121
3.2.7 Looking at the UK as a whole, clearly the biggest potential impacts
come from crops that are grown on a large scale here. Wheat, for instance, is
the most commonly grown arable crop, and GM wheat could therefore have a
potentially significant impact on UK farmers.
3.2.8 Costs and benefits may also vary over time. For example, a build-up of
volunteer crop weeds (that is, crop plants which grow from seed left over from
the previous year's harvest) which are resistant to one or more herbicides,
could cause problems for farmers when they use the field for another crop.
Some farm-level cost savings are possible from currently available GM crops,
although these are hard to predict and vary between different crops and traits
3.2.9 Box 3.1 illustrates the type of cost impacts that could be associated with
the use of herbicide tolerant crops, the main trait found in commercially
available GM crops which could be grown in the UK.122
It shows that the
potential size of impact depends to a large degree on the effectiveness and
cost of existing methods of weed control.
119
The Science Review is looking in detail at whether GM crops could accelerate the
development of pest resistance.
120
The Invigor varieties of oilseed rape claims to have higher levels of hybrid purity due to the
use of the GM trait in the seed breeding process. See PG Economics (2003), page 66,
available on the project website.
121
Soil Association (2001) "Seeds of Doubt".
122
A large amount of international evidence exists on other GM crops, such as herbicide-
tolerant soybeans and insect-resistance maize. This evidence is reviewed by PG Economics
(2003). However, as these crops would not be grown in the UK, we do not consider this
evidence here.
64
Box 3.1: Examples of farm-level agronomic impacts from GM crops that
could be grown in the UK123
Herbicide tolerant oilseed rape. Oilseed rape is an important UK crop,
making up around 10% of the total UK arable crop area.
Weed control is currently reasonably effective in oilseed rape production in
the UK. Expenditure on herbicides ranges from 36-45 per hectare (in
comparison, total variable costs124
of growing are around 200 per hectare).
Expenditure on glufosinate for an HT crop would probably be in the region of
21-65 per hectare, and so might only offer savings to farmers with worse
than average weed problems.
However, it is possible that the crop could deliver yield increases. This could
occur through a combination of reasons: there may be a reduction in knock-
back125
; better weed control may improve the reliability of yield; and some
varieties may offer improved hybrid vigour due to the use of the HT
characteristic in the seed production process. The majority of international
evidence suggests that yield benefits would arise, although there is a wide
range of results (-15% to +22%).
One Canadian study found that this yield impact helped to produce a 30%
increase in gross margins126
against a conventional crop, even after taking
into account the higher cost of GM seed127
. In contrast, a second Canadian
report128
found that HT oilseed rape produced a lower return than
conventional, by up to 7%. These results may not, in any case, be applicable
to the UK, as market conditions here could be very different.
Herbicide tolerant sugar beet. Sugar beet, which is grown largely in
Eastern England, makes up 4% of the total UK arable crop area.
In contrast with oilseed rape, weed control in sugar beet is currently relatively
difficult and costly. Farmers may spend in the region of 84-167 per hectare
on weed control (including application costs). Desk-based studies suggest
that UK farmers growing GM sugar beet might be able to cut this cost to 26-
40 per hectare, although there would be additional costs in other areas,
particularly the increased price of buying GM seeds.
123
The evidence presented here is drawn largely from the literature review conducted by PG
Economics. The analysis paper: Analysis of the Costs and Benefits of GM crops in Product
Chains (available on the project website or on request from the SU) gives more detail on the
costs and benefits associated with these, and other, crops
124
Total variable costs include all costs incurred on an ongoing basis in the operation of the
farming activity. They do include fixed costs such as the cost of the land.
125
The knock-back effect is tested when in the pesticides approval process, and pesticides
with an average impact of over 5% are not approved; this therefore provides an upper limit to
the gains from this specific impact.
126
The gross margin is equal to total revenues earned less total variable costs incurred,
before taking into account items such as taxation.
127
Canola Council of Canada (2001) "An agronomic and economic assessment of transgenic
canola".
128
Fulton & Keyowski, University of Saskatchewan (1999) "The producer benefits of
herbicide-resistant canola".
65
Evidence on yield impacts is hard to assess, as there is no commercial
growing of this crop in the world now. What evidence there is suggests that at
worst there is no yield impact, and at best there may be yield gains of 5-15%
from HT sugar beet, due to reduced damage from chemical spraying, and
better weed control.
Less debatable is the fact that weed control in HT sugar beet is likely to be
easier and more flexible than in conventional sugar beet. Financially, this
could lead to savings in terms of labour costs, and money spent on buying
agronomic advice.
Herbicide tolerant maize. Almost all the maize grown in the UK is used for
animal feed. It makes up around 2% of the total arable crop area, and is
grown predominantly in southern and central areas of the country.
Current methods of weed control in maize are reasonably economic and
effective, with total herbicide costs amounting to 15-42 per hectare, out of
total costs of around 400 per hectare.
However, they are based on the use of atrazine, a chemical that is very
persistent in the soil. As well as being environmentally undesirable, this also
restricts which crops can be grown in subsequent rotations. Weed control
without atrazine would be more expensive (perhaps rising to over 50 per
hectare).
Herbicide costs for an HT variety would be around 25-60, depending on
how many applications were needed. This may not be economically attractive
to farmers growing maize, therefore, unless atrazine were to become
unavailable.
3.2.10 The complexity of the issues discussed in the box demonstrates how
the introduction of a GM crop may have a range of effects on costs and
revenue. The box also shows that the impact may vary widely from crop to
crop.
3.2.11 Despite a large body of evidence on HT crops, the effects described in
the box are still subject to a degree of uncertainty. This is both because
different pieces of research have come up with different estimates of impact,
and because the impacts themselves may not be replicated in a UK context.
Future developments in the technology could offer more significant benefits ­
but their development is subject to considerable uncertainty
3.2.12 Crops are currently being developed which address a range of other
agricultural issues. These include crops which offer new ways to deal with a
range of pests and diseases, such as viruses and fungal infections, either in a
way which is, it is claimed, more effective or cheaper than existing methods,
and/or less environmentally damaging. Other areas of research are looking at
ways to make crops more resilient to environmental conditions, such as
drought, saline or cold resistant crops; and at ways to make crops which use
66
resources more effectively, for example through nitrogen-fixation (the
transformation of nitrogen in the air to nutrients which can be absorbed by the
plant).129
3.2.13 Many of these developments are still at laboratory stage, and efforts
are also being made in parallel to gain similar results through alternative
methods such as non-GM crop breeding, and the use of more integrated
agricultural systems. For these reasons, it is hard to give an overall idea of the
potential impact of these future crops.
3.2.14 But as Box 3.2 suggests, such crops do at least have the potential to
deliver significant benefits to UK agriculture ­ if they could be successfully
developed. Scenarios which envisage a widespread use of GM crops as well
as rapid technological developments could therefore see more benefits from
this type of crop ­ although this may be accompanied by new types of risk.
Box 3.2: Potential impacts of possible future GM developments
Fusarium resistant wheat.130
A wet climate means that wheat growing in
the UK is vulnerable to fungal infections. One of these is fusarium, which is of
particular interest since infested wheat can contain mycotoxins, which are
dangerous to human health. The incidence of fusarium (and of its treatment)
varies widely from year to year; survey evidence131
shows that at its worst, it
can affect up to 60% of the UK wheat crop, although in other years only a very
small proportion of the crop may be affected. A precise financial benefit is
therefore hard to ascribe. However, effective control of fusarium could
improve quality levels and reduce the instance of crops being rejected outright
due to infestation, making farm incomes more stable. It could also reduce
risks to human health.
Nematode resistant potatoes. The potato cyst nematode (PCN) is one of
the key pests of the potato crop, causing annual yield losses of approximately
43 million. The pest is currently controlled by a combination of crop rotations
and chemicals (nematicides); these chemicals are relatively toxic and many
are being phased out. Research at Leeds University132
has used GM
technology to develop an alternative way to control the PCN which has a
lower environmental impact. The product could potentially give farmers a
replacement for pesticides that have been withdrawn, as well as producing a
more reliable yield. However the technology is still at the stage of early
research, so its full impact has not been thoroughly tested.
129
A list of crops under development, based on the AEBC Horizon Scan, is given in the
background working paper on industry and science (published on the project website in
January 2003).
130
Fusarium resistant wheat is currently under development by Syngenta.
131
Annual survey, Central Science Laboratory (www.csl.gov.uk).
132
See the response to the project-scoping note from Professor Howard Atkinson, available
on the project web site.
67
But these potential benefits may be offset by additional costs, or by the lower
marketability of the crop
3.2.15 Farm incomes have been low in recent years, and farmers are looking
ever more keenly for cost savings. In this context, the kind of cost and
convenience advantages described above would be appealing to many
farmers.
3.2.16 However, there are other important factors involved which would offset
some of these cost savings, and could limit the take-up of any commercially
available GM crop, at least in the short term.
ˇ GM seeds would be sold at a higher price than conventional seeds, so that
agricultural biotechnology firms can recoup some of their research and
development costs. Overseas, this has generally taken the form of a
premium on seed prices (along with a requirement that farmers buy new
seed each year). This may be accompanied by a contractual requirement
that farmers only use a particular brand of herbicide.133
However, these
requirements are becoming less common in the US, and the economics of
the sale of GM products are becoming more like that of other newly-
developed crops ­ with profit coming purely through higher seed prices.134
The size of the premium varies between crops and countries. As an
example, GM soybean seeds in the US cost around 30-35% more than
their conventional counterparts; but due to weaker market conditions, the
premium in Argentina is around 20%.135
The size of the seed premium that could apply in the UK is hard to predict,
as this would vary by crop, and depend on European market conditions.
Companies would set a price which they believed would make the crop
economically attractive to farmers, as well as providing them with a good
return.
ˇ A second element of additional costs may be the financial cost and/or
inconvenience involved in complying with the regulations surrounding the
commercial cultivation of GM crops. Connected with this, farmers may be
concerned that they might be held liable for any adventitious presence of a
GM crop in neighbouring fields. These issues are discussed in Section 3.3.
ˇ A third, and critical, factor is whether there would be a market for the crop.
The key message of DEFRA's Strategy for Sustainable Food and
133
Some herbicide-tolerant crops will only work with a particular branded herbicide, which is
produced by the same company that makes the seed, so allowing them to sell more of this
herbicide without the need for contractual conditions. However, this is not the case with
Monsanto's widely-used Roundup Ready crops, which are tolerant to glyphosate. The
chemical used in the "Roundup" herbicide is off-patent, meaning that proprietary brands are
available at a cheaper price than Monsanto's Roundup brand.
134
Monsanto used a simple royalty system to sell its Roundup products in both 2002 and
2003.
135
PG Economics (2003).
68
Farming136
, and of parallel strategies in the devolved administrations, is of
reconnection. A vital part of this is that farmers should reconnect with
consumers; like all businesses, the report says, farmers "have to respond
to what consumers care about and want". At present, though, many
consumers have a negative attitude towards GM foods, and most retailers
do not stock GM products. Producing GM products, albeit at a slightly
lower price, would therefore ­ in the current climate ­ not be consistent
with the vision set out in these reports, and could leave farmers facing a
low market price or, in the extreme, no market at all.137
Of course, public attitudes could change, particularly if GM crops start to
deliver specific consumer benefits. Any such change may, however, take
time to filter through into actual demand if retailers are reluctant to change
their policies. It is also important to stress that this argument applies to a
much lesser extent to crops grown for animal feed (such as maize, one of
the Farm Scale Evaluation crops), and non-food crops (such as GM
cotton, grown widely overseas). Indeed, imported soybeans with a GM
content are already used in UK livestock production, though some sectors
use non-GM feed only, including the poultry industry, and organic livestock
farmers. Some farmers may also be able to grow GM crops for export
markets, although the crops for which GM varieties are currently available
are not ones which are exported on a large scale.138
3.2.17 Ultimately, individual farmers would have to take decisions about
whether the benefits outweighed the costs. The overall costs and benefits of
current generations of crops appear to be fairly finely balanced, and in the
short term other developments are likely to be more important to farmer
incomes, particularly reform of the Common Agricultural Policy.
3.2.18 Future crops may, though, bring more important cost savings. If
farmers do not have access to these crops, then they could ultimately lose
competitiveness in international markets. However, it is possible that these
crops could also introduce new risks.
3.2.19 Finally, there are questions over whether cutting the cost of producing
commodity crops such as maize will be an appropriate strategy for all UK
farmers. Undoubtedly, the efficient production of commodity crops will remain
important for UK farmers in the near future. But analyses of the British farming
sector, such as the Foresight report,139
suggest that rather than just trying to
make farming more efficient, farmers should also be trying to diversify their
output ­ by producing new types of product, or even moving into areas such
as tourism ­ or to add value to the crops they produce through, for instance,
136
http://www.defra.gov.uk/farm/sustain/newstrategy/index.htm.
137
For instance, British Sugar, which is the monopoly buyer of sugar in the UK, currently has
a no-GM policy.
138
Just over 10% of oilseed rape produced in the UK is exported, two-thirds of which is
destined for other EU countries. The proportion of exports of refined sugar is higher but (as
noted above) British Sugar, the UK processor, has a no-GM policy. Maize exports are
negligible.
139
Foresight report for the Food Chain and Crops for Industry Panel (2001) "Agriculture in the
UK ­ its role and challenge".
69
the production of premium-quality goods. The next section looks at the
potential role that GM crops may play in this.
New crops could help farmers to diversify their businesses
Farmers are looking for new sources of income
3.2.20 The search for higher or more stable sources of income by UK farmers
has already led to significant changes in the way in which the agricultural
sector operates. There is an increasing trend towards the production of high-
value added products such as organic produce (particularly in horticulture) ­
which has generally, to date, attracted a price premium ­ and towards
adherence to assurance standards of production.140
3.2.21 Some farmers are also attempting to capture more of the profit margin
of their products by cutting out stages of the food chain, for instance, through
selling directly to consumers in farmers' markets, although this remains a
small-scale activity.
GM products may open up some new options...
3.2.22 GM crops could contribute to this shift if the technology can be used to
produce goods that have high value-added, or are tailored toward specific
needs.
3.2.23 For instance, products could be designed which may have particular
appeal to consumers. These might include fruit and vegetables with a longer
shelf life, or enhanced nutritional value, and foods with reduced
allergenicity.141
3.2.24 Other possibilities include GM crops which meet the needs of livestock
farmers, such as crops with added protein value. Crops could also be
designed to fulfil particular non-food niches, such as the more efficient
production of paper from GM trees,142
or of industrial inputs.143
3.2.25 Many new products could also be produced using non-GM techniques
­ particularly as the pace of non-GM crop development has accelerated
recently, due to a better understanding of crop genomics. One recent
development, for instance, is a broccoli with enhanced levels of a cancer-
preventing substance which was developed using non-GM techniques.144
140
Examples include the "Little Red Tractor" logo, which denotes products made under the
British Farm Standards scheme.
141
Annex 1 to the Industry and Science Background Working Paper (January 2003) set out a
range of possible developments, based on the AEBC Horizon Scan.
142
Agricultural Biotechnology in Europe (2003), discussed in "Future developments in crop
biotechnology".
143
The environmental and human health impacts of such crops are discussed in Section 3.5,
and in more detail in the analysis paper: Analysis of the Costs and Benefits of GM crops to
the Environment and Human Health (available on the project web site or on request from the
SU)
144
http://www.seminis.com/news/news_2003/PR_2003_January29.html
70
3.2.26 However, the availability of GM technology would at least provide an
extra option for crop developers, and so could ultimately expand the range of
available products. In scenarios which encourage rapid developments in GM
crop technology, therefore, there may be a wider range of such products
available, and/or faster development times.
