Questionnaire on the socio-economic implications of the by 5E35cTB

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									 Questionnaire about the socio-economic implications of

     the placing on the market of GMOs for cultivation



              A diagnosis by Spanish organizations:

   COAG, Ecologistas en Acción, Friends of the Earth,
              Greenpeace and CECU



                   Original document: December 2009
                  Translation to English*: January 2010




* translated by the undersigning organizations and with their own resources
Content:


1.    Introduction………………………………………………………                                     1

2.    The impact of GM crops in non-GM farming (and therefore for
      non-GM foodstuffs)….…………………………………………..                                2
      2.1. The loss of the market and lower prices for organic maize
           due to GM contamination and extra costs for non GM maize
           cultivation; thus: the gradual disappearance of organic maize
           cultivation and increased difficulties for production of con-
           ventional maize in some areas………………………………                        5
      2.2. Damage to socially orientated initiatives such as rural devel-
           opment and other sectors ……………………………………                          10
      2.3. The loss of the market for gluten from conventional maize...     11
      2.4. The loss of organic feedstuffs ………….……………………                     13
      2.5. Increased prices of organic feedstuffs ..……………………..              14
      2.6. The costs of analysing (conventional and organic) feedstuffs
           to check for contamination …………………………………                         17
      2.7. Contamination of conventional and organic seeds……... 20

3.    The impact of MG crops for those farmers that cultivate them….        25
      3.1. Practical data from the Spanish Member State ……………..             26
      3.2. The experience of farmers cultivating GMOs in Third Coun-
           tries …………………………………………………………                                     28
      3.3. The development of resistance to agro-chemicals……………             30
      3.4. The failures of Bt technology ………………………………..                     32
           3.4.1. Lack of knowledge concerning the concentration of the
                  Bt toxin in MON810 maize….………………………..                     32
            3.4.2. The development of resistance to the Bt toxin ……….       33
      3.5. The implications of the current inability to draw up insurance
           policies to cover the risks involved in GM farming …………          36

4.    Social conflict generated by the introduction of GM crops ………..       37
      4.1. In farming………………………………………………………                                  37
      4.2. In scientific circles …………………………………………….                         38

5.    Implications for the right of consumers to GM-free food…………..         38

6.    Conclusions…………………………………………………………. 41

7.    Summary of aspects of the European Commission questionnaire co-
      vered in the present document………………………………………. 41
      7.1. Economic stakeholders considered in the present document….. 41
      7.2. Chapters of the European Commission questionnaire covered
           in the present document……………………………………….. 42

8.    References ………………………………………………………….. 43
   1. Introduction

Ever since the opening of the debate on the introduction of genetically modified (GM)
varieties in farming in the Spanish Member State in the early 1990s, the farmer and
social organizations that have drawn up the present document have called for the
potential socio-economic implications of GM crops to be taken into consideration in the
processes of drafting of relevant legislation, GM crop authorisation or rejection and
monitoring of GM crops.

This demand has also been made by a wide range of farm and social movements across
the European Union (EU) and for the following reasons:

      In the first place, for different reasons these movements reject the policy of
       basing all decisions concerning the introduction of a new technology such as
       genetic engineering on purely scientific information:

           o As has been proven many times, science is not necessarily objective
           o As has also been shown, particularly in the case of genetic engineering,
             science is open to the risk of manipulation by economic stakeholders
             (Robin, 2008)
           o For reasons of ethics and justice, socio-economic criteria should prevail
             over the technological applications of science when it is thus decided by
             different peoples.

      Secondly, available information, both theoretical information from almost two
       decades ago and new data concerning the practical aspects of the commercial
       cultivation of GM varieties, confirms that the impacts of the application of
       genetic engineering in open, interrelated systems include inevitable flows of
       genetic information and alterations in the market.

       The existence of not only physical but also socio-economic impacts in farm
       production systems that wish not to use genetic engineering has been confirmed.
       Thus, limiting authorisation processes of GM varieties to only their
       “technological” behaviour means analysis excludes other aspects of our daily
       lives that are more important than purely techno-scientific results for much of
       the population of the EU, including the majority of farmers.

      Thirdly, it has long been considered that the information given to farmers to try
       and encourage them to buy GM seed is clearly insufficient, partial and not
       subject to appropriate checks, a view now confirmed. This situation is also
       generating a whole series of socio-economic impacts for the minority of farmers
       that cultivate GM varieties in the EU (it should be borne in mind that the
       multiple problems generated by GM crops are caused by their cultivation on less
       than 0.2% of EU tilled farmland).

      Lastly, to date the legislative powers of the EU have not listened to calls for
       multidisciplinary analysis of GM crops for their authorisation or rejection.
       Apparently the EC can no longer ignore the numerous problems that the
       cultivation of GM varieties is causing in farming and, consequently, along the
       whole food-farm chain. These problems are agronomic, environmental, social,
       economic and ethical.

       The farmer and social organizations that have drafted the present document thus
       applaud the initiative that the EC has now put in motion to identify the socio-
       economic implications of the introduction of GM cultivation in European
       farming, but wish to register their denunciation and deception for the late hour at
       which our European institutions have accepted the need to bear these
       implications in mind. We insist that the latter should have been incorporated in
       all analysis, decisions and legislation concerning GM crops from the beginning,
       even before the period of authorizing or rejecting the deliberate release of GM
       varieties.

Additionally, the farmer and social organizations that sign the present diagnosis
consider that, when the European Commission analyses their document, it should bear
in mind the huge difficulties, particularly for farmer and social organizations, that
hinder identification and access to practical and verifiable data on, precisely, the socio-
economic implications of GM cultivation. Once again this is due to a series of clear
reasons that have been repeatedly denounced.

To start with, there is a serious lack of practical, sufficient, adequate and verifiable
information concerning both experimental and commercial cropping with GM varieties.
The type of information that is needed to adequately answer the EC questionnaire on the
socio-economic implications of GM cultivation is simply not available to the public in
general and we suspect that it is not even available to the relevant Institutions.

Equally, the lack of transparency that surrounds the bureaucratic procedure for the
introduction and, particularly the control, observation and monitoring of GM crops,
means that much of the information that the farmer and social organizations can offer in
the present document is information gathered from studies financed by non-
governmental sources or by Institutions that have only indirect powers in the area of
GM cultivation. As such this also explains the lack of information.

Despite undertaking a series of initiatives to achieve transparency and appropriate
monitoring of the impacts of GM crops, farmer and social organizations have received
no efficient or democratic reply from the Spanish Government. Thus, the said
organizations have had to use their own human, economic and technical resources to
gather the little information they offer here. If they offer no other information it is
because the Institutions are not collecting it or, if they are collecting it, they do not
publish the results.