...although some potential downsides have to be taken into account
3.2.27 Depending on the product, there could be uncertainties over the
acceptability of such crops ­ both to consumers, and to the regulatory
authorities. Non-food crops, for instance, might have to be grown under glass
­ both to reduce the risk of contaminating food crops, and to assuage public
concerns about the release of GM crops into the environment. Similar
suggestions have also been made for food crops, as a way of reducing risks
and making them more acceptable. However, growing under glass could
prove to be a costly option, and would certainly have a material impact on the
economics of growing GM crops.145
3.2.28 Another consideration is that farmers may not reap the benefits from
some developments in this area. Research into the use of crops to produce
pharmaceutical products, for instance, is quite far advanced, and such crops
would be likely to have a high market value. Alternatives to GM crops as a
source of pharmaceuticals exist;146
and even if such crops were used, they
would be likely to be grown in very small quantities, under highly controlled
conditions, and so are unlikely to have a significant impact on the overall
economics of farming.
3.2.29 Finally, it is possible that the introduction of GM crops could, whilst
opening up some options, also limit others. In particular, if co-existence
measures prove to be less effective than is currently expected, then organic
farming may become a more expensive and less attractive option, because of
the risk of the accidental presence of GM material. This could make the aims
to expand organic farming set out in the Organic Action Plan for England147
harder to achieve, and reduce consumer choice. This issue is discussed in
detail in the following section.
3.3 Practicalities of the supply chain: providing consumer and
farmer choice
Segregation of GM and non-GM products requires a range of measures
to be taken
145
Actual costs of growing under glass would depend on the level of containment needed. A
normal greenhouse used for horticulture would not prevent the escape of pollen or insects
into the environment; something much more sophisticated would be needed to provide a
completely sealed space. Data from DEFRA and the HSE Inspectorate suggest that typical
set up costs for high-specification GM research glasshouses (of 500 -1000m
2
) range from 1-
2 million, indicating the upper end of the potential cost range).
146
See Industry and Science analysis paper available on the project website.
147
DEFRA (2002) "Action Plan to develop Organic Food and Farming in England".
71
Segregation is seen as important to maintain consumer choice
3.3.1 Keeping GM crops and foods separate from non-GM148
crops and foods
is currently considered important for economic reasons, both in order to
provide choice for farmers and consumers, and to maintain price differentials
for products that are valued differently by consumers. There are also legal
obligations on the labelling of GM products under European regulations.
However, segregation is not a safety issue, as the GM crops in question
would all have been judged to be safe under the approvals system.
Segregation of GM and non-GM crops may have different elements
3.3.2 There may be different elements to the segregation of GM and non-GM
products.
3.3.3 At the farm level, co-existence measures could be used to limit
adventitious presence of GM material in neighbouring non-GM crops.149
3.3.4 Proposed EU-wide legislation on traceability and labelling will require
producers of GM crops to trace and label final products of GM, whether or not
they take additional steps to keep their produce separate from non-GM crops.
3.3.5 Non-GM producers who wish to guarantee the non-GM nature of their
products may choose to adhere to an identity preservation system, which
seeks to minimise the level of GM adventitious presence. This would require
farmers, and others in the product chain, to take a number of practical steps
to minimise adventitious presence, and to put in place records to confirm that
these steps have been taken.
3.3.6 Such identity preservation systems are already in place for a number of
high-value products, such as soya for the production of tofu. In the future, it is
also possible that they might be used to preserve the purity of high-value GM
products against the adventitious presence of other GM or non-GM crops.
There are different views on the appropriate threshold for GM presence
3.3.7 The mixing of GM and non-GM crops and foods may happen in many
different ways ­ from impurity of the original seed, to pollen drift from one field
to another, to the use of a truck that has not been cleaned out.
3.3.8 For these reasons, the absolute absence of GM content in non-GM
products cannot be guaranteed (just as the absence of other unwanted
material, such as dirt, also cannot be guaranteed). This applies whether or not
GM crops are grown here.
3.3.9 However, the accidental presence of GM material can be kept to a
minimum. The limit of reliable detectability is currently thought to be 0.1%. At
this level, though, tests may give misleading results unless large sample sizes
148
The definition of "non-GM" is the subject of some controversy ­ see following text.
149
The forthcoming AEBC report on co-existence and liability will consider this issue in detail.
See www.aebc.gov.uk.
72
are used. Such a low threshold may also be expensive to achieve, given the
large number of variables that may affect the ability to detect GM presence in
particular crops, including potentially long supply chains from third countries.
At the European level, therefore, adventitious presence is currently defined as
up to a 1% presence150
across the board.
3.3.10 Different groups view these limits in different lights. Parts of the organic
sector, as well as many consumers of organic foods, would prefer a 0% limit,
although others would accept 0.1% as a limit for GM presence in organic
food. The SU's discussions with retailers suggest that currently, many are
telling their suppliers that any GM presence should be below the 0.1% limit of
detectability. These stances might change if GM crops were commercially
grown in the UK, and/or if consumer attitudes changed.
Segregation issues already arise in relation to imports; but additional systems
may be required if GM crops are cultivated in the UK
3.3.11 In response to their customers' demands, some commercial importers
have put in place voluntary systems to segregate non-GM and GM imports of
particular commodities - mainly soya151
- and to check for the purity of seed
imports. Unless there is a major shift in European consumer opinion, these
systems may have to develop to deal with increasing volumes of segregated
imports, whether GM crops are cultivated here or not. The scale and cost of
this will depend on the capacity of the global market to supply non-GM crops.
3.3.12 In addition to this, if GM crops are commercially cultivated in the UK,
additional measures may need to be considered to facilitate the co-existence
of GM and non-GM crops at the farm level. The next section looks at the
possible costs of this.
At the farm level, many of the measures required are in line with existing
good practice...
3.3.13 Given the number of different routes by which adventitious presence
may occur, keeping GM and non-GM crops separate at the farm level requires
a range of measures to be taken.
3.3.14 It is not easy to judge whether these types of measures would impose
additional costs on farmers, or whether they would merely require the
application of good farming practice combined with co-operation between
neighbours.
3.3.15 The most useful parallels are other types of segregation systems which
currently exist in the UK. Examples include the production of certified seeds,
which have to attain a certain level of purity, and of high erucic acid or HEAR
rape, which is grown for the production of industrial chemicals and cannot
enter the food chain. On a larger scale, the separate production and use of
150
This may change once new regulations on traceability and labelling come into force. See
the Regulations Analysis Paper, available on the project website, for further details.
151
A number of crops, including soya, are currently approved for import into the EU. These
are mostly used for animal feed.
73
organic produce is another example. None are perfect parallels to the GM
crops situation ­ either because they are from relatively small-scale growing
or, in the case of organic produce, because the market conditions are very
different. However, it is still useful to consider on a general basis how these
systems work.
3.3.16 The production of HEAR rape and certified seeds, for instance, require
fairly similar segregation measures to be taken as would the production of GM
crops. To date, these have worked well. Separation distances are generally
achieved through co-operation between neighbouring farmers, who may
agree to change crop rotations in order to avoid having neighbouring fields of
the same crop.
3.3.17 There is more direct evidence from the Farm Scale Evaluations, which
required farmers to adhere to guidelines to keep the crop segregated from the
food chain.152
A survey of farmers who have taken part in the Farm Scale
Evaluations of GM crops found that 94% considered the guidelines "very
straightforward" or "fairly straightforward" to comply with, although three-
quarters agreed that they did impose some extra effort in terms of record-
keeping or practical issues.
3.3.18 Experience therefore suggests that segregation is achievable without
excessive costs. However, a range of factors would affect whether this would,
in practice, be the case for GM crops. These are explored below.
...although costs may arise, depending on a range of factors
3.3.19 Whilst it is very difficult to attach monetary values to the costs of co-
existence, it is possible to identify the factors that determine whether any
costs will arise, and what their magnitude is likely to be.
ˇ Type of crops: crops that cross-pollinate over a wide area, such as oilseed
rape, will be much harder to keep separate than those (such as soybeans)
which are self-pollinating. Also, it would be easier to conduct hygiene
measures, such as machinery cleaning, with large crops such as potatoes
than with small seeds such as oilseeds.
ˇ Farming system: the maintenance of separation distances may require
changes to crop rotations. This will be more difficult in systems that rely on
rotations for weed control or nutrition, such as low-input systems or
organic farming.
Non-GM farms using farm-saved seed may also face problems due to a
possible accumulation of GM presence in seeds over the years: this could
also have a serious effect on the farm-saved seed industry itself. If the
supply of farm-saved seed is reduced, this may increase the market
power that seed companies hold over farmers.
152
SCIMAC, the Supply Chain Initiative on Modified Agricultural Crops, developed a set of
guidelines to be used by farmers growing GM crops. See www.scimac.org.uk
74
ˇ Degree of co-operation: in cases where farmers find it easier to co-
ordinate their crop rotations, any co-existence system is likely to be less
costly.
ˇ Stringency of the measures put in place: the more cautious the regulatory
approach ­ and the lower the level of adventitious presence which is
allowed ­ the more costs are likely to be imposed on farmers. However,
more stringent requirements for GM farmers would minimise potential
problems for non-GM or organic farmers. This trade-off could vary
significantly between the scenarios set out in Chapter 4.
If the organic sector sets lower thresholds than conventional non-GM
farmers, then segregation would be harder to achieve. However, organic
acreage of the crops being considered for commercialisation in the short
term is currently fairly low ­ only 0.05% of the total 2002 oilseed rape crop,
for instance, was organic. This issue would become more pressing if GM
varieties of commonly grown organic crops such as vegetables became
available.
ˇ Farm size: adherence to any guidelines on co-existence is likely to be
more difficult in areas with a large number of small farms or small fields,
due to the more widespread sharing of machinery, and the larger number
of neighbours with whom the individual farmer has to co-ordinate crop
rotations.
ˇ Current adherence to good practice: if a farmer already operates
according to good practice standards, such as the Assured Combinable
Crops Scheme, then the introduction of GM might only require changes to
existing systems. However, if they do not, then they may have to introduce
entirely new systems.
ˇ Technological developments: future developments in GM technology could
help to reduce some of the problems with co-existence. This might involve,
for instance, breeding GM plants that have different flowering times to their
conventional counterparts.
3.3.20 Because of all these factors, there is considerable uncertainty about
what the actual costs of co-existence might turn out to be. The forthcoming
AEBC report on co-existence and liability will shed fresh light on the issue. But
this is an area that would have to be kept under close review if GM crops
were commercialised in the UK.
3.3.21 Costs would also arise if a co-existence system were backed up by
inspections to check compliance. Box 3.4 sets out the costs of the current
regime of inspecting GM field trials in the UK. The regime checks adherence
to the consent conditions attached to release approvals, not to co-existence
protocols. However, there is some overlap in the type of work that would have
to be done in each case, and the numbers provide a reasonable comparison.
If GM crops were grown on a wide scale, some economies of scale may result
as several farms could potentially be inspected during one visit.
75
Box 3.4: Costs of inspection153
The GM Inspectorate (for England and Wales154
), part of DEFRA's Central
Science Laboratory (an Executive Agency of the Government), is responsible
for field inspections of GM releases. In 2002-3 the Inspectorate carried out
124 routine field inspections (largely FSE sites), at an average cost of
approximately 400, and a number of call-out emergency visits at 430 per
visit.
In addition, the Inspectorate carries out desk-based audits of compliance with
consents. It also investigates any problems - such as the 2002/3 seed
contamination incident, where a proportion of seeds supplied by Aventis (now
owned by Bayer) for a Farm Scale Evaluation trial were found to contain
modifications conferring a type of antibiotic resistance, as well as herbicide
resistance.155
Dealing with this incident has so far cost the Inspectorate over
40,000.
Those further along the product chain may also have to change some of
their practices ­ although many of these measures may be needed to
deal with imports anyway
3.3.22 Segregation does not end at farm level. To achieve segregation of GM
and non-GM crops, measures have to be taken all the way through the
product chain, to the level of the retailer or caterer.
3.3.23 This may impose costs on organisations throughout the product chain,
such as transporters, grain processors, and food manufacturers. The diversity
of systems used by different players, and the differences between different
organisations, makes it hard to generalise about the costs imposed.
3.3.24 However, it is possible to identify some possible areas of cost. The
importation of both GM and non-GM soya, mainly for animal food, provides an
example of the measures that have to be taken, which include, for instance,
the use of separate silos for storing each type of product.
3.3.25 The handling of the segregation of organic and conventional crops may
be analogous to the way manufacturers might handle GM. One major food
manufacturer told the SU that organic and conventional foods could be
processed on the same production line if this was timed carefully. Specifically,
they make organic products in the morning, after machines have been
cleaned down, and conventional products in the afternoon. It is likely that
similar measures would be taken for handling GM, rather than more drastic
steps such as setting up separate production lines. Again, this would depend
on the thresholds set for adventitious presence.
153
Source: GM Inspectorate.
154
In Scotland the GM Inspectorate is the Scottish Agricultural Science Agency (SASA).
155
See http://www.defra.gov.uk/news/2002/020815a.htm.
76
3.3.26 Manufacturers and processors may also wish to carry out testing to
check the integrity of non-GM products. The costs of tests vary,156
depending
on the nature and accuracy required of the results; examples of costs for
basic tests are given in Box 3.5.
Box 3.5: Costs of testing157
The most basic tests are strip tests for the presence of a particular
protein, which cost 5, give a quick answer and can be performed by non-
experienced personnel. However, these have limitations: for instance, they
only detect a particular GM trait, and do not work if the protein is not
expressed in the particular tissue tested. They also do not give any idea of the
scale of GM presence.
ELISA158
tests also look for protein, and so are subject to some of the same
limitations, but can produce a quantitative result. They cost 10-20 and are
generally performed in laboratories.
A PCR test looks for the presence of the transgene itself, rather than the
protein it produces, and is therefore more reliable. The test uses a range of
primers specific for various traits and events and can thus test for several GM
constructs at once. It can also be made quantitative. The PCR test normally
takes 5-10 days to process, and costs around 200.
3.3.27 The likely extension of GM technology to new types of crop
internationally will add to these costs, whether the UK grows such crops or
not. It is therefore possible that commercial cultivation in the UK would not
create many additional costs.
Adventitious presence will still occur, even if this is rare ­ the further
along the food chain this is discovered, the costlier it will be
3.3.28 Even if measures are taken to minimise adventitious presence, it is
inevitable that it would still occur, even if very rarely. Measures have to be in
place to deal with this eventuality, in particular a system of apportioning
liability for economic loss.
3.3.29 If accidental presence were detected at the farm level, then the cost
incurred would amount to the loss of the non-GM or organic premium from the
harvest.
3.3.30 The question of who is liable in the event that adventitious presence is
discovered is a complex one.159
Blame would be hard to prove, and might
156
Similar testing technologies are being developed for medical and other purposes. Overall
the costs appear likely to diminish as technology develops.
157
Source: GM Inspectorate. The forthcoming AEBC report on co-existence and liability will
consider the issues around testing in more detail.
158
Enzyme-Linked Immunosorbant Assay.
159
The P has been working on the issue of liability at the farm level, and their forthcoming
report will discuss this issue. This study has therefore not dealt with the issue in detail.
77
depend on whether it can be shown that the farmer growing the GM crop had
complied with any relevant industry guidelines or regulations. The fear of
incurring liability for economic loss arising on a neighbour's farm could
potentially prove a deterrent to farmers thinking of growing GM crops.
3.3.31 Non-GM farmers might decide to take out insurance to cover possible
costs, as a way of reducing the risks they face. Currently, however, such
insurance is not available.160
Were a workable co-existence system to be in
place, a market would be likely to develop. However, in situations where co-
existence proved to be problematic, then insurance might remain unavailable,
or be prohibitively expensive.
3.3.32 If a problem were only discovered after the product had left the farm,
then costs might be higher. If the product had reached supermarket shelves,
then costs would be incurred in removing the mislabelled product.161
Liability
would also be harder to prove, as the product would have been through many
intermediate stages, and individual harvests would have been mixed together.
3.4 Wider impacts on the rural economy and society
The promotion of a "green" reputation has economic value for many
rural areas...
3.4.1 Many areas of the UK actively promote their "green" reputation in order
to market goods and services. Areas which are heavily dependent on rural
tourism ­ such as parts of England, and many areas in Wales and Scotland ­
rely on a positive image of their countryside to attract visitors. And food-
producing regions may be able to attract a higher price if they have a
reputation for purity (Scottish salmon is one example).