This situation has two clear consequences in the context of the present document:

      Farmer and social organizations do not always have access to all the practical
       information they need concerning the socio-economic implications of GM crops
       (for example, yields of GM crops per hectare or the degree of GM contamination
       of non-GM crops), but consider that, if they did, it would confirm their answers
       to the present EC questionnaire. In other words, if our Institutions adequately
       financed the monitoring, analysis and evaluation of the socio-economic impacts
       of GM crops in the Spanish Member State, a far greater negative socio-
       economic impact would be observed in farming and food systems that would
       like to be 100% GM-free. Additionally, the negative impacts of GM crops for
       those farmers that have decided to cultivate them, whether freely or due to GM
       contamination, would also be more clearly revealed.

      Information regarding both the socio-economic impacts of GM farming in other
       geographical regions and potential impacts that are not necessarily verifiable in
       the Spanish Member State will inevitably and indispensably be included in
       replies to the type of questionnaire that the EC has sent out. The motive is,
       clearly, the lack of information at a local level. This situation is considered to be
       the result of an inadequate situation characterized by a lack of transparency,
       itself generated by existing legislation and bureaucracy and is not due to the lack
       of effort by civil society to try and understand and analyse the reality of GM
       crops. Once again we insist that GM varieties should not be cultivated in the EU
       in this context.

Lastly, the farmer and social organizations that have drafted the present document have
agreed to send copies in Castillian and English to their sister organizations in Europe, to
given Member States of the EU, members of the European Parliament and members of
the EC.




   2. The impact of GM crops in non-GM farming (and therefore for non-GM
      foodstuffs

The information offered here is of three types:

      real, quantifiable impacts of GM crops in non GM agriculture in the Spanish
       Member State
      References to information concerning real and quantified impacts of GM crops
       in non GM crops in other geographical areas
      References to abstract information for predictions of the socio-economic impacts
       of different GM crops when practical information is not available (with the
       intention of not having to denounce such consequences in the future).

We can offer the following practical quantified information concerning the socio-
economic impacts of GM crops on conventional and organic (non GM) cultivation,
livestock production and foodstuffs in the Spanish Member State.:

      The loss of markets for organic maize crops due to their contamination by
       GMOs and, consequently their sale at lower prices in the market for
       conventional maize; the extra costs for producing non-GM maize; the gradual
       loss of cultivation of organic maize and the huge difficulties to produce
       conventional maize in given areas.
        Damage to socially orientated initiatives such as rural development and other
         sectors, for example, the market for organic cereals for flour and bakery
         products.

        The loss of the market for gluten from conventional maize due to contamination
         by GMOs and sales at lower prices for animal feedstuffs

        The loss of organic feedstuffs due to contamination by GMOs and the costs of
         replacing them with feedstuffs that guarantee no contamination

        Increased price of organic feedstuffs due to both the extra costs of buying
         guaranteed GM-free organic maize and the rising prices of alternative elements.
         Implications for food sovereignty.

        The costs of testing for GM contamination of feedstuffs and seeds

        The contamination of conventional and organic seeds

In order to adequately gauge the economic losses that are quoted in this chapter of the
present document, it is worth bearing in mind that the average annual income of farmers
in the Spanish Member State is currently some 20.000 euros


    2.1. The loss of the market and lower prices for organic maize due to GM
        contamination and extra costs for non GM maize cultivation; thus, the
        gradual disappearance of organic maize cultivation and increased difficulties
        for production of conventional maize in some areas

In 2006 Greenpeace, the Catalan farmer organization “Assemblea Pagesa” and the
Catalan anti-transgene organization “Plataforma Transgenics Fora” presented a joint
document entitled “Impossible coexistence”1 (“La imposible coexistencia”). Based on
the results of extensive research this document revealed the true situation of transgene
crops in the Spanish Member State, mainly in Catalonia and Aragon. The text provides
real evidence that “coexistence” between transgene agriculture and non GM farm
models is not viable. It is based on the testimonies of dozens of arable and livestock
farmers and farm cooperative managers and the results of analyses of samples of maize
gathered from farmers’ fields. The report clearly demonstrates that Public Authorities
have taken no measures to separate, segregate and control GM and non-GM crops and
harvests, lack of transparency in research, the presence of illegal GM varieties,
unauthorized experimental plots of GM varieties and the absence of public registers of
GM cultivation.

In 2008 Greenpeace wrote a new document entitled “Coexistence is still impossible” 2
(“La coexistencia sigue siendo imposible”) which presented the testimonies of farmers

1

          Full information with descriptions of numerous cases:
    http://www.greenpeace.org/espana/news/ecologistas-y-agricultores-rev and
    http://www.greenpeace.org/espana/reports/copy-of-la-imposible-coexisten
2
      Full report with description of numerous cases:
     http://www.greenpeace.org/espana/news/greenpeace-desenmascara-las-co
whose fields had directly or indirectly been contaminated in 2007 by GM maize
MON810 and whose socio-economic situation suffered due to the presence of this
transgene in Spain’s countryside. The lack of systematic analyses by the public
authorities to determine the extent of the problem means that the real dimension of the
phenomenon is unknown: thousands of hectares of Bt maize have been cultivated in the
Spanish Member State with absolutely no measures being taken by the Government to
evaluate, and least of all, to avoid pollination of organic and conventional maize crops
by these transgene varieties. For the same reasons there are no analyses of the socio-
economic impacts of these problems.

In countries such as the United States, the pioneer in cultivation of GMOs, a high
percentage of the conventional seed bank is already contaminated. A national report
published in 2004 concluded that 50% of “conventional” maize and soy seed and up to
to 83% of canola seed already contained genetic information from transgene varieties.

Below the cases of two of the many Spanish farmers that have suffered the agronomic
and economic consequences of contamination of their non-transgene crops by GM
elements are presented. It should be stressed that these reports had to be drawn up with
funds provided by the social movements themselves in the face of the totally passive
attitude of the relevant Spanish authorities.

Case Nº 1. In 2007 in the region of Aragon 75% of the samples taken by the Aragonese
Council for Organic Farming (CAAE: Consejo Aragonés de Agricultura Ecológica)
were found to be contaminated with transgenes. One of these samples belonged to
farmer Félix Ballarín, from Sariñena, Huesca:

This farmer had been cultivating organic maize for 6 years. He began to cultivate a local
endangered “red” variety that is popular in local culinary dishes. In 2004 his crop was
contaminated by two types of transgenes, one to a high percentage. “The incredible
thing was that the Ministry for Agriculture blamed me, saying that I must have done
things badly in the process of selection and reproduction of the local variety. In fact
such an argument shows that, even respecting the distances proposed by the Ministry
for Agriculture between GM and non GM crops to avoid contamination, in the last three
years of selection (2000-2003) a local variety, the heritage of farmers, has
disappeared”.

“Given that generations of farmers had undertaken the same process of selection, we
had the possibility and freedom to use this maize variety. Now we cannot because the
force of the law will fall on us if we now reproduce our seed (seed which belonged to
all) as it now contains a gene and can become seed that belongs to a multinational”.

In 2007, the maize that Ballarín cultivated was contaminated yet again, in this case, a
certified organic hybrid. The CAAE analysed the harvest and found GMOs.

As a consequence, despite being the unwilling victim of unwanted contamination, the
yield of his 7.7 hectares of maize lost its “organic” status and had thus to be sold at a
lower price in the conventional maize market. This situation arose despite the fact that,
being aware of the presence of GM maize crops in the area, Ballarín forwarded sowing
to prevent simultaneous flowering in the hope of reducing the probabilities that his crop
would be contaminated by pollen from the GM varieties. However, new water rights for
irrigation were given to his neighbours who then quickly sowed their own GM maize
only one week after Ballarín and thus flowering partially coincided and contamination
occurred.

Given that Ballarín had originally intended to sow later, he had chosen a short cycle
maize variety (known as the “600 cycle”) to harvest dry and thus avoid sending his
maize to a drier, given the risk of contamination due to the presence of residual GM
maize grains left from drying previous harvests in the same driers. However, as his
neighbours also forwarded their sowing, he had to sow too early for the type of variety
he had chosen (the temperature was too low for the earliest phases of plant growth) and
his yield was thus drastically reduced (from 9.000 kg/ha to 6000 kg/ha).

The loss of the crop’s organic status and its sale in the conventional maize market
obliged Ballarín to sell his harvest at a much lower price (14 cents/kg less), an
important economic loss.

Summary of economic consequences:
Forced untimely sowing date                                            3.000 kg/ha x 7,7 ha x 36
                                                                                                   8.316 €
                                                                       cent/kg
Loss of organic status and sale -Price he would have received in the
in conventional market          organic market: 36 cent/kg
                                                                       6.000 kg/ha x 7,7 ha x 14
                                                                                                   6.440 €
                                                                       cent/kg
                                   -Price in conventional market:
                                    22 cent/kg (14 cent/kg menos)
Economic loss that can be
directly attributed to problems                                                                    14.756 €
caused by GM farming


It is clear that this purely monetary valuation of damages does not adequately consider
the worry caused by uncertainty throughout the growing season and the damage to the
farmers’ good name amongst clients, nor the problems that contamination poses for the
viability (or lack of viability) of organic maize cultivation in the area in the future.

“I am discouraged. I am not going to sow maize this year. I can take on a certain
amount of risk on my capital, but not this much. Maize in Aragon is disappearing even
though there is a potential for thousands of hectares of organic maize. This is also
affecting organic livestock farmers… it is very difficult, if not impossible, to go into
organic livestock farming here because of the risk of buying transgenic maize”.

The following Table shows the degree of the problem for Aragon as a whole, with both
falling organic maize cultivation and high levels of contamination with transgenes:

 Year      Ha. organic            % samples with GM
             maize                     presence
 2004           120                        100
 2005            37                         40
 2006            41                         30
 2007      42                               75
Source: CAAE
Case Nº 2. A further example is that of Eduardo Campayo, who farms in the province of
Albacete. Twelve years ago the Campayo family discussed the need to start farming
organically. They began to grow organic maize to supply the “Rincón del Segura”
bakery business, which itself produces and buys organic cereals to make different types
of flour and organic bakery products sold throughout the Spanish Member State. “I
grow more natural crops because I feel I should and to be honest with myself. But given
the uncertainties and risk of contamination by GMOs, I am constantly running the risk
that my buyers will exclude me from their market”.

In 2006, Campayo sowed and harvested 2 hectares of organic maize, which he sold in
January 2007 to the Rincón del Segura bakery. Analyses of samples undertaken during
the periodical inspections by the certifier Sohiscert revealed the presence of transgenes
in the maize sold by Campayo. As a consequence, the organic status of the maize sold
by Campayo and of the bakery produce already made with it in the Rincón del Seguro
bakery was lost, the distribution of the latter products was stopped and 7,014 kg of
maize and 604 kg of flour and meal returned to Campayo.

The strategy that Campayo had used to try and avoid contamination by transgenes had
been to sow maize a month later than neighbouring farmers to thus try and avoid
presence of GM pollen in his crop. He sowed a short cycle maize that, however, has a
lower yield and so in 2007 his production fell from 12.000 to 9.000 kg per hectare.

The bakery goods that had been distributed had to be recalled and then sold in the
conventional market at a lower price (12 cents/kg), generating a big economic loss.

Another of the strategies for “self-protection” is that of the farmer him or herself
voluntarily taking and analysing samples. In the present case, Campayo took five
samples: two from neighbours’ maize crops at 500m distance to verify that it was not
transgene, one from his own crop just before harvesting (to check, should the harvest be
contaminated, whether or not this was due to cereal grains in the harvester), one from
the cereal grains collected after harvesting and a last one following drying. “I myself,
and not the owners of transgene technology, have to bear the costs of all these tests: the
victim pays”. Each analysis cost Campayo 250 Euros.

The loss of organic status for his harvest also led to the loss of the Common
Agricultural Policy (CAP) subsidy, of 300 euros / hectare3.




3
           Undertaking agri-environmental measures allows farmers to receive an economic subsidy given that his or
her farming practices are stricter and subject to more conditions than usual. In the case of agri-environment subsidies
for organic farming, some of the common conditions in different Spanish regions are:

         -Strict fulfilment of the conditions of organic production as laid out in Regulation 2029/91.
         -Fulfilment of the common and specific organic farming rules established for different crops in each region
of the Spanish Member State.
         -Market a given percentage of the crops in the organic market.

         Thus, if the harvest of an organic farmer is contaminated by GMOs, he or she cannot fulfil the third
condition and the organic farming subsidy is withheld, unless the relevant Regional Government has purposefully
decreed otherwise for cases in which a farmer is the proven victim of contamination by transgenes.
Summary of economic consequences
Forced change of sowing date                                           3.000 kg/ha x 2 ha x 26 cent/kg   1.560 €
Loss of organic status and sale -Price he would have received in the
in conventional market          organic market: 26 cent/kg
                                                                       9.000 kg/ha x 2 ha x 12 cent/kg   2.160 €
                                  -Price in conventional market:
                                   14 cent/kg (12 cent/kg menos)
Taking and analysing samples 5 samples, average cost of each: 250 € 5 x 250 €                            1.250 €
Loss of subsidy                   300 €/ha                             2 ha x 300 €/ha                   600 €
Economic loss that can be
directly attributed to problems                                                                          5.570 €
caused by GM farming


These sums would be considerably higher if, instead of 2 hectares, they were done on
the basis of the 37 hectares Campayo had sown the year before.

Obviously, once again, these figures do not express lost expectations and the unrest
caused by the companies that sell transgene seeds. Neither do they include the costs and
logistics of recalling contaminated goods and their placing on the conventional market.

“I know my crops could be contaminated again and it is a great risk because it
generates huge economic loss and the economic capacity of several people and small
businesses is based on the GM-free character of my grain. If my maize is contaminated
again this year, I will not grow the crop next year. I am sorry for my buyers who more
or less depend on me”.