...and some believe that a "GM-free" label may help to maintain this
image
3.4.2 A "GM-free" label is seen by some as a way of reinforcing this
reputation. This has been a factor in the decision of several councils to
declare themselves "GM-free zones", as well as in the establishment of
movements to keep Scotland and Wales "GM-free".
3.4.3 There is no evidence that tourism would be affected by the growing of
GM crops. Canada, for instance, still promotes its environmental image
strongly in attracting tourists, whilst also growing GM crops.
3.4.4 However, there are more specific concerns about the impact of
adventitious presence of GM material. Some food producers argue that even
a minimal amount of GM content, well below the threshold for statutory
labelling, may damage the reputation of their products. An example is honey.
160
"Technical Bulletin on Genetically Modified Crops", NFU Mutual May 2000
161
The costs of such a move are described in the Environment and Human Health Analysis
paper, available on the project website.
78
Research suggests that even if GM crops were grown in honey-producing
areas, the small amount of pollen in the final product would mean that the GM
content in the honey could be expected to be only 0.00000000003g in a 500g
jar.162
However, submissions to the SU's review suggest that beekeepers are
still concerned about the risk to their reputation.
The broader social impact of the introduction of a new technology also
needs to be taken into account
3.4.5 Any wider social controversies over GM crops are likely to be replicated
in rural communities. But problems specific to farming communities may also
occur. For example, tensions over the introduction of GM crops may damage
relations between neighbouring farmers, or between individual farmers and
their local communities. Such tensions are more likely to arise if there are low
levels of trust in the regulatory systems set up around GM crops, or confusion
about liability and segregation.
3.4.6 This effect may be more likely to arise in circumstances where problems
emerge with the co-existence system.
3.5 Agriculture, the environment and human health
The interaction between agriculture, the environment and human health
is a complex one
3.5.1 Agriculture and the environment are very closely linked in the UK. In the
past, the introduction of new technologies has often had unforeseen and
significant impacts. Increasing mechanisation, for instance, led to larger field
sizes and the destruction of hedgerows, which damaged farmland
biodiversity. Against this background, it is important to assess the potential
environmental and human health impacts in the case of GM crop
commercialisation.
3.5.2 It is also possible that GM crops could help to achieve some of the UK's
environmental and human health objectives, such as those set out in
DEFRA's recent Strategy for Sustainable Food and Farming, and in similar
documents in the devolved administrations.
3.5.3 This section gives the SU's assessment of how GM crops might change
the way in which farming is conducted in the UK, and the environmental
implications of this. It does not consider the scientific evidence of the direct
impacts of GM crops, such as, for instance, the possibility that an allergen is
found in a GM food, as these are being considered in detail in the Science
Review, as well as being looked at as part of the regulatory process. However
this section does discuss the potential role of monitoring in picking up adverse
effects on the environment or health, and Chapter 4 contains a more general
discussion on the impact of unexpected events, be these positive or negative.
162
MAFF funded study (1997) "Honey from genetically modified plants: Integrity of DNA and
entry of GM-derived proteins into the food chain via honey."
79
GM crop cultivation could lead to significant changes to the type, timing
and quantity of pesticides used
Pesticides are integral to conventional agricultural methods...
3.5.4 Increasing chemical inputs have helped to increase yields across a
range of crops in the UK and in other developed countries over the past half-
century.
3.5.5 A major component of this has been pesticide use. Pesticides comprise
a range of chemicals which kill or control weeds or pests, including herbicides
(weedkillers), insecticides, and fungicides (to control mould and fungus).
...but there has been mounting evidence of their costs, leading to initiatives to
minimise their impact
3.5.6 The approvals system for pesticides checks for detrimental impacts on
the environment or human health. However, the use of pesticides can still be
damaging to the environment or to human health in a number of ways, which
may include163
:
ˇ Drinking water quality impacts: ground and surface waters may not meet
standards for drinking water quality, leading drinking water suppliers to
use alternative drinking water sources or (more likely) deploy measures
to remove pesticides;
ˇ Agro-ecosystem and biodiversity impacts: including harm to non-target
species, damage to ecosystems through the treatment of the pest and
harm to non-target species, and wider impacts associated with their role
in facilitating the intensification of agriculture; and
ˇ Human health impacts: pesticide users, bystanders, and consumers of
food with pesticide residues.
3.5.7 In recognition of this, there is a UK-wide voluntary initiative to promote
best practice in pesticide use. If this initiative does not achieve its objectives,
then a pesticides tax may be introduced.
3.5.8 This section talks mainly about herbicide-tolerant crops, as these are
already commercially grown in other countries and there is a body of evidence
on their impact. However, many of the arguments would also apply to crops
designed to change or replace other types of pesticide.
The cultivation of GM crops could lead to significant shifts in pesticide
use...164
3.5.9 Herbicide tolerant crops generally allow the replacement of existing
herbicides with "broad-spectrum" herbicides, which are effective against a
163
These points are taken from DETR (1999) "Design of a tax or charge scheme for
pesticides".
164
The scientific evidence on these impacts is considered as part of the Science Review.
80
broad range of weeds. The crops are resistant to either glyphosate or
glufosinate ammonium.
3.5.10 There has been a great deal of debate over whether these crops
reduce the quantity of chemicals used. No clear conclusions have emerged in
this area; the evidence varies from crop to crop, and much depends on the
decisions made by the individual farmer.
3.5.11 However, the use of GM crops would undoubtedly affect the type of
chemicals used. Glyphosate and glufosinate ammonium have some
advantages over some of the chemicals they would replace; glyphosate in
particular has a low persistence in the soil, minimising run-off into water
courses; and both chemicals have a low toxicity to animals.
...which could have broad impacts
3.5.12 One particular impact that could be significant is the effect of GM crops
on the effectiveness of pest control. Unlike conventional methods, HT crops
offer the possibility of very effective weed control at all points in the growing
cycle. Whilst this presents potential advantages to farmers (as discussed in
Section 3.2 above), it could reduce the quantity of weeds and, in the winter,
weed seeds in fields, reducing both plant biodiversity and the amount of food
available for animals throughout the year165
. Conversely, if crops were
managed with the objective of conserving biodiversity, farmers could suffer
yield losses166
. Here, therefore, there could be a trade-off between agricultural
and environmental objectives. The Farm Scale Evaluation results will shed
fresh light on this issue in the case of maize, oilseed rape and sugarbeet.
3.5.13 The use of GM crops could also affect the timing of pesticide spraying.
Glyphosate or glufosinate could be sprayed onto GM crops at a relatively late
stage. This might help to conserve in-field biodiversity by allowing weeds to
grow at certain times of the year, although if spraying is delayed too long then
farmers could lose yield167
.
3.5.14 The ultimate impact of these changes will depend on farmer behaviour.
This can be influenced in a number of ways. "Soft" incentives include codes of
good practice, and product stewardship schemes run by the biotechnology
companies. "Harder" incentives include the financial rewards attached to
membership of agri-environment schemes (see Box 3.5), as well as actual
regulation. Positive impacts would therefore be more likely to be realised if
GM crops were introduced into a carefully regulated environment, whereas if
regulations were more laissez-faire in their nature, net impacts might in
principle be either positive or negative.
165
Additional information about the biodiversity impacts of HT crops will be available later this
year, with the publication of the results of the FSEs.
166
For instance, Dewar et al (2000) "Delayed control of weeds in glyphosate tolerant sugar
beet and the consequences on aphid infestation and yield", shows that delaying pesticide
spraying on suger beet can result in yield losses of almost a third.
167
These types of changes are taken into account in the regulations governing pesticides,
under which any new crop/pesticide combinations and use patterns need to be approved. See
http://www.pesticides.gov.uk/committees/acp/acp.htm.
81
Box 3.5: Agri-environment schemes in the UK
Agri-environment schemes aim to reward farmers for managing their land in a
way which is environmentally sustainable. The main government-led schemes
currently in place are set out in chapter 2 (paragraph 2.4.19).
Looking forward, the government plans to introduce an "entry level" scheme
that would be available to all farmers168
. This scheme, which would present
farmers with a menu of options for changes to farm management, is currently
being piloted. It would be complemented by a higher-level scheme, offering
higher rewards for more significant action.
Such schemes are voluntary, but can have a significant impact by providing
an economic reason for farmers to follow good environmental practice.
Currently, there are no specific provisions for GM farmers in the pilot entry
level scheme, as there is no commercial cultivation of these crops in the UK.
However, adding some GM-specific elements would be one option for
influencing how farmers used these crops, and therefore, their overall
environmental impact.
3.5.15 The impacts from the replacement of chemicals and changes to pest
management regimes will, clearly, be larger if GM crop growing is
widespread.
3.5.16 Pesticide use also raises a number of other environmental issues, such
as the risk that a chemical used either on the crop ­ or engineered into the
crop ­ may affect a wider range of animals or plants than its intended target.
This type of effect is considered in the regulatory process, and is also being
considered by the Science Review. The implications of an adverse impact
being unexpectedly discovered is considered in Chapter 4.
GM crops are not the only option for changing pesticide use
3.5.17 The potential for GM crops to help achieve improvements in the
sustainability of pesticide use also needs to be put carefully into context.
There are many other ways to improve pest control without chemicals, such
as better planning of crop rotations, or the use of predator insects in
greenhouses. These methods could deliver significant environmental
improvements, akin to those which are claimed for some GM crops, although
they may also bring their own risks, such as the impact of predator insects on
local biodiversity, should they escape from greenhouses.
3.5.18 Some systems, such as integrated pest management, could use GM
as part of a package of farm management techniques.
GM crops could lead to changes in farm management ­ though the
impacts of this are subject to considerable uncertainty
168
http://www.defra.gov.uk/erdp/reviews/agrienv/default.htm
82
3.5.19 The methods of crop management associated with GM crops could
also lead to other changes, some of which could have environmental impacts.
Because of the easier weed control associated with herbicide tolerant crops,
farmers may be able to reduce the amount of tillage (ploughing) they have to
do, which could reduce soil erosion and the run-off of nutrients into
watercourses169
, as well as reducing energy usage. In the UK context, the
overall benefits from this would probably be fairly marginal, though could be
important in some areas.
3.5.20 A potentially more significant, though much more uncertain,
development in GM technology could be crops which help farmers to reduce
their reliance on inputs (other than the chemical inputs mentioned above).
Many farmers are already doing this by, for instance, planning their crop
rotations so as to minimise the need for additional inputs of nutrients. Future
GM crops could facilitate this through more efficient use of existing nutrients.
A GM drought-tolerant crop, were it to be developed, could also help to
reduce the use of water in agriculture ­ which could be particularly important
in the context of climate change.
3.5.21 It is also possible that crops with these desirable attributes could be
developed through non-GM techniques. However, it is likely that GM methods
would be a useful tool, and that by not using it, development may be more
difficult. If the regulatory system imposes few restrictions on developing GM
technology, then technological developments may be encouraged and there
could be a wider range of this type of crop.
3.5.22 As with chemical inputs, the success of any such technologies in
achieving environmental goals will depend on the actions of farmers. The
introduction of any such crops could be paired with schemes specifically
aimed at achieving environmental targets in order to maximise any possible
benefits.
Over the longer term, shifts in crop growing patterns could emerge
3.5.23 Over the past decades, there have been very significant shifts in crop
growing patterns in the UK. The area of land used for growing oilseed rape,
for instance, has grown by 60% over the last two decades, and the winter
growing of crops has become much more common. These changes may be
driven by economic circumstances or by technological developments.
3.5.24 Such shifts often have environmental consequences. Winter growing of
crops, for instance, can reduce the availability of food for birds which would
otherwise be available in fields of stubble.
3.5.25 It is therefore important to consider whether the introduction of GM
crops might lead to further shifts in the type or location of crops grown. This is
very difficult to judge ­ not least because there is no international evidence,
as yet, on any such shifts. Some changes are certainly possible. Modifications
to the efficiency of nutrient use, for instance, may change patterns of crop
169
The advantages of low-till agriculture are discussed in the Environment and Human Health
Analysis Paper, available on the project website.
83
rotations; and the availability of GM crops could affect the diversity of crop
growing. These changes are likely to be more significant in scenarios where
the use of GM crops is widespread. But it is not possible at this stage to say
whether the ultimate environmental impact may be positive or negative.
Monitoring could be important in picking up any adverse impacts
3.5.26 Despite the existence of a thorough regulatory system, it is important to
consider the possibility that a particular GM crop could have an adverse
impact on the environment or human health. Ongoing monitoring of GM crops
and food would help to pick up any such impacts at an early stage, making it
easier to deal with them if they were to arise.
Requirements are already in place for the monitoring of environmental
impacts...
3.5.27 The new European Directive on deliberate release (2001/18/EC)
contains a requirement for all applications for commercial growing to contain a
plan for post-market monitoring. The effectiveness of this requirement will
depend on how it is interpreted170
. Monitoring could also be carried out (or
funded) by the Government, by regulators, or by independent researchers.
3.5.28 Monitoring plans might, in principle, range from packages of measures
based largely on the reporting of problems by those using the crop, to ones
including extensive plans for primary research into a range of risks that could
be associated with the crop. Clearly, the latter type of monitoring would carry
higher costs than the former, and if required as part of post-market monitoring
could discourage firms from commercialising crops.
3.5.29 To be effective, monitoring should make the best use of existing data
on the environment and biodiversity. Additional costs may also be incurred,
which range from the costs of desk-based exercises correlating data on
biodiversity with that on the location of GM crop growing, to the costs of
conducting primary research. An example of the latter is the Farm Scale
Evaluations, set up with the purpose of monitoring impacts on biodiversity of
HT crops at a cost of 5.9 million to Government (plus substantial additional
costs to industry). The degree and type of monitoring is assumed to vary
between the five overall scenarios in chapter 4.
3.5.30 The identification of impacts on the environment could be hampered by
the complexity of the relationship between agriculture and the environment.
Baseline data on farmland biodiversity in the UK is fairly patchy, although it is
set to improve as a result of new plans for the co-ordination of monitoring from
the Joint Nature Conservation Committee171
. It can therefore be difficult to
spot changes in a timely fashion, as well as to determine the relationship
between cause and effect.
170
In the UK, the Advisory Committee on Releases to the Environment (ACRE) has recently
published draft guidance on interpretation
(http://www.defra.gov.uk/environment/acre/postmarket/index.htm).
171
JNCC (March 2003) "The future role of JNCC in biological surveillance and monitoring".
84
...though impacts on human health are harder to monitor
3.5.31 The identification of an impact on human health is by its nature difficult,
as people eat a very wide range of foods. Food is also only one of a range of
environmental and genetic influences on health. It is therefore often difficult to
pin a particular problem to a specific food, or indeed to food more generally
rather than some other problem.
3.5.32 A severe impact, such as a dangerous allergy, would almost certainly
be picked up in the regulatory process. However, it is far more difficult to
identify more subtle impacts, or ones that only occur cumulatively over time.
In these cases, cause and effect are hard to prove. It would also be easier to
identify risks arising from a "whole" GM product, such as an apple, rather than
from an ingredient, such as maize; but it is the latter type of product which is
likely to be commercialised first.
3.5.33 Effects would be easier to identify if a monitoring system were in place.
The Food Standards Agency has commissioned a feasibility study into how
such a system could work, due to be published in summer 2003. This issue
was initially considered by a subgroup of the Advisory Committee on Novel
Foods and Processes (ACNFP), which is responsible for recommending
whether to approve novel (including GM) foods.
GM crops might also contribute to the delivery of products with
environmental or human health benefits
3.5.34 Most of the GM crops which are currently commercially available have
been modified to contain agronomic traits ­ that is, traits which make the crop
easier to manage. It is possible that future developments in the technology
may result in crops which have been engineered to deliver specific benefits to
the environment and human health. Box 3.6 lists some possible benefits, and
the SU's Environment and Human Health analysis paper discusses in detail
how significant these benefits might be, and whether they could be developed
through non-GM routes172
.
Box 3.6: The possible future uses of GM technology to deliver
environmental or human health benefits173
Possible human health benefits:
ˇ Nutritional benefits, such as reduced fat absorption in potatoes
ˇ Disease prevention, through the overexpression of substances which are
beneficial to human health
ˇ Reduced allergenicity, such as wheat with a low gluten content
ˇ Longer shelf life, which could maintain a food's nutritional content for
longer, and perhaps encourage the consumption of fruit and vegetables
172
Section 3.2 discusses the possible value of such products in terms of their potential
economic value-added.
173
More detail on each of these, as well as references, are given in the Environment and
Human Health analysis paper, available on the project website.
85
ˇ Pharmaceutical crops, which could produce pharmaceuticals at a lower
cost
Possible environmental benefits:
ˇ Crops engineered to produce biomass energy more effectively, or to
produce fuels such as bioethanol
ˇ Environmentally sustainable materials, for instance biodegradable plastics
ˇ Crops which are designed to reduce energy used during processing, such
as trees with altered levels of lignin which are easier to convert into paper
3.5.35 However, as the analysis paper explains, these possibilities are subject
to a very great degree of uncertainty. Potential benefit will also depend on
other circumstances, including whether government policy is supportive. For
instance, changes to government's energy policy, and to the price of oil,
would affect the prospects for energy crops. Benefits will also depend on
whether consumers, processors and others accept the technology.
3.5.36 Again, non-GM methods could be used to develop these crops.
Indeed, the UK is already growing a limited amount of willow and other crops
for the production of energy. Recent developments in non-GM technology
include, for instance, a maize-based fibre and plastic174
.
3.5.37 Still, by restricting the use of GM technology in developing new
varieties, it would become less likely that some of these benefits would be
achieved within a given time. SU scenarios which either explicitly or implicitly
do not include GM crop cultivation are therefore likely to see a slightly smaller
range of such crops being developed. GM technology might also influence the
economics of some of these products, as well as their availability: herbicide
tolerant sugarbeet, for instance, may be cheaper to grow than its conventional
counterpart (see Box 3.1), and may therefore be marginally more attractive as
a source of bioethanol fuel.
3.6 Impacts on the science base in the UK
Impacts from GM crops could affect the achievability of the UK's aims in
science policy
3.6.1 As outlined in Chapter 2, the Government's overall aim for science and
technology is to expand the UK's research activity and to exploit the outputs
to generate social goods and economic growth.
3.6.2 Some areas of UK science and industry will be directly affected by the
fate of GM crops. These include the agricultural biotechnology (ag-biotech)
industry, and public research institutions working on ag-biotech. Groups that
may be indirectly affected include other biotechnology sectors (such as
healthcare (red) and industrial (white) biotechnology), venture capitalists, and
potential students.
174
See, for instance, http://www.cargilldow.com/ingeo/home.asp.
86
Multinational ag-biotech companies will be directly affected
Multinational Ag-Biotech activity has declined in the UK
3.6.3 The UK's historical position as a leading location for commercial
agrochemical and crop research has been eroded over the past two decades.
The number of UK R&D posts in the sector has fallen by over 60 % in that
time. This situation has been brought about principally by industry
consolidation, but exacerbated by recent public opposition and regulatory
approaches to GM crops. Syngenta's research station at Jealott's Hill is the
only major private research facility that has not been closed or severely
scaled down175
.
3.6.4 Although some multinational research previously conducted in the UK
has moved to France and Germany, the focus of most multinational ag-
biotech companies has switched away from Europe and is increasingly on
expanding markets: the USA and particularly the Far East.
It could decline further, be maintained or expanded
3.6.5 A deterioration, or even continued uncertainty, in the climate for GM
crops in the UK ­ such as that described in some of the scenarios in chapter 4
­ could reduce the companies' already small activity in the UK still further.
The companies' research programmes tend to bundle together many different
crop development activities, and they are unlikely to maintain their
expenditure in the UK by switching it from GM to non-GM crop development.
3.6.6 Even in a more positive climate for GM crops, it is unlikely that major
new research facilities would be built in the UK in the near future, particularly
given the growing interest in Far Eastern markets. A more likely outcome of a
more positive climate for GM crop research would be that existing facilities
would be maintained and in some cases expanded.
3.6.7 The potential to collaborate with experts in leading research institutions
is one of the most attractive elements of the UK as a location for crop
research. Multinational sponsorship of public sector research is probably the
most likely area of expansion in a more favourable GM crop climate. This is
discussed in the following section.
Multinationals are also important as purchasers/sponsors of Small and
Medium Sized Enterprises (SMEs) and public sector research
3.6.8 Because of the high regulatory costs involved, ag-biotech products (and
intellectual property) developed by SMEs and public sector research can often
only reach the market if they are bought up by, or licensed to, multinationals.
3.6.9 Multinationals can also sponsor specific research and development work
in SMEs and public sector research establishments (PSREs). This is a
significant revenue stream for SMEs and is also increasingly important to
175
See the Industry and Science analysis paper, available on the project website, for details
of recent events in multinational involvement in the UK.
87
PSREs, who are being encouraged by Government to conduct work more in
line with industry requirements. Prospects for GM crop commercialisation will
affect the amount and direction of the external research that multinationals are
prepared to sponsor.
3.6.10 Collaborative work tends to be most effective between institutes and
companies that are co-located; thus decisions about multinational research
stations in the UK will therefore also affect the extent to which this
collaborative work will be conducted here.
SMEs in crop technology research face their own set of problems...
3.6.11 The UK's research-based ag-biotech SME sector is small, and has
been relatively stagnant in the last five years. Its involvement in GM crops is
limited by access to investment, in particular venture capital, which has been
in short supply in recent years.
3.6.12 However, venture capital companies tend to want to be involved in the
next wave of technical developments, and if the climate for GM crop
development were to improve, funds for SMEs could become available fairly
rapidly.
...but are potentially very important in developing novel applications of plant
biotech
3.6.13 SMEs have accounted for only 6% of the GM crop trials in the EU.
Their work has focused on modified nutrients or ingredients, a reflection of
their need to create products for potential niche markets.
3.6.14 As discussed in Section 3.2 above, this type of specialised, high-value
crop may be attractive to farmers and consumers in the future; the absence of
a thriving SME sector may make it less likely that such crops would be
developed in the UK.
PSREs in plant science and ag-biotech have been hit by the decline in
commercial opportunities for GM crops
3.6.15 In principle, GM crops might be a way to help PSREs achieve some of
their objectives, such as improving links with industry176
. However, the
reduction in commercial activity in UK GM crop development has reduced the
ability of PSREs to win commercial sponsorship of research.
Many other applications of biotechnology to plant science and agriculture exist
­ though may not in practice substitute for GM
3.6.16 GM is only one way of using modern biotechnology in plant breeding
(see Section 3.4). Agricultural crops can also benefit from biotechnology
through, for instance, diagnostic techniques to improve the targeting of
176
This point is explored in the Industry and Science analysis paper, available on the project
website.
88
pesticide applications. Genomics can also be used to identify suitable
varieties for growth in organic systems.
3.6.17 However, some of this research may be inherently difficult to turn into
major revenue streams (it may not be patentable, or it may generate
environmental or quality of life improvements but not profit-making ones). As a
result, sources of commercial sponsorship may be difficult to find. If
multinational sponsorship dries up, there is no guarantee that research will
expand to focus on these alternative areas of plant and agricultural
biotechnology. Additional public sector support may be required to develop
these areas of research.
Effects on other biotechnology sectors will largely be indirect
3.6.18 The other main areas where biotechnology has been applied are in
healthcare and in environmental and industrial processing. Healthcare ­
particularly drug discovery ­ is the dominant application of biotechnology, and
there are already some important and widely-used medicines derived from
GMOs, such as insulin.
3.6.19 The life science strategy that temporarily united pharmaceutical and
agricultural biotechnology companies has been largely abandoned. As the
situation currently stands, most of the links between the two sectors come in
terms of fundamental knowledge and supporting technology, such as the
modelling of biological systems.
3.6.20 Many aspects of the sectors are quite distinct. Separate regulations
often apply, although regulations on the release of GMOs will apply to GM
vaccines and GM bacteria for soil remediation as well as to GM crops.
Customers, markets and profit potential are markedly different in these
different areas; and public attitudes also differ between biotechnology
applications. Impacts from GM crop policy would therefore only be indirect.
3.6.21 Other industrial sectors may also be affected through the use of non-
food crops as replacements for petrochemicals as sources of raw materials.
These might include, for instance, the energy sector or the chemicals industry.
There are considerable uncertainties about the development of these areas,
and the role that GM might play in them. However, without GM methods, one
option for their development would be ruled out.
Signals about approaches to new technology are important
3.6.22 One wider influence of any decisions on GM crops will be the signal
they send about how the UK chooses to approach controversial new
technologies. The relative influence of public opinion, scientific advice,
industry, and NGOs is an important consideration for many future commercial
developments of biotechnology in its widest sense, as well as more generally.
Negative signals to GM crops would send a negative (or neutral) signal to
wider biotechnology and science, whilst a more positive approach to GM
crops would send a positive (or neutral) signal. Even fairly marginal effects
may still be important in the globally competitive market for biotechnology.
89
3.6.23 Potential students of biosciences may be affected by the signals given
out regarding GM crops. Since expanding UK biotechnology will require more
qualified personnel, encouraging or discouraging people to study relevant
subjects may have long term effects. However, evidence to date shows that
biosciences are very attractive to students: bioscience student numbers rose
50% between 1994/5 and 1999/2000.177
3.7 International impacts
Any action the UK takes will have international repercussions
3.7.1 The UK does not take decisions in isolation; it is embedded in an
international context that includes the European Union, international rules on
trade, multilateral environment agreements and links with trading partners and
other overseas bodies178
. The UK has legal obligations to some of these ­
such as the European Union (EU) and the World Trade Organisation (WTO) ­
and less formal relations with others.
3.7.2 In a globalising world, and with a technology as mobile as GM crops, the
actions taken by the UK will have repercussions at the international level. This
international influence will only be one factor in a complex global policy
environment, but will, nevertheless, form part of the overall impact of UK
action.
Some of these impacts will be direct, others indirect
3.7.3 Some of the influence will be direct, through the immediate impact of
policy decisions. These could include the effects of labelling food and feed
products on trade, legal implications of a decision to reject GM crops, or
influence derived from the type and effectiveness of the regulatory regime.
3.7.4 Other UK influences will arise indirectly from signals sent out on the
grounds of decisions and the process through which they arose. The role of
the public in "GM Nation? The Public Debate", for example, could provoke
similar processes elsewhere.
UK action will have an impact on the context in which developing
countries179
decide about GM crops
177
See the Industry and Science analysis paper, available on the project website.
178
See also Chapter 2.
179
The "developing countries" term includes all countries designated as such by DfID. These
are all the countries in Part I of the OECD Development Assistance Committee (DAC) eligible
to be in receipt of official development assistance (see Statistics on International
Development, DfID 2002).
90
Whether GM crops are "good" or "bad" for developing countries remains a
highly contested issue - this study does not make any assumption regarding
the impact
3.7.5 There is considerable debate about whether GM crops could have a
positive, mixed or negative impact in developing countries. On the one hand,
claims are made that GM crops hold the solution for world hunger through, for
instance, the creation of crops which are less sensitive to environmental
conditions such as drought. On the other hand there are claims that the
technology generates profits for large companies while failing to meet the
needs of impoverished farmers.
3.7.6 An initial overview of available evidence suggests that it is too early to
make firm conclusions, though it is possible to identify potential areas of
benefit as well as potential sources of costs180
. The impacts will be
heterogeneous and specific; GM crops are unlikely to be either a blanket
solution or an unequivocal failure. Like all technologies, they may contribute to
addressing certain problems, but could also exacerbate or create others.
UK action on GM crops is likely to impact on the context in which
developing country decisions are taken
3.7.7 UK Government policy states that developing countries should be able
to make their own choices about whether and how to use GM crops181
. These
choices will differ between countries and involve trade-offs and constraints.
3.7.8 UK action will almost certainly have some impact on the context in which
developing countries make these choices about GM crops. The nature of the
UK's impact will depend not only on the actual action taken by the UK, but
also on the grounds for that action and the process used. That said, the
impact is difficult to pin down empirically and will only be one of many sources
of influence.
UK impact could occur through three principal routes ­ trade, signalling
and technology transfer
3.7.9 What is clear is that UK impacts could occur through three principal
routes: trade, signalling and technology transfer182
. The fact that GM policy
and trade impact is mostly at the EU level means that this will be the main
route by which the UK has an impact. Signals could be generated by
unilateral action by the UK.
Trade matters most, though it is too soon to predict specific impacts
180
See the SU's Background Working Paper on developing countries (January 2003),
available on the project website, for details.
181
"Genetically modified organisms and developing countries", DfID (May 1999). The term
"developing country" includes countries such as Argentina, China and South Africa which
have already made decisions regarding GM crops. However, other developing countries
have made fewer or no choices at all.
182
Potential UK impact of GM crops on the decision-making contexts of developing countries:
Analysis paper (available on the project web site or on request from the SU) contains a full
analysis of each of these three routes
91
3.7.10 The potential impact of European GMO regulations on trade is
significant for developing countries. Current and potential regulations will
require importers of GM food and feed into the EU to have approval for the
GM variety or varieties and to meet standards of labelling and segregation.
3.7.11 This could increase the costs of exporting to the EU. It could also
prevent certain GM crops from being grown in developing countries if getting
approval, maintaining separation, and labelling the resulting GM products is
too costly or requires greater regulatory capacity than currently exists.
3.7.12 However, the actual regulatory impact will depend on the range of GM
crops available to developing countries183
, the nature of trade flows and the
practical implications of regulatory requirements. These would vary between
the scenarios set out in Chapter 4.
Signalling, though nebulous, is a significant source of influence
3.7.13 Anecdotal evidence suggests that actions and processes undertaken in
the UK could generate signals for developing countries. These signals could
come from a range of sources including government decisions, policy
processes and consumer demand.
3.7.14 The UK, in its role within Europe and its relationship with its major
trading partners, is a potentially important source of signals about a
controversial technology such as GM crops. Though their specific impact
cannot be predicted, the mechanism for influence remains important.
Technology transfer from the UK government will not be a major influence
3.7.15 The Government's impact on developing countries via GM crop-related
Official Development Assistance is not likely to be significant in the global
context. The Department for International Development (DFID) does not
currently prioritise GM crops and its impact in this area is small. Future
varieties of "pro-poor"184
tropical GM crops which are deliverable to the
poorest and developed using UK-based expertise could increase UK
government influence in this area. However, overall government impact looks
set to remain small unless the technology can be proven to address the needs
of the "poorest of the poor".
3.7.16 This study has not looked in detail at technology transfer from UK
public sector research establishments and private research. However,
technology transfer to developing countries from these sources could
significantly increase overall UK impact.
183
For example, there are few GM horticultural varieties at the moment, so direct trade
impacts on these exports are currently low or negligible.
184
"Pro-poor" technologies are those that address the specific needs of the poorest, such as
low input costs and availability in areas with weak physical infrastructure.
92
An explicit rejection of GM crops could cause tensions within Europe,
and with our other major trading partners
3.7.17 It is not within this project's scope to look in detail at how a decision to
reject wholesale the cultivation GM crops ­ either at UK or EU level ­ might
be effected in practice. However, it is important for this study to note that
taking such a decision would be far from clear-cut.
3.7.18 At the very least, there could be a messy stalemate; more likely, in the
long term, is that there would have to be a fundamental rethink of European
directives on GM. Either could cause serious international tensions if the
direction of policy was considered to inhibit trade.
3.7.19 Already, the EU's GM crops approvals process has caused tensions
with our trading partners, which culminated in the recent filing of a WTO case.
This case risks not only generating fresh antipathy over GM crops, but could
also have serious knock-on implications for trade relations and international
law more generally.
3.8 Applying the analysis to the scenarios
3.8.1 As the analysis of this chapter has shown, the impact of GM crops will
be felt across a range of areas. In most cases, it is not possible to say
whether this impact will be "positive" or "negative". In part, this is because of
the uncertainty which is inherent in any such forward-looking analysis ­ such
as gaps in scientific knowledge, and uncertainty over how various players will
behave. It is also clearly the case that an impact which, to one individual or
organisation, may be seen as a benefit, may be seen by others as a cost.