“Organic maize could disappear due to transgenes. My experience with maize is that its
pollen travels much further than technical studies say and maize is contaminated at
greater distances than in the proposals for legal rules. In my case, the closest maize
was 500 m away, was not transgene and, even so, my crop was contaminated… it is
clear that it comes from much further away”.

It is worth mentioning that some of the problems these farmers mention, for example,
the difficulties involved in hoping to rely on the different flowering times of different
maize varieties to prevent contamination by transgenes, have been incorporated in the
document entitled “Comments on the first draft of the document ‘Best practices for
coexistence in maize’” (“Comentarios al primer borrador del documento ‘Mejores
prácticas para la coexistencia en maíz’”) that the Spanish farmer organization COAG
has drawn up and sent to the European Coexistence Office (COAG, 2009).

ABANDONMENT OF ORGANIC PRODUCTION
There is a clear trend towards abandoning cultivation of organic maize in those areas of
the Spanish Member State in which transgene maize is cultivated. Thus, the area sown
with organic maize in Aragon has diminished by 75% since 2003 when Aragon was the
main organic maize producing area in Spain, due to the high number of cases of
contamination of organic maize by transgenes.

This tendency is due to three interrelated causes:
   (i)        firstly, lack of adequate information to enable farmers to know exactly where
              fields of GM maize are located. On the one hand, although data has recently
              been released indicating in which parishes GM maize is grown, it is not
              known in exactly which fields within these parishes. On the other hand, there
              are very few cases in which farmers cultivating GM maize have actually told
              neighbouring farmers.

   (ii)       secondly, no effective measure has yet been identified and taken to prevent
              contamination by GMOs and all relevant theoretical and practical documents
              indicate that coexistence between GM and non GM crops is impossible as
              contamination will always be possible (see Assemble Pagesa, Platforma
              Transgénics Fora! & Greenpeace, 2006; Greenpeace, 2008; EHNE, 2005 and
              2007; COAG 2009….). Thus farmers have simply preferred to desist in any
              attempt to grow organic maize, their definition of organic being the total
              absence of any contamination by transgenes.

   (iii)      Thirdly, there is no adequate and efficient method by which to claim
              compensation for the economic loss suffered. There is no juridical basis to
              guarantee that those responsible for contamination cover the costs of the
              consequences.

The socio-economic implications of these GM maize crops for consumption of GM-free
(100% free) maize are considered below (section 5).



   2.2.Damage to socially orientated initiatives such as rural development and other
       sectors

The Rincón del Segura bakery, in the Sierra de Segura (Albacete), started as a family
business and as it grew it provided more jobs and employed rural women in a deprived
social environment. It is good example of profit generated from organic farming and
creation of wealth whilst also respecting the environment. In 2007 its sales were valued
at 1.183.000 euros.

“Our business laid its foundations on Gandhi’s philosophy of no violence and of
respecting all living things. And this is exactly the opposite of the role played by
Genetically Modified Organisms”.

At the start of 2007, the business bought a consignment of maize from Eduardo
Campayo Vera, maize that had been sown and harvested in 2007 (see above). When the
Rincón del Segura bakery bought the maize this had an up to date certificate of organic
status. In March 2007, the Sohiscert certifier’s annual inspection of the bakery detected
contamination by transgenes in that same consignment of maize which effectively
disqualified the bakery from selling any goods derived from maize throughout 2007.

Due to these events, the Rincon del Segura bakery:

   -       stopped sales of all products derived from the maize (flour and meal)
   -   informed its clients that, due to the results of analyses, these products would not
       be sold by them until they could guarantee raw materials free of any traces of
       GMOs
   -   Returned all the maize and maize products to the farmer, leaving the bakery’s
       usual clients without supplies and causing considerable economic damage to the
       bakery and loss of image with clients.

When Rincón del Segura requested data concerning the distribution and location of
fields sown with GMOs, the Ministry of Agriculture reply was that providing such
information could contravene the laws on protection of personal data and market
secrets. This reply is yet another excuse the Ministry uses to not fulfil Directive
2001/18/EC on deliberate release of GMOs into the environment, which requires the
existence of Public Registers in which the location of all GM crops is recorded.
Curiously, the location of all organic crops is clearly and correctly recorded in the
archives of both organic certifiers and the public authorities. The difference in criteria
applied in each case is manifest and, in the case of GM crops, there is a clear lack of
transparency.

“Farmers and processors of organic foodstuffs are helpless and at a clear
disadvantage, as we must comply by strict rules with multiple bureaucratic proceedings
in order to carry out our work. The companies and producers of transgenes are allowed
to freely contaminate our fields and food, even when the majority of consumers, if
provided with information, would choose conventional or organic food before buying
GM food”.

“Growing of organic crops is disappearing because farmers are afraid that their
organic maize will be contaminated by transgene maize and that they will suffer
substantial economic loss. Whilst the area under all other organic crops is on the rise,
the area under maize, an essential crop for the food industry and organic livestock
farming, is decreasing and maize has to be imported.”

This case study underlines the negative impact of transgene crops for food sovereignty,
as contamination by GMOs is hindering the introduction of agroecological farm models,
short market circuits and employment for women in rural areas.


SEED CONTAMINATION/
  2.3.The loss of the market for gluten from conventional maize

Documentary evidence is available concerning farmers whose crops of conventional
maize have been contaminated by transgenes, with clear economic implications. This is
particularly the case if the maize was to be sold as gluten as currently the food industry
demands GM-free maize and will not accept contaminated maize which must be sold at
a lower price for livestock feedstuff. Below, the problem the Tarazona Cooperative
(Aragon) experienced in 2202 and 2003 is described.

The farmers belonging to the Tarazona Cooperative unanimously decided not to
cultivate GM Bt maize (their reasons being, the higher production costs, lower yields
and lower prices for the GM harvest in the market). They also concluded that GM maize
would only even begin to make some sort of sense if there were serious attacks of corn
borer in an area in at least five consecutive years and that in their area there simply was
no corn borer worth speaking of.

The first added cost to their farming caused by the cultivation of GM maize in Aragon,
was expenditure on DNA analyses of maize that entered the Cooperative (see section
2.6 for examples of costs). In 2002 these analyses revealed the presence of GM maize.
The starch industry demanded GM-free maize and thus the maize contaminated by
transgenes had to be sold in the livestock feedstuff market. The price difference was at
the time 4 pesetas or 0.24 cents per kilo. Given that approximately 500.000 kilos of
maize were contaminated, the direct economic loss was 2 million pesetas or 12.000
euros (Ardatza, 2007). In 2003, the Cooperative suffered a new case of contamination.