3.8.2 The following chapter applies this analysis to the five scenarios to
illustrate different possible futures for the UK with or without GM crops.
93
Chapter 4: Scenario analysis and conclusions
Summary
ˇ In response to future uncertainties and the limitations in the evidence
base, the SU has used a scenario analysis to look at different possible
futures for the UK with or without GM crops.
ˇ Scenarios allow consideration of a range of plausible possible futures.
They are not predictions, but they are useful in illustrating how costs and
benefits may vary in different futures for the UK with or without GM crops.
ˇ Five scenarios have been developed, including an explicit "no GM"
scenario. The scenarios use different assumptions about possible public
attitudes to GM and the nature of the regulatory regime as the main
determinants of different futures.
ˇ Unexpected events may throw these scenarios off course. These "shocks
and surprises" have a low or uncertain, and often contested, probability but
­ if they arose ­ they could have potentially high impacts. These impacts
could either support or damage the delivery of particular policy objectives.
ˇ The scenarios illustrate the trade-offs inherent in any future for the UK with
or without GM crops. They show that the nature of the regulatory system
will have an important bearing on our ability to deal with any risks to the
environment and human health, as well as on the impact of GM crop
cultivation on non-GM and organic farmers.
ˇ The scenarios also illustrate the central importance of public attitudes in
determining the impacts of GM crops. In the short term, negative
consumer attitudes can be expected to limit the demand for products
containing GM foods, and therefore the economic value of the current
generation of GM crops.
ˇ But there is significant potential for benefits from future developments in
GM crop technology, as well as the potential for impacts in wider science
and industry. The scenarios also demonstrate that international
implications could be significant.
This chapter sets out the Strategy Unit's scenario analysis and the project
conclusions. Section 4.1 describes the scenarios as five plausible futures for
the UK with or without GM crops, which build on the assessment of costs and
benefits in Chapter 3. The next section (4.2) explains the axes used for the
scenario analysis. It then sets out the five scenarios and the main costs,
benefits and trade-offs associated with each. Section 4.3 introduces the role
of shocks and surprises as potential disrupters of the scenario outcomes.
These high impact events that have a low or uncertain, and often contested,
likelihood could have positive or negative implications for policy objectives.
The chapter then ends with overall conclusions (section 4.4).
94
4.1 Introduction
The costs and benefits of GM crops have been developed into five plausible
scenarios
4.1.1 As the previous chapter demonstrates, there are a range of costs and
benefits that could be associated with growing, or not growing, GM crops in
the UK. These costs and benefits will have impacts in a very wide range of
areas. In many cases, it is not clear whether the impacts will be "positive" or
"negative". An impact which may be positive for one person or organisation,
may have negative consequences for another.
4.1.2 To take these issues into account in the study, the Strategy Unit has
developed a set of scenarios. Scenarios do not predict the future, nor do they
have probabilities attached to them. They are a means of identifying key
factors that could influence future developments, making assumptions about
how these might change and exploring the implications of these changes in
different possible futures.
4.1.3 As Chapter 1 explained, the nature of these scenarios was determined
by a stakeholder workshop. The two axes illustrate two key factors that
determine the impact of GM crop cultivation - public attitudes, and the nature
of the regulatory regime185
. A distinct fifth scenario looks at the possibility that
the UK may choose to reject GM crops outright.
4.1.4 These scenarios have been developed by applying the analysis of costs
and benefits set out in Chapter 3 to each of the five plausible futures. In
particular, the costs and benefits were assessed according to how they might
vary in each of the different scenarios.
4.1.5 The scenarios could potentially be disrupted by events with a low or
uncertain, and often contested, probability which ­ if they arose - could have a
high impact. These "shocks and surprises" could arise from external or GM-
related sources and could shift some or all of the scenario outcomes.
4.1.6 Overall, the scenarios illustrate the potential relative costs and benefits
of alternative futures for the UK, both with and without the commercialisation
of GM crops. We have based this scenario analysis on the information
contained in the analysis papers accompanying this report, as well as on
discussions with our Expert Advisory Groups and with other stakeholders.
185
Further details of the process to generate these axes are set out in the Overview
Methodology paper and the note of the SU "Scenarios workshop" held 2
nd
December 2002,
both found on the project website.
95
4.2 Scenario Analysis
The scenarios are driven by two key factors ­ public attitudes and regulations
4.2.1 The scenarios adopted in this study are illustrated in Figure 4.1, and
described below. They represent possible future outcomes which could occur
over 10 to 15 years.
Figure 4.1: Scenarios used in the Strategy Unit study
UK PUBLIC
ACCEPTS GM
UK PUBLIC
REJECTS GM
GM-SPECIFIC
REGULATIONS
NON-GM-SPECIFIC
REGULATIONS
Tangled
threads
Bare
minimum
Separate
weave
Part of the
fabric
Not made
in the UK
4.2.2 The vertical axis on regulations represents a range of possible
regulatory regimes. At the top are "Non-GM-specific regulations" which
describes a regime which treats GM crops and foods much like any other
novel crop or food. That is, subject to approval but not to a list of specific
regulations. At the bottom of the axis are "GM-specific regulations" which
describes a regime that could include an exhaustive approvals process and a
comprehensive regime for coexistence. Conditions for use would also be
attached to approvals of GM crops, such as ongoing monitoring.
4.2.3 The horizontal axis represents a range of public attitudes. Public
attitudes are complex and heterogeneous. They include, but are not
synonymous with, consumer attitudes, which are themselves highly varied.
This axis is a representation of broad shifts in public attitudes towards being
more positive or negative in respect of GM foods and crops. However, it is
assumed that public attitudes will continue to reflect a range of views.
4.2.4 The following pages contain the results of the scenario analysis. Each
scenario is described briefly in terms of its principal characteristics, which are
determined by the axes. This description is followed by an assessment of the
likely costs and benefits that could be expected to occur.
96
Scenario 1: Part of the fabric...
...explores the full potential - upside and downside ­ of GM crops
In this scenario, there is a growing level of public acceptance of GM foods.
Due to this general acceptance, GM ingredients become common in foods,
and consumers make less distinction between GM and non-GM.
In response, the regulatory regime around GM crops and foods becomes
more relaxed, treating them very much like any other novel foodstuff. There is
widespread commercial cultivation of GM crops across the UK and EU.
Globally, GM and non-GM crops are generally not segregated, although a
limited number of organic and non-GM product chains are maintained.
Developments in GM crop technology increase the range of products
available...
ˇ Faster technological development, stimulated by low levels of regulations,
would result in a greater potential for new GM crops.
ˇ The introduction of a range of new crops gives farmers a greater choice of
what to grow.
ˇ New commercial GM crops could have environmental benefits or
increased nutritional content. Non-food crops could include those that
produce renewable materials.
...and some positive economic impacts are likely for GM farmers,
processors and consumers
Scenario 4 Scenario 1
Scenario 2Scenario 3
"No GM"
Scenario 5
UK PUBLIC
REJECTS
GM
NON-GM-SPECIFIC
REGULATIONS
UK PUBLIC
ACCEPTS
GM
GM -SPECIFIC
REGULATIONS
97
ˇ There are likely to be cost savings from at least some of the new GM
crops, which would also be easily marketable.
ˇ New types of GM crop, especially non-food, could help some farmers to
diversify their business.
ˇ Consumers willing to consume GM food could benefit from lower prices, if
lower costs are passed through the supply chain. Consumers could also
benefit from a range of new products with longer shelf life and nutritional
enhancement.
ˇ With workable thresholds for adventitious presence, food manufacturers
and retailers may incorporate GM into their product chains with little
additional costs
The combination of consumer acceptance and a cheaper, less stringent
regulatory regime could benefit UK biotechnology ...
ˇ The UK GM crop development industry is boosted and public sector
research expands.
ˇ Overall, a positive signal is sent to the wider biotechnology sector.
ˇ Developing countries wishing to locally adapt GM crops could benefit from
the strong UK science base, to the extent that it contributes to "pro-poor"
crop development.
...and a very pro-GM message is sent to the rest of the world
ˇ There would be a strong positive signal from the UK Government and
consumers regarding the use and acceptance of GM crops.
ˇ Developing countries growing GM crops would have a market for their
exports and would not face additional costs because of few GM regulatory
requirements.
However, the rapid advances in technology with few GM-specific
regulations may carry a higher likelihood of adverse impacts...
ˇ Negative impacts could be more likely to arise from unexpected
environmental or human health effects because of the large range of GM
crops approved.
ˇ The relatively hands-off approach to regulation, including little or no
monitoring, means that it would be difficult to identify, attribute and
influence any impacts on the environment or human health, whether these
are positive or negative.
...and producers and consumers preferring non-GM products may feel
their choice is restricted
98
ˇ Conventional and organic farmers may find it difficult and costly to keep
GM material out, due to relatively low-key co-existence measures.
ˇ Consumers wishing to avoid GM products might choose to buy organic
products, to minimise the likely amount of GM presence, and could face
higher prices as a result.
ˇ Developing countries wishing to avoid GM imports may find this difficult
due to limited availability of segregated commodities.
Scenario 2: Separate weave...
...considers a future in which public confidence is restored
Under this scenario, GM crops are introduced gradually to the UK and the rest
of the EU, under a strict regulatory regime with an exhaustive approvals
process, conditions for use attached such as ongoing monitoring, and a clear
regime for co-existence. GM food is clearly labelled. Gradually, public
confidence and consumer acceptance of GM foods grows. Consumers are
particularly attracted to goods offering specific benefits, such as better flavour,
longer shelf-life or nutritional benefits ­ whether these be GM, non-GM or
organic.
Globally, the EU model is seen as successful and is used as a model for
some countries. Some non-GM supply chains are maintained as a result of
consumers' demand for choice.
Consumer and producer choice is supported by the regulatory
approach...
ˇ Labelling ensures consumer choice, and strict regulations create
consumer confidence in GM products.
Scenario 4 Scenario 1
Scenario 2Scenario 3
"No GM"
Scenario 5
NON-GM-SPECIFIC
REGULATIONS
GM-SPECIFIC
REGULATIONS
UK
PUBLIC
ACCEPTS
GM
UK
PUBLIC
REJECTS
GM
99
ˇ Farmers may choose between GM and non-GM crop varieties. Co-
existence measures aim to ensure that an acceptable level of adventitious
presence is reached.
ˇ Developing countries would be able to avoid GM imports if they wished,
because of some separation and labelling of GMOs in commodity markets.
...and the likelihood and impact of any adverse impacts is limited
ˇ The strict regulatory regime and focus on crops that do not outcross easily
reduces the likelihood of adverse impacts on the environment or health.
ˇ Monitoring of environmental and (to some extent) health impacts, plus
inspection to verify compliance with any consent conditions, means that
there is a strong ability to pick up any possible adverse impacts.
ˇ These impacts would be more easily attributed and dealt with given the
segregation of GM and non-GM products in the product chain.
Although a more careful regulatory regime would impose some
additional costs on the food chain...
ˇ GM crops may only prove to be economic for farmers who find existing
methods of weed and pest control difficult or expensive.
ˇ Costs would also be incurred in keeping a wide range of GM, non-GM and
organic produce separate at the farm level and through the product chain.
This could increase the overall cost of food if these costs are passed
through the product chain to the consumer.
ˇ Food and feed imports from developing countries would need to meet
segregation and labelling standards. This could mean some developing
countries forego benefits from certain GM crops if meeting these
standards is challenging or costly.
...as well as slowing technological developments to an extent
ˇ The regulatory approval process is relatively slow and costly, so GM crops
would be worth developing only if they had major markets, high added
value, or obvious agronomic benefits.
ˇ These crops would offer good opportunities for UK ag-biotech research.
Multinationals would have a significant role in bringing SME/PSRE
research to market.
ˇ The slow rate of development in the technology may mean that some
future benefits ­ such as environmental or human health benefits - are
foregone or delayed.
100
ˇ Fewer scientific developments in the UK may reduce the likelihood that
"pro-poor" GM crop varieties are created for developing countries wishing
to adapt them locally.
The nature of GM crop introduction means that potential environmental
benefits could be realised
ˇ Policy measures such as GM-specific agri-environment schemes or codes
of good practice encourage environmentally sensitive use of GM crops by
farmers, meaning that the potential positive impacts of changes to
chemical use are more likely to be realised, with less of the downsides
ˇ Such measures could also help other potential benefits to be realised,
such as reductions in tillage.
The signal from the UK would be positive and supportive of strong
regulations
ˇ The signal from the UK government and consumers would be positive
while emphasising the importance of effective regulations
Scenario 3: Bare minimum...
...sees a very low level of GM crop growing
This scenario assumes that a combination of strict regulation and negative
public attitudes results in the UK having very low levels of GM cultivation for
the foreseeable future. A rigorous approvals process ­ together with the
prospect of extensive post-market monitoring ­ make ag-biotech companies
reluctant to introduce crops. Farmers are wary of liability concerns and UK
supermarket demand for GM products is low. Most consumers are negative
towards the technology, preferring conventional or organic produce. However,
agronomic benefits may be appealing in feed and non-food markets, and a
small amount of GM crops may be both grown and imported for animal feed
and non-food uses.
Scenario 4 Scenario 1
Scenario 2Scenario 3
"No GM"
Scenario 5
NON-GM-SPECIFIC
REGULATIONS
GM-SPECIFIC
REGULATIONS
UK PUBLIC
REJECTS
GM
UK PUBLIC
ACCEPTS
GM
101
Globally, some segregated non-GM supply chains are established and some
countries avoid GM crop cultivation.
Regulatory costs would be incurred...
ˇ Regulations impose significant hurdles for GM crop commercialisation,
which discourages applications for new GM crops.
ˇ Costs of coexistence and segregation at the farm level discourage farmers
from growing GM crops and offset potential gains.
ˇ Food and feed imports from developing countries would need to meet
segregation and labelling standards. This potentially significant cost may
affect developing country decisions about whether GM crops are grown
and exported.
...and many GM crops would not reach commercialisation in the UK
ˇ Most consumers are not willing to buy GM food and the market for
produce is small. This means that potentially beneficial GM crops may not
reach the market.
ˇ Multinational research focus shifts further from the UK (and EU), and
research activity in the UK diminishes.
ˇ The potential use of GM crops as a tool to help reduce the use of
pesticides or other chemicals is largely rejected in the UK, meaning that
other measures have to be taken to achieve these objectives.
ˇ Slow scientific developments in the UK may reduce the likelihood that
"pro-poor" GM crop varieties would be developed for developing countries
wishing to adapt them locally.
ˇ The UK is on the "back-foot" when it comes to the exploitation and
development of GM crop technology.
But consumer choice would be maintained...
ˇ Labelling and segregation of GM from non-GM, including co-existence,
means that consumers can choose between organic, conventional and
(mainly imported) GM products.
ˇ Developing countries may be able to avoid GM imports if they wished,
because of some segregation and labelling of GMOs.
...non-GM crops may be boosted...
ˇ Crop development research shifts towards public sector dependence. With
adequate funds, some areas ­ such as organic and marker assisted
breeding ­ may be boosted.
102
ˇ Conventional crops and crop protection products continue to be developed
to meet world-wide demand for non-GM food. This will include the UK
market.
ˇ Some non-GM crops ­ particularly where price is largely determined by
the UK market - are available without much of a price premium, because
of the relatively small amount of GM crop production in the UK.
...and the likelihood of negative impacts is reduced
ˇ As few GM crops are grown or food consumed, there is limited potential
for negative impacts from GM sources.
ˇ Post-market monitoring means that any problems are more likely to be
picked up and attributed.
Internationally, the messages sent would be mixed
ˇ There would be mixed signals from the UK, with the signal from
Government being that GM crops can be grown but only subject to
regulatory approval; while the signal from UK consumers is negative.
Scenario 4: Tangled threads...
...looks at a failure of regulatory policy to meet public expectations
In this scenario, there is a discontinuity between public attitudes and
regulatory policy. EU regulations on GM crops and food prove to be
expensive or unworkable in practice. UK public and consumer attitudes are
generally against GM crops, but exporting countries may find it difficult to
comply with EU thresholds for adventitious presence.
Over time, the regulatory approach changes to improve its workability, but
consumer attitudes remain generally unsupportive of the technology. This
means that many consumers are demanding GM-free products which the
Scenario 4 Scenario 1
Scenario 2Scenario 3
"No GM"
Scenario 5
NON-GM-SPECIFIC
REGULATIONS
GM-SPECIFIC
REGULATIONS
UK PUBLIC
REJECTS
GM
UK PUBLIC
ACCEPTS
GM
103
regulatory regime is struggling to deliver. There is some demand for certain
GM products, including non-food crops, and UK farmers limit their growing of
GM crops to meet this limited domestic as well as export demand.
Globally, problems with the EU model discourage other countries from having
a GMO-specific regulatory regime.
Uncertainty over the regulations and acceptance of GM confuses
industry, producers and farmers alike...
ˇ Regulatory processes have been reduced in scope, but research, trials
and products are unpopular. There is little incentive to develop GM crops
for the UK.
ˇ In view of a weak regulatory environment, some farmers wishing to sell
identity-preserved conventional and organic crops could be faced with
additional costs due to effects from their neighbours growing GM crops.
This could contribute to tensions within rural communities.
ˇ It may be difficult for developing countries to choose to avoid GM imports if
they wish, due to low levels of separation and labelling of GMOs.
ˇ Developing countries wishing to export GM food and feed products would
have relatively few regulatory requirements to meet for entry to the UK
market, but there would be little consumer demand.
...leading to dissatisfaction among consumers...
ˇ There is demand for non-GM produce but a blurring between GM and non-
GM sources. Any non-GM products that can maintain a low adventitious
presence of GM will be boosted.
ˇ Organic and conventional farmers could bear costs to maintain their non-
GM status, depending on how liability is dealt with. These costs would
need to be passed onto consumers as a "purity premium" which may be
easier for organic than conventional products.
ˇ GM crops are unpopular, but can be grown and protests against GM crops
and trials are common. Consumer choice is seriously affected and public
trust in regulatory authorities is diminished.
...and a poor ability to deal with adverse impacts...
ˇ Low levels of monitoring mean that if problems are caused by GM crops,
they may take some time to be noticed.
ˇ The lack of segregation between product chains means that attributing the
impacts will be difficult.
The overall outcome is messy, with benefits for some but problems as
well...
104
ˇ High demand for organic produce means that the organic sector grows
more quickly than is currently envisaged; chemical use falls, and there is a
possible increase in the diversity of rural environments.
ˇ There is less overall capacity for the UK to benefit from any positive GM
crop developments such as new developments in environmentally or
health-beneficial GM crops. However, there could be developments in
non-GM techniques.
ˇ Regulatory confusion and consumer pressure for choice generates costs
for food manufacturers and retailers.
ˇ The slowing in scientific developments may reduce the likelihood that "pro-
poor" GM crop varieties would be created for developing countries wishing
to adapt them locally.
ˇ Developing countries could specialise in organic exports, but this may
involve foregoing certain GM crop benefits if segregation is difficult.
...and the rest of the world views developments with some alarm
ˇ There would be conflicting and messy signals from the UK. The regulatory
approach, once adjusted, could send a positive message about the
technology, but there would be a negative signal about GM crops from
consumers.
Scenario 5: Not made in the UK...
...considers the case where no GM crops are grown
This scenario is based around an explicit policy against the commercial
cultivation of GM crops. It shares many similarities with Scenario 3, but the
explicit decision precludes any GM crops from being grown on a commercial
basis, and sends a clearer and firmer signal about attitudes to GM crops. At
the same time, there is no need to design and introduce rules for coexistence,
Scenario 4 Scenario 1
Scenario 2Scenario 3
"No GM"
Scenario 5
NON-GM-SPECIFIC
REGULATIONS
GM-SPECIFIC
REGULATIONS
UK PUBLIC
ACCEPTS
GM
UK PUBLIC
REJECTS
GM
105
insurance, etc. Most consumers are against the technology, preferring
conventional or organic produce, and therefore retailers continue to demand
non-GM products. However, a minority are not put off by GM foods, and there
is a small import market for GM foods.
Globally, some segregated non-GM supply chains are established and some
countries avoid GM crop cultivation.
An explicit no-GM policy has international implications...
ˇ The UK signal about GM crops would be strongly negative from both
Government and consumers.
ˇ The policy decision could be difficult to achieve and the route by which it
could be made is not clear cut. It would also generate trade-related
tensions.
...and there is a reduction in the types of crops available to producers
and consumers
ˇ Farmers could be faced with increasing competitive pressure from GM
production elsewhere, particularly in the export market.
ˇ The potential use of GM crops as a tool to help reduce the use of
pesticides or other chemicals is lost to the UK, meaning that other
measures have to be taken to achieve these objectives.
ˇ The UK is reliant on non-GM methods for producing non-food crops such
as energy crops, and so could forego some benefits. More generally, using
GM crops to meet policy objectives would not be an option.
ˇ Consumers and other groups, such as livestock farmers, who wished to
buy GM products, would rely on imported products. Some supermarkets
may not stock GM products.
ˇ Developing country exporters of GM crops would have little UK demand
coupled with significant regulatory hurdles. This could mean they avoid
exporting to the UK or specialise in non-GM products for the UK market.
The latter may involve foregoing certain benefits from some GM crops if
segregation is costly or challenging.
...as well as limiting options in the ag-biotech industry...
ˇ There would be no point developing any GM crop, including niche GM
varieties, for UK markets.
ˇ There are also negative signals sent to the wider biotechnology science
base, the nature of which will depend upon the basis for the decision to
rule out GM crops.
106
ˇ The slowing in scientific developments could reduce the likelihood that
"pro-poor" GM crop varieties would be developed for developing countries
wishing to adapt them locally.
Some, but by no means all, of the costs of regulation are avoided
ˇ There is no need to design or implement a coexistence or monitoring
regime. However, regulation would still be required to deal with imports of
GM products including costs of segregation through the product chain
which include testing and labelling.
...and consumers and producers wishing to avoid GM food can do so
ˇ As no GM crops are grown in the UK, and all GM imports must be labelled
as such, it is possible for producers and consumers who wish to avoid GM
products to do so.
Risk of adverse effects is reduced...
ˇ GM crops are not grown and there is little consumption of GM food, so
there is very limited potential for adverse impacts from this source.
ˇ Any negative impacts could be relatively easily detected and attributed to
the small number of imported GM products.
...and the UK could see benefits from having a "GM free" environment
ˇ As a "GM-free zone" the UK could benefit from a reputation for an
environment that does not contain GM crops.
ˇ The UK could develop niche non-GM products for domestic and
international markets.
Summary of scenario analysis
The scenarios highlight the importance of trade-offs and the weighting of
different costs and benefits
4.2.5 These scenario outcomes are based on the SU's assessment of costs
and benefits and represent a range of possible futures related to GM crop
cultivation in the UK. They highlight the importance of trade-offs in decisions
about GM crop cultivation, and how different groups and individuals will be
affected differently by a variety of future paths.
4.2.6 Although the scenario outcomes set out possible futures, no
assessment has been made of the likelihood of a particular scenario
occurring, or which possible future is better than any other. Value judgements
and "weighting" of different factors will be required to assess how costs and
benefits should be traded off against one another.
107
Levels of trust in the UK may affect how the scenarios pan out...
4.2.7 The scenarios will be sensitive to levels of trust in institutions and
regulations. The outcome of the scenarios could be affected by the degree to
which different groups in society trust the basis and implementation of the
regulatory framework. A regulatory framework that does not command
widespread trust may shift the costs and benefits associated with that
scenario.
...as well as global developments
4.2.8 International developments will also affect the outcome of the scenarios.
For instance, scenarios with very limited growing or consumption of GM crops
may be harder to sustain if the majority of countries in the rest of the world
decide to use GM crops. Conversely, should there be a slowing or reversal in
GM crop uptake globally, then a UK future with widespread GM crop growing
could be problematic in the long term.
Liability could affect the distribution of costs and benefits in the scenarios
4.2.9 The nature of liability for economic or environmental damage will play an
important role in the distribution of costs and benefits in scenarios where GM
crops are grown in the UK. This issue will be considered in the AEBC's
forthcoming report on coexistence and liability.
4.3 Potential disrupters ­ the impact of shocks and surprises
The scenarios could potentially be disrupted by events with a low or uncertain,
and often contested, likelihood that could have a high impact ­ either positive
or negative
4.3.1 The scenarios are built on the assessment of costs and benefits set out
in Chapter 3. This analysis reflects the SU's understanding of the range of
costs and benefits that could arise under conditions that look broadly as they
do today. The scenarios are plausible, therefore, in the sense that they could
occur without having to rely on unlikely events.
4.3.2 However, when looking forward over 10 to 15 years it is impossible to
rule out that such events could occur. These events could have a low or
uncertain, and often contested, likelihood of occurring, but a high impact if
they do happen. To address this source of change and uncertainty, the SU
has introduced the tool of "shocks and surprises".
Shocks and surprises have a low or uncertain probability but could have
important implications
4.3.3 Shocks and surprises are events which are perceived to have a low or
uncertain probability of occurring; and their likelihood may be disputed among
different groups of stakeholders. Events which, to some, are highly unlikely or
108
even impossible, are deemed probable, or even expected, by others. And the
shock or surprise itself could have a range of different impacts or be subject to
different interpretations.
4.3.4 They are events that have the potential to disrupt the scenarios and
change their outcome ­ in ways that may be generally supportive of, or
damaging to, policy objectives.
Shocks and surprises could be "internal" or "external"
4.3.5 Shocks and surprises can be classed as "external" or "internal". External
shocks and surprises arise from events outside of GM crops; internal shocks
and surprises are generated from GM crop-related sources. This distinction
will be explored more fully below and discussed with reference to how they
could impact on the scenario analysis.
They can be discussed in illustrative terms only
4.3.6 However, by their very nature, shocks and surprises cannot be predicted
- they can only be discussed in terms of what could happen, not what will
happen. All examples and discussion of shocks and surprises are therefore
illustrative only.
External shocks and surprises ­ changes in the outside world
4.3.7 The SU's basic analysis assumes that the "outside world" ­ everything
other than GM crop-related issues ­ looks broadly as it does today. This may
be the case. But equally "outside world" conditions could change markedly
from current circumstances.
4.3.8 It is important to consider how external shocks and surprises could
disrupt the context in which GM crops are, or are not, grown. These shocks
have no direct link to GM issues, but they could affect the impact of GM crops.
4.3.9 Some illustrative examples of external shocks and surprises are given
below:
ˇ Health ­ a food scare in another type of agriculture could change
perceptions about the safety of GM crops;
ˇ Environment ­ climate change could alter the types of pests found in the
UK, and therefore the type of pest strategies needed in UK agriculture;
ˇ Political / economic ­ an oil price shock could change the economics of
energy crops;
ˇ Innovation ­ a breakthrough in genomics could change the economics of
GM technology.
The impacts of external shocks and surprises on GM crops...
4.3.10 All of these external shocks and surprises would alter the context in
which GM crops operate; for example:
109
ˇ External shocks and surprises would alter the policy context in which GM
crops occur. Changes to this context could generate new goals and
objectives which GM crops could be in a strong, or weak, position to meet.
ˇ External shocks and surprises could also generate new drivers for GM
crop decisions, making GM crops more attractive.
ˇ Trust in key institutions would also be affected by external shocks and
surprises. The way an external event was dealt with by an institution could
affect public trust, which could indirectly affect perceptions of GM crops.
ˇ External shocks and surprises could also be amplified by GM crop issues.
For example, pre-existing concerns about GM crops could exaggerate the
reaction to health issues in another area of agriculture.186
ˇ GM crops could also be a lightning rod for external shocks and surprises.
A shock that is unrelated to GM crops could increase or reduce public
concern about GM crops.
4.3.11 Box 4.1 below highlights an illustrative external shock that was
generated independently by stakeholders for the SU's Seminar on Shocks
and Surprises187
. It is discussed with reference to its potential impact across
the scenarios.
Box 4.1: Stakeholder-generated external shock or surprise
This political "shock or surprise" is discussed for illustration only
Nature and impact of the event
Anti-globalisation and xenophobia combine to promote a new localism. At the
same time, radical environmentalism develops out of a series of eco-
disasters. These two forces lead to authoritarian radical environmental
political forces operating at a regional level. The result is a set of strong,
regional political units with independent approaches to GM crops. Some
areas instigate full bans, while others introduce strict regulations. Border
conflicts flare up between different jurisdictions.
Implications of the event across the scenarios
Overall, this event would cause a shift along the regulatory axis towards the
GMO-specific end. The event would also change the public attitudes axis by
shifting "average" attitudes towards the negative end of the spectrum. The
event could make scenarios 1 and 2, with positive public attitudes,
186
Likewise, pre-existing concerns about GM technology could amplify concern about a GM-
related shock. A recent report from the Pew Initiative on Food and Biotechnology and the
John F. Kennedy School of Government, "When Media, Science and Public Policy Collide",
indicates that media coverage during the Starlink case seemed to convey the message that
contamination by a transgenic strain was more likely to cause an allergic reaction than that by
a conventional crop. In practice, this is not necessarily the case; the report states, for
example, that contamination by ordinary peanuts would have been more serious.
187
Further details are set out in the note of this seminar, available on the project website.
110
unsustainable in the long term. It would have less overall impact on scenarios
3, 4 and 5 because the public is already negative towards GM crops, and
would be less disrupted by more restrictive policies on the technology.
External shocks and surprises across the scenarios...
4.3.12 By definition, external shocks or surprises do not have any direct
relationship with GM issues, but by changing the context in which GM crops
occur, they will shift GM crop-related outcomes in various ways. Overall,
external shocks and surprises do not appear to impact across the scenarios in
a systematic way. However, an external shock or surprise could make a
scenario unsustainable over the long term. It could also affect non-GM crop
outcomes.
Internal shocks and surprises ­ GM crops as the source
4.3.13 Internal shocks and surprises are generated from GM crop-related
sources. They are therefore related to how, and to what extent, GM crops and
foods are developed and used.
Internal shocks and surprises could have positive or negative policy impacts
4.3.14 An internal shock or surprise could support policy objectives. If there
was an unexpectedly early or completely unanticipated breakthrough in the
development of a particular GM crop variety, for example, this could assist
certain agricultural policy objectives to be met. A drought resistant GM crop
variety developed earlier than expected would constitute an internal shock.
4.3.15 An internal shock could also be generated by an unexpected shift in
innovation that changes the principles of GM crop development. This could
make the creation of GM crops easier or quicker, generating new benefits and
reducing some costs. The development of alternatives to GM crops could also
undergo an unexpected shift that affects their contribution to agriculture.
4.3.16 An internal shock or surprise could also damage policy objectives. The
likelihood of a negative internal shock occurring will depend upon the nature
and effectiveness of the regulatory regime, as well as the range of crops and
traits that are approved. The impact of any such shock will depend, in part,
on whether or not it is reversible, and at what cost.
The current regulatory regime aims to minimise negative shocks
4.3.17 As Box 4.2 below shows, current European risk assessment
procedures are detailed and take into account potential shocks from direct or
indirect effects of GM crops.
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Box 4.2: GM crop risk assessment in place
All GM crops undergo a risk assessment for their impacts on human health
and the environment. The risk assessment process is specific to the GM crop
being considered and contains a range of scientific information, including:
ˇ potential cumulative long-term effects associated with the interaction of the
GM crop with other GMOs, the ecosystem where it would normally be
grown and the environment more widely;
ˇ any toxic, allergenic or other harmful effects on human or animal health;
ˇ description of monitoring plans to trace and identify any direct or indirect,
immediate, delayed or unforeseen effects on human health or the
environment of GMOs after they have been placed on the market;
ˇ measures to minimise or prevent the dispersal of reproductive material
from the plant to neighbouring species that are sexually compatible;
ˇ emergency plans should any unexpected events occur.