In the case of maize, genetic flows or pathways of contamination between conventional
and GM varieties are mainly cross pollination in the field and the use of shared farm
and processing machinery (drills, harvesters and driers…) both in the field and in post-
harvest management (EHNE, 2007). The presence of GM maize seed in sacks of
conventional seed is also a possibility given that the Spanish Member State is very
permissive and allows up to 0.5% of MG maize seed in conventional non GM maize
seed (Hugo et al., 2007; see section 2.7), without any indication of the contamination on
the seed label and thus favouring initiation of processes of contamination against which
nothing may be done (unless each farmer privately invests money to analyse each sack
of seed, a measure that is, however, prohibitively expensive, as is analysed below).

Significantly, in the case of the Tarazona Cooperative, a new means of “contamination”
or, at least, a new pathway for contamination arose: sales of GM maize seed to farmers
without their knowledge of the GM character of the seed. After the first case of
contamination the Cooperative thoroughly checked all their equipment and found no
GM seed. After checking with each farmer member of the Cooperative they identified
four that had not bought their seed from the Cooperative but rather from a different
source and concluded that this seed must have been the source of the contamination.
(They concluded that the second case was due to cross pollination).

It is clear that, apart from their dubious ethical character, the market tactics and
practices used by the companies that sell GM seed have different socio-economic
implications:

      A technology has been and still is sold to farmers who do not need it: thus, Bt
       maize seed has been sold and is still sold to farmers to, theoretically, combat the
       corn borer, even in those areas of the Spanish Member State in which the corn
       borer is not present, or is only present sporadically and at low numbers.

      GM maize has been sold and is still sold to farmers without clearly informing
       them that it is GM. The degree to which part of the blame lies with farmers
       themselves is open to debate, but what cannot be denied is that no measures
       have been taken to prevent inadvertent contamination by these farmers, with
       economic implications for other Cooperative members.

Introducing GM maize crops in areas of cultivation of non GM maize for grain
production (as opposed to livestock forage) means the gradual loss of the market for the
millions of tons of such grain that is currently produced in the Spanish Member State
for the food processing industry. This industry currently demands GM-free maize and
there is a quantifiable economic loss of 18 euros/ton if this maize has to be sold for
livestock feedstuff due to contamination by GMOs.
    2.4.The loss of organic feedstuffs due to contamination by GMOs and the costs of
        replacing them with GM-free feedstuffs

There are a number of documented cases of contamination of organic feedstuffs by
transgenes and consequently economic loss derived from both having to replace and
adequately dispose of them. Two cases are considered below:

In 2001, the organic chicken farmer, Charo León, from Argueras (the province of
Navarre) made an agreement with a neighbouring farmer to the effect that he would sow
organic soy and she would buy his harvest as organic feedstuff for her chickens and
hens. The Navarre Council for Organic Farming (CPAEN) sent a sample of the soy
bought by Charo León to be analysed and as GM soy was identified in the sample she
had to get rid of the contaminated soy and pay out more money to buy new feedstuffs.
The economic cost totalled some 1500 euros.

However, this case has three other socio-economic implications:

      Firstly, it generated conflict within the farming community, an issue analysed in
       section 4.1 of the present document. The chicken farmer did not initiate
       proceedings for compensation precisely because she wished to avoid problems
       with a neighbouring farmer.

      Secondly, Charo León also desisted in attempts to claim compensation because
       analysis of the legal possibilities of claiming some sort of compensation
       revealed that the nature of the source of contamination (GM seed in the soy seed
       originally bought by the arable farmer) and the lack of a clear legal definition of
       accepted levels of GM presence in non GM seed meant she had no case. In
       social terms, GM free (100% free) farming is not protected under current
       legislation (Amigos de la Tierra et al., 2009).

      Thirdly, both her feelings of great frustration and the difficulties involved at that
       time of guaranteeing GM free organic soy led Charo León to give up organic
       egg production and start producing free range. This meant she lost the price
       premium for organic eggs, at that time between 1 euro and 1.50 euros a dozen.
       Simultaneously, and obviously, this caused a loss of buying opportunities for
       customers interested in organic produce.

Another case of contamination of organic chicken feed occurred in the parish of Aulesti
in the province of Bizkaia. The farmer, Arrantza Arrien, bought organic soy for her hens
and chickens. An analysis she herself paid for revealed contamination by GM soy.

The reaction of the Basque Government to this case of contamination by GMOs is
rather puzzling, for two reasons: firstly, the government official that turned up at
Arrantza Arrien’s farm asked her why she had analysed the soy feedstuff in the first
place, a rather worrying indication of the Basque Government’s real attitude to GMOs
in practice; and, secondly, the official proceeded to close and seal the soy, but despite
repeated telephone calls, a year later the chicken farmer had still not heard from the
Basque Government official again and who showed no interest at all in how the farmer
could be compensated for the loss of the approximately 600 Euros (once again, it should
be borne in mind that the average income of Spanish farmers is around 20.000 euros)
spent on the soy feedstuffs she could not use, nor how she could safely dispose of the
contaminated soy, whilst the soy was becoming an increasing problem due to its gradual
decomposition and rodent activity.

Additionally, the reaction of representatives of different organic consumer groups was
initially very negative and they indicated that they no longer wished to purchase
Arrantza Arrien’s eggs, once again causing conflict in rural areas (see section 4). Over
time, however, the farmer managed to regain their confidence in her produce, mainly
because of the responsible attitude she had shown in the first place, as it had been the
farmer who had voluntarily decided to undertake and pay for analysis of the soy
feedstuff.


   2.5. Increased prices of organic feedstuffs due to both higher costs of acquiring
       100% GM free organic maize and to the rising prices of alternative materials.
       Implications for food sovereignty

Case 1. The Garte Livestock business, located in Fuentes Calientes (province of Teruel),
rears about 3000 pigs a year following organic livestock regulations and which are sold
under the guarantee of origin “Teruel ham” (Jamón de Teruel”). The animals consume
around a million kilos of feedstuff each year produced from raw materials bought in and
processed by the company, which, however, also produces three million kilos of organic
feedstuff for other organic farmers. About half a million kilos of this total of some four
million kilos is maize and the other three and half million kilos are raw materials such
as barley, soy, wheat and legumes.

In 2007 Garte Livestock only managed to acquire 2.000kg of organic maize in the
Spanish Member State that had not been contaminated by GM maize and so had to
import nearly all the maize it required (specifically from France). The extra costs
involved were valued at 12 cents/kg, covering both extra transport costs and higher
prices in France. In other words, the contamination caused by transgene maize in the
Spanish Member State cost the Garte Livestock business an extra 12 cents/kg for
organic maize: the almost 500.000 kilos of maize cost an extra 60.000 Euros.