The 2001/18/EC Directive provides for:
ˇ detailed assessment by the lead member states expert advisers;
ˇ detailed scrutiny by the expert advisers of the other 14 member states
during EU decision making and by the European commission's Scientific
Committee on Plants;
ˇ EU wide public consultation.
The Directive also provides for the possibility that new evidence may come to
light in future that could change the basis of the risk assessment. If new
information on risk becomes available (i.e. from monitoring or elsewhere)
which casts doubt on a risk assessment, the Directive provides a means by
which consents can be varied or revoked.
4.3.18 However, for the purposes of the scenario analysis, it is important to
consider different regulatory approaches and their capacity to prevent and
deal with negative internal shocks.
4.3.19 With any regulatory system there are tradeoffs between its ability to
prevent negative shocks versus its financial cost. If the regulatory regime is
as exhaustive as possible, it may be more effective at picking up risks, but at
a high financial cost. At the other extreme, a laissez-faire approach to
regulation could allow some potentially serious risks to go unnoticed.
However, shocks and surprises are - by definition - unexpected
4.3.20 Whichever approach is taken, an effective regulatory regime would
minimise the chances of any adverse impacts occurring. However, regulations
themselves cannot guarantee that such impacts will not arise for two main
reasons:
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ˇ Regulatory regimes focus on known and foreseen risks. It is difficult to
deal with hazards that are presently unknown, although monitoring would
increase the likelihood that any of these adverse shocks are detected.
ˇ For regulatory regimes to operate effectively, they rely on compliant
behaviour from all actors involved. Unexpected impacts may occur if
regulations, or conditions attached to regulatory consents, are not fully
followed.
4.3.21 For these reasons, the impact of a negative internal shock or surprise
is not necessarily the sign of regulatory "failure". It could be the result of
where the line was drawn between cost and effectiveness, how regulations
were complied with, what information was available at the time and which
shock or surprise actually occurred.
4.3.22 Some illustrative examples of internal shocks and surprises are given
below:
ˇ Health ­ a completely new toxin could be identified for which a number of
GM crops, even those already with approval, must be tested.
ˇ Environment ­ greater scientific understanding of ecosystems identifies a
new environmental impact of GM crops that has not been taken into
account by current regulations.
ˇ Political / economic ­ research into GM crops becomes less expensive,
more quickly than expected, which changes the structure of the ag-biotech
sector.
ˇ Innovation ­ there is a breakthrough in key traits that enable the
development of nitrogen fixation using GM and a subsequent reduction in
the use of fertilisers, with associated environmental benefits.
The impacts of internal shocks and surprises on GM crops and food...
4.3.23 In a similar fashion to external shocks and surprises, these internal
shocks and surprises share a number of features which will affect GM crops
and foods:
ˇ Internal shocks or surprises could generate possible ramifications
beyond the immediate issues that also affect GM. For example, concerns
about unlabelled GM soya ingredients contributed indirectly to labelled GM
tomato paste being removed from UK supermarkets in the late 1990's.
ˇ The way that key institutions - such as Government and the media ­ react
to an internal shock or surprise will affect its overall impact. This could
either increase or reduce support for GM crops.
4.3.24 Box 4.3 highlights an illustrative internal shock or surprise generated
independently by stakeholders for the SU Seminar on Shocks and Surprises.
It is discussed with reference to its potential impact across the scenarios.
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Box 4.3: Stakeholder-generated internal shock
This health shock or surprise is discussed for illustration only
Nature and impact of the event
A pattern of illnesses are attributed to an allergic reaction from food
consumption. There is a possibility that the allergic reaction may be linked to a
protein giving insect-resistance, which is used in a range of GM crops. The
impact of this shock will depend upon whether the pattern is linked to GM
crops or not. However the official reaction to the shock and how it is dealt with
will also determine the impact. Any negative public association between the
shock and GM crops may persist even if the scientific evidence proves there
is no connection.
Implications of the event across the scenarios
If this shock occurred and was proved to be GM-related, it would be harder to
deal with in scenarios 1 and 4 because of the relatively weak labelling and
segregation between GM and non-GM, and because of reduced monitoring.
This shock would be easier to deal with in scenarios 2, 3 and 5 because of the
more extensive regulatory regime. In 3 and 5 only a small amount of imported
GM food would need to be tested.
Internal shocks and surprises across the scenarios...
4.3.25 There is likely to be a large variation in how internal shocks and
surprises impact across the scenarios. This is due to the link between the
likelihood of the GM-related shock or surprise occurring and the extent of GM
crop cultivation and consumption in different scenarios.
Conclusions on the impact of shocks and surprises
4.3.26 A particular pattern emerges with respect to internal shocks and
surprises. There is a key trade off between the susceptibility of the scenario
to negative internal events and ability for the scenario to benefit from positive
internal shocks or surprises.
ˇ High impact from internal shocks and surprises: a scenario able to
capitalise on positive internal shocks or surprises will also be more
vulnerable to negative internal shocks. For example, in scenario 1 a
breakthrough in GM crop technology could be quickly developed and
used. But it would also be more difficult in this scenario to deal with an
unexpected environmental issue from GM crops.
ˇ Low impact from internal shocks and surprises: a scenario that is
relatively resilient to negative shocks will have less potential to benefit
from positive shocks. For example, in scenario 3 there would be relatively
few sources of internal negative shocks because of the small amount of
GM crop and food used. However, at the same time, the slowing in
scientific developments means that it is less likely that benefits could come
from a positive GM development such as a new trait.
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4.3.27 The impact of external shocks and surprises will depend more upon
the event itself than the scenario, although their impacts will differ across
scenarios.
4.3.28 Overall, this section demonstrates the importance of taking the impact
of shocks and surprises into account when assessing the overall implications
of each scenario. The costs and benefits from the basic SU analysis could be
significantly disrupted ­ in a direction that supports or damages policy
objectives ­ from the occurrence of shocks and surprises.
4.4 Overall conclusions
The scenarios illustrate the trade-offs inherent in any future for the UK, with or
without GM crops
4.4.1 None of the scenarios are universally good or bad. Instead, they all
represent trade-offs between costs in one area and benefits in another.
Different individuals will have different views on the desirability of each
scenario outcome. Value judgements and "weighting" of different factors will
therefore be required to assess how costs and benefits should be traded off
against one another.
4.4.2 The Government is particularly interested in whether GM crops can help
to achieve policy objectives. The analysis shows that different objectives may
be supported more or less in different scenarios.
The scenario outcomes could be shifted by interactions between
policies and attitudes
4.4.3 The scenario outcomes could be shifted by interactions between
different factors. Dynamic relationships between, for example, regulatory
policy, public attitudes and global developments, could affect the overall
outcome in any scenario. These interactions are unpredictable, and the
uncertainty surrounding their potential impacts should be noted when
assessing the overall conclusions to this study.
The scenarios show that the nature of the regulatory system will have an
important bearing on our ability to deal with any risks to the
environment and human health...
4.4.4 The current EU regulatory system has been designed to limit adverse
effects as far as possible ­ and as the regulatory system evolves over time, it
will continue to retain this aim. But no procedures can be 100% effective, and
there will always be the possibility ­ however small, or disputed ­ that some
unforeseen (and possibly unforeseeable) adverse impacts to the environment
or human health may occur, particularly in the longer-term. The potential
irreversibility of some of these impacts also has to be taken into account when
considering this possibility.
115
4.4.5 In light of this, a key trade-off will be between the costs and burden of
regulation, and its effectiveness in anticipating and handling risk. A regulatory
system which required large amounts of information, such as many years'
worth of testing, might be more effective in anticipating problems or in dealing
with unexpected events should they arise. But it could also be expensive and
may discourage biotechnology firms from developing potentially valuable new
crops in the UK.
...as well as on the impact of GM crop cultivation on non-GM and organic
farmers
4.4.6 The nature of the rules on the growing of GM crops will determine how
effectively they can be kept separate from non-GM crops at the farm level,
and to what extent non-GM and organic farmers may have to incur costs
themselves in ensuring the integrity of their products. Whether they could
pass on any such costs would depend on the relative demand for their goods,
which would be higher in scenarios where the public has negative views about
GM produce.
They also illustrate the central importance of public attitudes in determining
the impacts of GM crops
4.4.7 Consumer attitudes are a very important determinant of the impact of
GM crops. In scenarios with negative attitudes, there is only a limited market
for GM crops, and hence low take-up. Attitudes are complex and
heterogeneous, and may vary between different uses of GM crops ­ the use
of crops for industrial purposes or animal feed, for instance, might prove to be
more acceptable than their use in food.
In the short term, negative consumer attitudes can be expected to limit the
demand for products containing GM foods, and therefore the economic value
of the current generation of GM crops
4.4.8 Applying this to the current situation in the UK means that if consumer
attitudes towards GM foods are negative in the short term, then any net cost
and/or convenience savings associated with the current generation of GM
crops would be likely to be outweighed by the lack of a market, limiting their
economic value. Interest from farmers may be limited to goods destined for
export markets, for the production of animal feed.
But there is significant potential for benefits from future developments
in GM crop technology...
4.4.9 The availability of GM crop technology may help in the development of
new and potentially beneficial crops in the future, such as those with
particularly useful agronomic traits which make agricultural production easier
or cheaper. These traits may be important in maintaining competitiveness in
internationally-traded commodities. GM crop technology may also help the
development of products with health or consumer benefits. And the potential
for GM crops to be used in the production of a range of non-food products,
116
such as renewable materials or pharmaceuticals, could provide benefits
outside the farming and food industry.
4.4.10 However, this potential needs to be balanced against the possibility
that new GM crops could introduce new risks. Much would depend on the
ability of the regulatory system to keep up with the technology in the future,
and to anticipate and manage risks and people's concerns effectively.
...as well as the potential for impacts on wider science and industry
4.4.11 GM crop policy may also have wider impacts on UK science and
industry. The UK has a leading position in biotechnology in Europe. The UK
also has a global reputation for wider scientific excellence, and science-based
industries as a whole make an important contribution to national output. This
contribution, and its future expansion, is likely to be affected if changes in GM
crop policy send signals, either positive or negative, about the UK's attitude to
biotechnology, science and industry.
The scenarios demonstrate that international implications could be significant
4.4.12 The scenarios show that the global impact of UK or EU GM policy
should not be underestimated. The ability of developing countries to choose
whether or not to adopt GM crop technology may be affected by
considerations about the possible impact on exports to the EU. And taking a
significantly different policy direction from other countries could cause serious
trade tensions.
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Chapter 5: Next steps
Summary
ˇ This SU study has to be considered in the context of the work that is
currently being carried out by the Science Review and by "GM Nation?
The Public Debate".
ˇ The final reports of the three strands of the overall GM Dialogue are
intended to support the Government in making forthcoming decisions
about the commercial development of current generations of GM crops in
the UK, as well as to inform GM policy making in the longer term.
ˇ This study has highlighted some interesting areas of research which,
although not directly related to decisions about the commercial
development of current generations of GM crops in the UK, may provide
fruitful areas for further research in the future.
ˇ In the longer term, the availability of more information will enable some key
issues to be looked at in more depth.
ˇ The report is published for comment ­ responses should be sent to the
Strategy Unit by Friday, 17th
October 2003.
The analysis presented in chapter 4 represents a first attempt at drawing out
the potential economic implications of various GM and non-GM scenarios.
This chapter outlines the scope for further analytical work in this field as well
as the next steps following the SU's GM crops project.
5.1 Recommendations for further analytical work
5.1.1 This SU study has to be considered in the context of the work that is
currently being carried out by the Science Review and by "GM Nation? The
Public Debate":
ˇ Final outputs from the Science Review will add to some of the areas of
analysis in this study, in particular the work on costs and benefits
associated with environmental and human health impacts. For example,
the Science Review may make it possible to draw clearer conclusions
about costs of monitoring, clear-up and remediation, and about the trade-
offs between costs of regulation and the likelihood of "shocks" arising.
ˇ The conclusions of the Public Debate will expose those areas that are of
particular concern to the public, and this may warrant further analysis in
some areas. It will also provide valuable information on the likely reactions
of consumers in the event of different scenarios ­ or "shocks" ­ arising,
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which will in turn inform analysis of the costs and benefits that are likely to
occur.
5.1.2 The final reports of the three strands of the overall GM Dialogue are
intended to support the Government in making forthcoming decisions
about the commercial development of current generations of GM crops
in the UK, as well as to inform GM policy making in the longer term.
This study has highlighted some interesting areas for further research
5.1.3 The remit of the SU study has necessarily been focused on supporting
Government in its decision-making. However, the study has also touched on
some other interesting issues, which - although not directly relevant to
decisions about the commercial development of current generations of GM
crops in the UK - may provide fruitful areas for further research in the
future.
5.1.4 The first area of potential research would be to build a stronger evidence
base on alternatives to the commercial cultivation of GM crops ­ such as
organic farming, conventional farm management and the use (in plant
breeding) of genomic techniques not involving genetic modification. This study
has made a preliminary attempt to assess the merits of these alternative
approaches, because they provide a benchmark against which the costs and
benefits of GM crops may be assessed ­ without such a benchmark, any
analysis would have been meaningless. However, there are no comparable
studies on the costs and benefits of these alternatives, and this has raised
considerable difficulties. It should be possible to draw on work carried out to
inform DEFRA's "Strategy for Sustainable Farming and Food"188
, and also the
"organic action plan"189
, as well as similar initiatives in the Devolved
Administrations190
. The aim would be to assess the way in which these
alternatives to GM could contribute to the goals of agricultural policy.
5.1.5 The second area of potential research would build on the outputs of "GM
Nation? The Public Debate" by assessing in more detail the sociology of
attitudes to GM crops and foods, and other examples of the commercial
application of new technologies. This could include an assessment of how
attitudes evolve and how they impact on decision-makers.
5.1.6 The final area of potential research relates to the costs and benefits of
GM crops in developing countries. The "Developing country background
working paper: Potential UK impact on developing countries", published as
part of this study, included a very broad overview of the costs and benefits
188
DEFRA (December 2002) "Strategy for Sustainable Farming and Food - Facing the
Future", available at http://www.defra.gov.uk/farm/sustain/newstrategy/index.htm.
189
DEFRA (July 2002) "Action Plan to Develop Organic Food and Farming in England",
available at http://www.defra.gov.uk/farm/organic/actionplan/index.htm. The Scottish
Executive Organic Action Plan is at http://www.scotland.gov.uk/library5/agri/orap-00.asp.
190
In Scotland, the Scottish Executive has published "A Forward Strategy for Scottish
Agriculture" (2001), available from http://www.scotland.gov.uk. In Wales, agriculture is a key
element of the "Rural Development Plan for Wales 2000-2006" (2001), available from
http://www.wales.gov.uk. In Northern Ireland, a vision for the future of the agri-food sector is
described at http://www.dardni.gov.uk/.
119
associated with GM crops in developing countries.191
But there was no
intention to carry out a "cost-benefit analysis" of GM crops in developing
countries, and the Strategy Unit's assessment was by no means
comprehensive. And although this report, and the associated analysis paper,
have considered the way in which UK decisions may impact on decisions
taken in developing countries, the complexity of the interactions, the inherent
uncertainties, the very wide varieties of potential applications, and the
significant differences between developing countries have all made it difficult
to draw firm conclusions.
5.1.7 Of course, the quality and quantity of information on GM crops ­ and
alternative approaches ­ in developing countries is even more limited than in
relation to developed countries. On the other hand, many developing
countries are facing difficult decisions about GM crops and foods, and might
well be willing partners in work to provide better information.
5.1.8 What this suggests is that any further work ­ perhaps involving (or even
sponsored by) DFID ­ should not take the form of a "root-and-branch"
analysis. Instead, it should look to sound out with developing countries and
international agencies the merits of work to improve understanding of the
possible contribution that GM crops ­ and equally of alternative approaches ­
may make to agricultural development objectives in these developing
countries. It would be important to focus on the objectives, and to consider
GM crops as one possible solution ­ rather than to consider GM crops in
isolation. This should help to ensure that decisions on funding192
and on
agricultural practice are tailored more closely to developing country needs.