Other problems and costs should be borne in mind, as a document by the Garte
Livestock company points out (4):

      the price of organic soy meal is at least 100% higher than conventional soy meal

      The monitoring plan of the company includes obligatory analytical controls for
       transgene content of each consignment of soy and maize bought from sources
       within the Spanish Member State. This constitutes an additional cost of 140
       euros per lorry load and a two to three week period of quarantine, which in itself
       means an additional storage area has had to be organised for these products – an
       area which has to be very carefully cleaned should analysis reveal
       contamination.
____________________________

4.   “Impacto de los transgénicos en el precio de los piensos 100% ecológicos”, Garte Ganadera 2009.
         Protein rich raw materials such as peas and lentils that can be used as
          alternatives to soy in the production of feedstuffs are currently at risk of
          contamination by GMOs. However, as they are the only alternatives to soy, their
          market price has risen considerably. They are, in fact the only organic raw
          materials the value of which is higher in the market than in different warehouses
          around Spain. Thus, conventional peas would cost Garte Livestock about 200
          euros/ton, whilst organic peas cost over 350euros/ton.

         The greater administrative complexity resulting from buying in organic cereals
          from a higher number of suppliers has complicated logistics and management.

“Organic farming should be protected. It is absolutely essential that no transgene crops
be cultivated within a huge radius of organic crops. It is impossible to think they can
coexist”.

Such a situation explains why organic feedstuffs are considerably more expensive than
conventional feedstuffs, the difference increasing with the amount of maize, peas, lentils
and soy contained in each type of feedstuff. This constitutes an important negative
economic impact for organic livestock farming.


Case 2. July Bergé, who farms in Bellcaire de Urgell, La Noguera (Province of Lleida,
Catalonia), gradually adopted organic farming methods until his farm became 100%
organic in 1996. At the end of the 1990s he cultivated 30-35 hectares of maize as part of
a rotation system with other crops. From 2000 onwards he became seriously worried
about the growing number of GM maize crops in the area. Buyers began to demand
results of analyses for GM content and Bergé thus had to assume the costs of this threat
by, for example, postponing for a month or a month and a half his sowing dates.

The consequently lower yields influenced his farm economy. One problem was that the
corn borer insect that was theoretically supposed to die following contact with GM Bt
maize, was found at higher densities in maize crops that did not express the Bt toxin,
such as organic maize crops. Whilst the corn borer is not usually a problem in organic
and conventional maize that is correctly sown and managed in rotation with other crops,
when organic farmers delay sowing their crops they become victims of the corn borer
(the insect finds newly germinated, tender maize plants at the start of the summer).

As a result, Bergé has reduced the area under maize, as shown in the following table:

                               Year                    Hectares
                               Before 2000             > 31
                               2001                    30
                               2002                    23
                               2003                    20
                               2004                    12
                             2005                    10
                             2006                    6
                             2007                    1,7
In 2007 the Catalan Organic Farming Council (CCPAE) found transgenes in Bergé’s
maize harvest which thus lost its organic status and Bergé had to sell in the conventional
market.

During recent years Bergé had sown a local Catalan variety of maize with good results.
As with any farmer seed, Bergé selected part of his harvest as seed for the following
crop and thus reduced his dependence on seed companies. The seed he used in 2007 was
thus gathered from his 2006 harvest which had been certified by the CCPAE as GM-
free.

Delaying sowing to June, meant his yield was reduced from 8000 kg/hectare to less than
5000 kg/ha. “As ay farmer knows sowing maize in June is very late. But I have no
alternative”. Sowing this late in the season also means that Bergé runs the risk of losing
his subsidy. In 2007 yields were particularly bad (about 3000kg/ha instead of even 5000
kg/ha). Bergé has calculated that delaying sowing has been responsible for the loss of
about 4000 kg/ha.

The loss of organic status meant the maize had to be sold in the conventional market at
a lower price (9 cents/kg less), an important economic loss. Additionally, Bergé bought
200.000kg of organic feedstuffs from France for his own chickens, half of which is
maize. Each kilo of feedstuff cost 54 cents, whilst he can produce it himself for 12 cents
less per kilo, even if he buys in raw materials other than maize. “It is a real shame that I
have to pay those prices when I could make my chicken feedstuff with my own maize”.

Summary of economic consequences
Torced untimely sowing
                                                                   4.000 kg/ha x 1,7 ha x 30 cent/kg 2.040 €
date
Loss of organic status and  -Price he would have received in the
sale in conventional market organic Maite market ecológico:
                             30 cent/kg
                                                                   3.000 kg/ha x 1,7 ha x 9 cent/kg   459 €
                            -Price in conventional market: 21
                            cent/kg (9 cent/kg menos)
Bought in feedstuffs for
                                                                   200.000 kg x 12 cent/kg            24.000 €
chickens
Economic loss that can be
directly attributed to
                                                                                                      26.499 €
problems caused by GM
farming


If Bergé were to have cultivated the 30 hectares he would like to, the loss would have
totalled 64.500 euros.

As in all the other cases mentioned in this present document, the monetary valuation of
damages does not adequately portray the worry caused by uncertainty throughout the
growing season, the damage caused to the credibility of Bergé’s organic produce in the
eyes of his customers, nor the problem that contamination of transgenes is creating for
the future viability (or lack of viability) of organic maize cultivation in the region in the
future.

“I think about both the future generations –about what sort of world I will leave to my
children- and those of us farming today. Before turning to organic farming I twice
suffered poisoning from pesticides I myself was using… I am really lucky to be alive…
and I am really pleased I have stopped using poisons”.

Summarising, it should be stressed that organic feedstuff prices have risen considerably,
to more than the usual difference between these and conventional feedstuff prices, due
solely to the problems caused by transgene crops.



   2.6. The costs of analysing (conventional and organic) feedstuffs to check for
       contamination

Farmers who wish to avoid using livestock feedstuffs containing transgenes have two
options. They may:

   (a) substitute all soy and maize in feedstuffs with alternative materials (see previous
       section for approximate costs as these would not differ greatly if the aim is to
       avoid using soy. Alternatively, farmers could acquire certified GM-free soy,
       which also has added costs that are widely documented on the Internet);

   (b) systematically analyse all soy and maize employed in feedstuffs to check for
       presence of GMOs and then act accordingly.

To estimate the costs of option two, the characteristics of most European livestock
farms should be used a base line: these are generally intensive or semi-intensive and use
substantial quantities of maize and soy. Additionally most soy imports are deliberate
mixes of conventional and GM soy and thus any attempt by a farmer to avoid using GM
soy would require analysis of each batch of maize or soy to determine whether or not it
contains GMOs.

The following data presents the costs of such analyses in the case of a dairy farm and
have been taken from a study on this issue undertaken in 2005 (EHNE, 2005).

Bearing in mind the profound and ongoing changes that are occurring in the structure of
dairy farming and its production, it is difficult to present data that could be considered
“characteristic” of a “typical” dairy farm. However, the study ventured the following
parameters for a family dairy farm in the north of the Spanish Member State (whilst
recognizing that the data would vary according to the farm production model and size of
specific farms):

      A dairy farm in which there are milkers, dry cows, heifers and calves

      A certain degree of dependence on imported soy concentrate, maize gluten and
       maize silage in feedstuffs, all of which could be GM. Dependence on these
       imported materials depends on the degree of production intensification.
      Supply of these feedstuffs throughout the year, the size and number of the
       batches depending on the size of the herd of milkers, their milk yield and the
       storage capacity of the farm.

      The presence of other animals, such as hens, chickens, sheep and pigs (typical
       on many such farms) mainly for home consumption and which also depend to a
       certain degree on bought in concentrates, mainly maize that has been ground or
       as grain.

Data can be offered concerning the costs of analysis should the dairy farmer decide to
analyse and then accept or reject all the batches of feedstuff that are bought in and that
contain soy and maize.

For the study a dairy farm with the following characteristics was considered: the
feedstuff needs for 40 dairy cows giving milk, 13 dry cows or that had recently calved
and 20-25 heifers and calves; a periodical supply of feedstuff batches throughout the
year, including 11 deliveries of feedstuff (75% barley, 25% soy) and 9 batches of maize
for silage delivered over a period of several weeks; and supplementary batches of
feedstuff delivered periodically during the year for the other farm animals and totalling
8 batches of ground maize and 11 of grain maize.

To be able to identify and reject any GM material, the farmer would have to analyse
each batch of feedstuff that includes maize or soy. The Table below estimates these
costs (at 2005 prices).


Summary of costs of analysis of detection of GMOs in batches of livestock feedstuff
         and forage containing soy and maize on an individual dairy farm
                     (euros, 16%VAT included, 2005 prices)
Analysis                                                     Cost (euros)

Qualitative analysis.……………………………………………… 149.00 - 175.21
Detection presence/absence of:
Promoter P-35S, Terminador T-NOS and plant gene
Cost of analysis when requested by a farmers’ organisation 69.6

Quantitative analysis……………………………………………..                               238.32
Of one of the following events or regulating areas:
* Promoter P-35S *Terminador T-NOS *Bt176 *Ga21
* Bt11, Mon810, RR, Nk603

Joint quantitative and qualitative analysis (should results be positive) 326.19

Optional analysis to detect traces of DNA………….…………….                      45.36
*maize *Bt176 *Mon810 *NK603 Mon810/809
* soy * RR (Roundup Ready) *T25 *Ga21 *Starlink *Bt11
Source: 2005 Prices quotes for analysis by authorised laboratories (Presupuestos de
análisis de laboratorios homologados) 2005 (Centro Nacional de Tecnología y
Seguridad Alimentaria, 2005; Neiker, 2005; Sistemas Genómicos, 2005)

Initially, the farmer needs to know whether GM material is or is not present in each
batch and the cost per “qualitative” analysis would have been between 149 euros and
175.21 euros in 2005. Further analysis would reveal which GM material was present
and in what quantity, information which is of interest to evaluate how contamination by
GMOs is occurring but which is not necessarily important for the farmer and is thus not
quantified here. However, it should be stressed that the qualitative analysis would
actually cost the farmer more than 175.21 euros as he or she does not buy just one batch
of feedstuff containing soy and maize but rather, in the case presented here, 39. Thus the
total cost would be 6,833.19 euros, an amount that is clearly impossible for the farmer
to bear.

Even if the analysis was to be requested by a farmers’ organization and thus each the
cost of each analysis be reduced to 69.60 euros, the total cost would be 2714.40 euros.

If the cost of analysis were to be limited to only the batches of maize and soy to be fed
to the dairy herd (and thus not bearing in mind the maize used in feed for the other farm
animals), the total cost would be 3,504.02 euros, which is still clearly impossible for a
farmer to bear: the cost of analysing a 2000kg batch of soy would be equal to about
40% of the cost of the soy itself (in 2005). Even should the analysis be requested by a
farmers’ organization the cost would be 1392 euros or 16% of the value of each batch of
soy (in 2005).

It is clear that, for the dairy farm considered in this example, the analyses constitute (a)
an extra cost that the farmer would not have to pay if GM maize and soy crops did not
exist and (b) extra costs that are too high for an individual dairy farmer to pay.

These costs would be considerably lower should the size of each batch of feedstuff be
increased and the number of total batches decreased. However, this would generate
investment costs in storage. Farms that rely on daily imported supplies of unifeed
cannot, obviously even begin to quantify the cost involved in analysing each batch and
thus exhaustively controlling GM presence in the feedstuffs they use.

And even so, it should be remembered that these costs only reveal whether or not the
animal feed is or is not contaminated by transgenes, but do not include the costs of then
avoiding any contaminated feedstuffs. In fact, at present, the only alternative open to
most livestock farmers that buy feedstuffs in cooperatives is to buy concentrate that
“could” contain transgenes.

The socio-economic implications of this situation for the consumer population are
obvious if one bears in mind existing legislation for labelling GM foodstuffs: there is
currently no legal obligation to label livestock produce (milk, meat…) according to
whether the farm animals have or have not eaten GMOs. Such products are thus not
differentiated in the market unless a GM-free label is considered, something that has
absolutely no official support at all in the Spanish Member State and which, in any case,
means that once again the costs of the responsibility for certifying the produce would
again be borne by those farmers that do not wish to use transgenes and not by those who
are causing the problem of contamination by transgenes by selling GM seeds in the first
place.

This situation will obviously change (and become more complex) should European
institutions heed the March 2009 Resolution by the European Parliament which calls for
labelling of livestock produce according to the presence or not of GMOs in livestock
feed, something that the organizations that undersign the present document have been
demanding for years.


   2.7. Contamination of conventional and organic seeds

One of the most important negative economic impacts of transgenes crops is derived
from their contamination of non GM crops, harvests, feedstuffs, etc. One frequent cause
of contamination is the presence of transgene seeds in batches of non-GM (conventional
or organic) seed, particularly when there is no control over such batches or no indication
on their label to point to the presence of GM seed. This may be an accidental or a
deliberate action by a seed company.

The evidence that social movements have managed to gather suggests that the Spanish
government has a very permissive attitude towards the contamination of conventional
seed by GM seed (mistakenly known as “fortuitous presence” of GM material), with
obvious socio-economic implications for both GM-free farming and food, as described
below.

There is no specific legislation to regulate the presence of GM seed in batches of non-
GM seed, although since the introduction of GMOs the European Commission (EC) has
proposed applying the same rules to GM seed as those applied to transgene foodstuffs:
in other words to consider any batches of conventional and organic seed GM-free even
if they contain up to a certain level of GM seed. Thus, in order to develop chapter C of
Directive 90/220/EC (of deliberate release into the environment of GMOs) at that
moment in force, at the start of the present decade the EC proposed allowing “the
fortuitous presence of GM seeds” in batches of non-GM seed up to a level of 0.3% for
cross pollinating species and up to 0.5% for self-pollinating species or those that
propagate vegetatively (proposal SANCO 1542/02 July 2002).