In the longer term, the availability of more information will enable some key
issues to be looked at in more depth
5.1.9 In addition, as further information (see section 3.2) becomes available,
the analysis presented in this report should be kept under review. Particular
areas of analysis that could be revisited in the light of further information
are:
ˇ The costs of regulatory activities, such as traceability and labelling;
monitoring of impacts; and policing of rules for coexistence. What is the
magnitude of these costs? To what extent do they vary according to the
area and range of GM crops grown? Who bears the costs? What is the
impact on the prices and choice faced by consumers?
ˇ Progress in crop development R&D relative to expectations, including both
GM and non-GM techniques. What GM traits are being brought to market,
and in which crops? What attributes are being developed through non-GM
techniques? How do the costs, timescales and scope compare?
ˇ Patterns of demand for products from GM crops. Are consumer attitudes
stable or volatile? What are the distinctions between different types of
191
The background working paper is available on the project website.
192
See, for example, section 2.1 of the Developing Countries Analysis Paper, available on the
project website.
120
product (e.g. food versus non-food)? What is impacting on these attitudes?
How important does price seem to be?
5.2 What happens next?
5.2.1 As the Department with lead policy responsibility for GM crops, DEFRA
will take responsibility for this report's dissemination and for ensuring that the
report's analysis is reflected in future policy decisions. Ministerial
responsibility will rest with the Secretary of State for the Environment, Food
and Rural Affairs, reporting to the SCI(BIO) Cabinet Committee.193
In
particular, the report will play an important role in informing Government's
policy towards GM crops and foods, on which an announcement is expected
towards the end of 2003. DEFRA will need to work closely with other
Government Departments and with the Devolved Administrations in
disseminating and using this report.
5.2.2 Finally, the Strategy Unit will be responsible for collating and publishing
responses to this report. The Strategy Unit also plans to publish a summary
of the responses received, and will pass all responses on to DEFRA.
5.2.3 Responses should be sent to
GMCrops@cabinet-office.x.gsi.gov.uk
GM Crops Project Team
Strategy Unit
4th
Floor, Admiralty Arch
The Mall
London SW1A 2WH
to arrive by Friday, 17th
October 2003.
193
The Ministerial Sub-Committee on Biotechnology (SCI(BIO)) is chaired by the President of
the Council and Leader of the House of Commons, and has as its remit, "To consider issues
relating to biotechnology - including those arising from genetic modification, biotechnology in
healthcare and genetic issues - and their economic impact; and to report as necessary to the
Committee on Science Policy." Full information is available at http://www.cabinet-
office.gov.uk/cabsec/2003/cabcom/sci_bio.htm.
121
Annex A: The role of the Strategy Unit
The Strategy Unit was created by a merger of the Performance and
Innovation Unit, the Prime Minister's Forward Strategy Unit and part of the
Policy Studies Directorate of the Centre for Management and Policy Studies.
The unit performs a range of functions, including long-term strategic reviews
of major areas of policy, studies of cross-cutting policy issues, strategic audits
and joint work with departments to promote strategic thinking and improve
policy-making across Whitehall.
The Unit's Director is Geoff Mulgan and it reports directly to the Prime Minister
through the Cabinet Secretary.
Comprehensive information about the work of the Strategy Unit and its
projects can be found on the Strategy Unit's web-site at www.strategy.gov.uk.
122
Annex B: Project team, Sponsor Minister and Expert
Groups
This report was prepared by a multi-disciplinary team guided by a Sponsor
Minister and non-Government Expert Advisory Groups.
The Strategy Unit Project Team
The Strategy Unit team included team members with experience in
economics, science, policy-making and issues affecting developing countries.
The team was made up of a mix of some civil servants and some drawn from
outside Whitehall. None of the team had previously worked for organisations
with a financial interest in GM crops or GM foods, neither had they been
associated with campaigning activities on GM issues.
The project team comprised:
Vicki Bakhshi Economist, Strategy Unit
Ian Coates (team leader) Economist, Strategy Unit
Dominic Cookson Strategy Unit
Nicholas Garland Strategy Unit
Dr Adam Heathfield Scientist, Strategy Unit
Matthias Kempf Economist, Strategy Unit
Halima Khan Strategy Unit
Lizzy Lomax Economist, Strategy Unit
Jamie Rentoul Deputy Director, Strategy Unit
Alison Sharp Strategy Unit
Additional assistance was provided by Kevin Mochrie from the
Communications Team in the Strategy Unit. Research assistance was
provided by Clare Blomeley (on work placement from the Government Chief
Whips Office) and by Ester Barnabas on work experience.
The Sponsor Minister
The work of all Strategy Unit teams is overseen by a Sponsor Minister, in this
case Rt Hon Mrs Margaret Beckett MP, Secretary of State for the
Environment, Food and Rural Affairs.
The Expert Advisory Groups
The project team appointed three Expert Advisory Groups to assist with
different aspects of the analysis. Individuals were selected to give a range and
balance of expertise and backgrounds. Each met on three occasions to
consider the scoping note, scenario development/ background working papers
123
and draft report respectively. The Expert Advisory Groups played a crucial
part in the project, but were advisory and this report does not necessarily
reflect their views.
Expert Advisory Group Members
Environment Expert Group
Professor Jim Dunwell University of Reading
Dr Timo Goeschl Department of Land Economy,
University of Cambridge
Dr Brian Johnson English Nature
Dr Guy Poppy Division of Biodiversity and Ecology
University of Southampton
Professor Jules Pretty Centre for Environment and Society
University of Essex
Professor Clive Spash University of Aberdeen and Macaulay
Institute
Dr Jeremy Sweet National Institute of Agricultural
Botany (NIAB)
Product Chains Expert Group
Richard Ali British Retail Consortium
Gundula Azeez The Soil Association
Dr Philip Cain University of Newcastle upon Tyne
Jill Johnstone National Consumer Council
Professor Terry Marsden University of Cardiff
Archie Montgomery National Farmers Union
Dr Geraldine Schofield Unilever
Industry and Science Expert Group
Dr Paul Burrows The Biotechnology and Biological
Sciences Research Council
Dr Glenn Crocker Ernst and Young
Dr Bruce Pearce Elm Farm Research Centre
124
Dr Paul Rylott Bayer Crop Science
Professor Alison Smith John Innes Centre
Professor Joyce Tait ESRC Centre for Social and
Economic Research on Innovation in
Genomics (INNOGEN)
Dr Roger Turner British Society of Plant Breeders
125
Annex C: Organisations consulted and submissions
received
Organisations consulted
The team was also assisted by being able to draw on the experience and
advice of a number of experts and stakeholders who attended workshops
associated with the project or bilateral discussions with the team:
Action Aid
Adams, Professor John, Department of Geography, University College,
London (UCL)
Advisory Committee on Pesticides (ACP)
Advisory Committee on Releases in the Environment (ACRE)
AfricaBio, South Africa*
Agribusiness Advisory Group (linked to DTI)
Agricultural Biotechnology Commission (ABC)
Agriculture and Environment Biotechnology Commission (AEBC)
Agriculture and Rural Development Committee, National Assembly for Wales
American Soybean Association
ANBio, Brazil*
ANBio Whitehouse Consultancy
Association of Applied Biologists
Barnes, Dr Simon, Imperial College
Bayer Cropscience
BioIndustries Association Scotland
Biotechnology and Biological Sciences Research Council (BBSRC)
British Crop Protection Council
British Overseas Agencies Groups (BOAG)
British Retail Consortium
British Society of Plant Breeders (BSPB)
British Sugar *
Broom's Barn
CAB International
Cambridge University Research Centre
Catholic Agency for Overseas Development (CAFOD) (as part of BOAG
representation)
Center for International Development, John F. Kennedy School of
Government, Harvard University, USA*
Central Office of Information (COI)*
Central Science Laboratory
126
Centre for Ecology and Hydrology
Centre for Environment and Society, University of Essex
Centre for Social and Economic Research on the Global Environment
(CSERGE), University College London
CETOIM, France
Chinese Academy of Agricultural Sciences*
Christian Aid (as part of BOAG representation)
Consumer's Association
Council for Nature Conservation and the Countryside
Cropgen
Department of Agriculture and Rural Development, Northern Ireland
Department for Environment, Food and Rural Affairs (DEFRA)
Department for International Development (DFID)
Department of Environment Northern Ireland (DOENI)
Department of Trade and Industry (DTI)
Division of Biodiversity and Ecology, University of Southampton
Economic and Domestic Affairs Secretariat, Cabinet Office
Elm Farm Research Centre
English Nature
Environment Agency
Environment Business and Development Group (as part of BOAG
representation)
ERGO Communications
Ernst and Young
European Centre for Development Policy Management*
European Commission Directorate General, Development
European Commission Directorate General, Environment
European Commission Directorate General, Health (SANCO)
European Commission Directorate General, Trade
FARM
Federal University of Parana, Brazil*
Fiddaman, Bob
Five Year Freeze
Food and Drink Federation
Food Standards Agency
Foreign and Commonwealth Office
Forum for Biotechnology and Food Security, India*
Friends of the Earth
Frontline Consultants
The Gatsby Charitable Foundation
Gene Campaign, India*
Genewatch UK
127
"GM Nation?" Public Debate Steering Board
Green Alliance
Greenpeace
Health and Safety Executive
HM Treasury
Horticulture Research International
IACR Rothamsted Research
The International Crops Research Institute for the Semi-Arid Tropics
(ICRISAT), Kenya*
Innogen
Institute of Development Studies, University of Sussex
John Innes Centre
Kings College, London
Lancaster University
Lexington Communications
Maharashtra Hybrid Seeds Company, India*
Medical Research Council
Michigan State University, USA*
Monsanto
National Assembly for Wales
National Consumer Council
National Farmers Union (NFU)
National Institute of Agricultural Botany (NAIB)
Natural Environment Research Council
Nawaz, Mahmud (Consultant)
Neville Craddock Associates
New College, Oxford
New Zealand Ministry of Research, Science and Technology
New Zealand Treasury
No 10 Policy Directorate
Northern Foods
Northern Ireland Environment Link
Northern Ireland Grain Trade Association
Northern Ireland Plant Breeders Association
Nuffield Council on Bioethics*
Office of Science and Technology (OST)
Office of the Gene Technology Regulator, Australia
Open University
Organisation for Economic Co-operation and Development (OECD)
Overseas Development Institute
Parliamentary Office of Science and Technology (POST)
PG Economics
128
Queen's University Environmental Science and Technology Research
(QUESTOR) Centre, Belfast
Rockefeller Foundation
Royal Institute of International Affairs
Royal Society
RSPB
Safeway
Sainsbury's
Science and Technology Policy Research (SPRU), University of Sussex
Science and Technology Policy Research Institute, Ghana*
Science Review Panel
Scottish Agricultural College
Scottish Beekeepers Association
Scottish Crop Research Institute
Scottish Executive
Scottish Organic Producers Association.
Scottish Universities Policy Research and Advice network
Sekona Partnerships
Soil Association
Supply Chain Initiative on Modified Agricultural Crops (SCIMAC)
Sustainable Development Commission
Syngenta
Tesco Centre for Organic Agriculture
Ulster Farmers Union
Unilever
United Kingdom Agricultural Supply Trade Association (UKASTA) (inc
UKASTA Scotland)
United Kingdom Environmental Law Association (UKELA)
United Kingdom Patent Office
United Kingdom Permanent Representation to the European Union
United Nations Industrial Development Organisation*
University College London
University of Aberdeen and Macaulay Institute
University of Cambridge
University of Cape Town, South Africa*
University of Cardiff
University of Newcastle upon Tyne
University of Reading
US Embassy, London
Washington University, St Louis, USA*
Wynne, Professor Brian
Zambian delegation of scientists and Government officials
129
Entries marked with a * are those for which contact was via telephone and/or
e-mail only.
Submissions received
Correspondence with stakeholders and experts also provided important input
to the project. Submissions were invited via the Strategy Unit website in
response to publication of the project's Scoping note, overall methodology
paper and a series of working papers. The Scoping note, all papers and
responses to them are available at
http://www.strategy.gov.uk/2002/gm/sub.shtml.
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Annex D: The GM Dialogue: links with the Public
Debate and the Science Review
The Strategy Unit study is part of a three strand national dialogue on genetic
modification (GM). The box below has been taken from the GM Public Debate
Steering Board Statement of Relationships and outlines the three strands of
the national dialogue. Further details can be found at www.gmnation.org.uk.
Please note that the text in the box is quoted verbatim from the "Statement of
Relationships", as published earlier this year. Some of the references in the
text - particularly to dates of activities - are therefore out of date.
INTERACTION OF THE GM PUBLIC DEBATE, THE GM SCIENCE
REVIEW, AND THE STRATEGY UNIT STUDY ON GM CROPS
Government announced last year that there should be a national dialogue on
genetic modification (GM). The dialogue has three main strands of activity: an
independently run public debate, a review of the science around GM, and a
study into overall costs and benefits. The strands are different but closely
related. This note summarises who is doing what, when, and how the
activities interact.
`GM Nation? The Public Debate' is a programme of public deliberation with
the issues for debate framed by the public. The debate is being conducted at
arm's length from Government by an independent steering board. The main
period of activities will be in June and the first half of July. The Public Debate
Steering Board will report to Government in September 2003 about what the
debate has indicated about public views, particularly at grass roots level, to
inform Government decision-making.
The Science Review is being led by Professor Sir David King (Government
Chief Scientific Adviser) working with Professor Howard Dalton (DEFRA Chief
Scientific Adviser). An expert Science Review Panel, chaired by Professor
King, is reviewing and summarising the state of scientific knowledge,
consensus and areas of uncertainty on GM science issues and examining
where any further work is needed. The science review will produce a first
report in summer 2003 and plan then to revisit the report in the autumn, in
order to take into account the results of the public debate and any new
scientific information.
The study into overall costs and benefits is an analysis of the nature and
distribution of costs and benefits that could arise under different scenarios for
the possible commercialisation (or not) of GM crops in the UK. The Prime
Minister's Strategy Unit (SU) is carrying out this study. The SU expect to
publish their report in June 2003.
The Public Debate Steering Board, Science Review Panel and Strategy Unit
have undertaken to:
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ˇ address the public's framings of the issues;
ˇ draw on each other's key outputs as appropriate;
ˇ operate with transparent and open processes, including publishing key
outputs as they go along;
ˇ inform each other about their activities.
The SU project team provides regular reports to the Public Debate Steering
Board, and the board in turn has been providing views on the SU team's work.
The SU has also invited the Public Debate Steering Board's comments on
drafts of key papers. The SU is also drawing on the emerging work of the
science review on the scientific evidence on potential impacts of GM as part
of its assessment of overall costs and benefits. Two members of the Science
Review Panel are on the SU Expert Advisory Group and others have
contributed to the SU's work on an ad hoc basis.
The Science Review Panel and the Public Debate Steering Board are keeping
each other updated on their respective work at steering board and science
panel meetings. Professor Phil Dale, one of the Public Debate Steering
Board members, is also a member of the Science Review Panel. The Food
Standards Agency (FSA) is providing advice to the Science Review Panel on
the issues the Panel is considering.
Those responsible for each strand meet as required in addition to interactions
between the strands at Public Debate Steering Board and Science Review
Panel meetings. The secretariats and project teams for each strand liaise
regularly to organise implementation of any actions agreed. Communications
advisers to each strand also exchange information about planned activities.
The FSA has been separately assessing consumer views on the acceptability
of GM foods and consumer choice. Activities have included a schools debate
and a citizen's jury broadcast live on the internet. Following review and
evaluation of the results by the FSA Board at its public meeting on 8 May, the
FSA will report to Government on what it has found. The FSA has also
undertaken to inform the Public Debate Steering Board of its findings and to
publish them.
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Strategy Unit, Admiralty Arch, The Mall, London SW1A 2WH
Tel: 020 7276 1881
Email: strategy@cabinet-office.x.gsi.gov.uk
Website: www.strategy.gov.uk
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