The agronomic, but also the socio-economic implications of this proposal are extremely
grave. In practical terms, the EC proposal means that between 30 and 50 square meters
per hectare meant for a supposedly non-GM crop could be sown with GM seed and,
additionally, without the farmer’s knowledge, as there would be no indication of this
degree of presence, of GM seed on the non-GM seed label. The implications for the
(lack of) legal protection of 100% GM free seeds are also huge, as are the implications
for the (lack of) legal protection of the crops, harvest and new seed gathered from the
field in question. Despite the fact that the practical negative implications of the initial
EC proposals were underlined by the Commission’s own Scientific Committee on
Plants (Scientific Committee on Plants, 2001), the EC did not change its strategy.

No legislation on this issue has yet been introduced in the EU and there is thus an a-
legal situation. To date different Member States have adopted different criteria and
measures and the policy adopted by the Spanish Member State has important socio-
economic implications. Thus, as mentioned above, a 2007 study (Hugo et al., 2007)
analysed the so-called “fortuitous presence”, (in other words contamination) of
transgenes in conventional seed.
According to the information provided in the study report, the policy adopted by the
Spanish Member State suggests that contamination exists and that the measures
necessary to guarantee the 100% GM-free farming in the future are not being taken:

      According to the study, the Spanish Government undertakes formal inspection
       of non-GM maize seed to see if they are contaminated or not.

      The Spanish government uses information on seeds that is provided by the very
       companies that sell seed themselves. Social movements consider that this
       constitutes a clear example of where data can be manipulated and that it would
       be better if the government bought and analysed random samples of seed and did
       not depend on batches selected by the companies themselves.

      The Spanish Member State analyses 90% of the batches of maize seed produced
       within its territory, 90% of imported batches and 10% of seed when the crop is
       still in the field. Around 200 samples are analysed a year.

      Between 2001 and 2006 ninety cases of authorised GM seed in batches of non-
       GM maize seed were documented. There was no indication of the presence of
       unauthorised GM maize seed.

      Forty two of the 90 cases were documented in 2006 alone, which suggests that
       the problem of contamination is increasing. Of these 42 cases, 16 were in seed
       batches from other EU Member States, with an average GM content of 0.18%
       and 26 were from third countries with an average GM content of 4.18%.

      Whilst the majority of EU Member States have a policy of zero-tolerance
       towards the presence of GM material in batches of non-GM seed, the Spanish
       Member State allows the marketing of batches of conventional maize seed that
       are contaminated up to a level of 0.5% by authorised GM maize and with no
       indication of the contamination on the label of the seed.

       This means that at least 36 batches of contaminated seed entered the
       conventional maize seed market in 2006. In other words, those farmers that did
       not wish to sow transgene maize and who bought seed from these batches ran
       the risk of having their harvest disqualified as conventional and GM-free.
       Obviously, it would be necessary to have access to data concerning the type of
       monitoring and the results of the monitoring of this contamination in crops to be
       able to estimate its exact economic implications for the conventional farmers
       involved, of the risk of further contamination of seed gathered from the crop and
       also the practical implications for guaranteeing supplies of GM-free food to the
       consumer population.

      Although no concrete cases are documented, the Spanish Member State even
       applies the same criteria – lack of information on seed labels – for batches of
       conventional maize seed that contain up to 0.1% of unauthorised GM material.
      The Spanish Member State only withdraws contaminated seed from the market
       when a batch is contaminated by (contains) more than 0.5% and 0.1% of
       authorised and unauthorised GM material respectively.
      It is worth mentioning that in its reply to a question in the study regarding which
       countries are considered risky concerning the presence of GM material in
       batches of non-GM seed, one EU Member State named the Spanish Member
       State.

      The Spanish Member State undertakes no monitoring of batches of soy seed,
       even though contamination of non-GM seed has been detected and reported (see
       below).

Summarising, the Spanish Member State itself allows, and takes no measures to
prevent, the use of batches of contaminated conventional maize seed in cultivation of
non-GM maize.

Apparently the Spanish Member State feels that such contamination does not cause
socio-economic problems. However, the grave-socio-economic implications of this
situation are revealed by practical examples of contamination documented by social
movements, including cases of contamination of certified organic seed.

      In 2002, Antonio Ruiz, an organic farmer from the region of Aragón, had a
       sample of certified organic soy seed analysed. The result revealed contamination
       by GM material. The importance of this case, apart from not being able to use
       the seed, is that it came from the same batch of soy seed as that used to produce
       organic soy for the chicken farmer Charo León and which had significant socio-
       economic implications due to subsequent contamination of the soy feedstuff (see
       case study in section 2.4).

       There are many ways by which seed can be contaminated. Often, as has already
       been mentioned, the seed that an arable farmer receives is already contaminated,
       either by mistake or purposefully, by the seed supplier. Again, maize is often
       sown by external operators (the farmer pays a company to sow his land, as
       special and expensive machinery is required). These operators generally wish to
       sow the highest number of hectares in the shortest time possible and do not thus
       thoroughly clean drilling machinery between one farmer’s fields and another.
       Remnants of seed are therefore often left in machinery as it passes from one
       farm to another and, in the case of GM seed, constitute another important source
       of contamination.

       The contamination revealed by the Navarre Council for Organic Farming in
       2001 of a batch of organic soy used as feedstuff on an organic chicken farm (see
       section 2.4) is relevant again. The conclusion was that the source of the
       contamination was probably in the seed originally used to produce the soy and
       which had been bought from Monsanto. At that time there were no other soy
       crops in the area and there had not been during the previous 15 years; however,
       the batches of seed were contaminated by (contained) GM seed, with no
       indication of this fact on their label.
    As such, this seed was illegal in the Spanish Member State, as no GM soy
    variety has been authorised for cultivation in the EU. Even so, Monsanto sold
    this seed and yet paid no compensation to the farmers for the economic loss they
    suffered due to contamination.

    Shortly afterwards, the Basque and Aragonese Farmers’ Unions (EHNE and
    UAGA, respectively) arranged and paid for a notary to extract two samples of
    seed from a sealed pack of the same batch of soy seed that a farmer belonging to
    the Aragonese Council for Organic Farming (CAAE) had bought. The samples
    were sent to two different laboratories, which both detected GM material in the
    seed (even though Monsanto was persistently claiming the seed was not GM).
    This constitutes a case of contamination of imported seed as the batches came
    from the US.

   Different analyses undertaken in 2008 revealed the presence of genetic material
    of two varieties of GM maize, one withdrawn from the market in 2005, in five
    farmer varieties of maize in the seed bank held by the Catalonian Centre for the
    Conservation of Cultivated Biodiversity (Centro de Conservación de la
    Biodiversidad Cultivada de Cataluña). The seed had been gathered by an organic
    farmer. Analyses of the crops in the field had not detected GM material. One of
    the 5 contaminated varieties, known as “embrilla”, had been cultivated by the
    farmer for over 15 years. Another case was that of a variety known as “queixal”
    in Catalonia that formed part of the collection held in the Esporus centre for
    biodiversity conservation (Binimelis, 2008).

   During 2006 a group of social movements organised a campaign of analysis of
    conventional and organic maize crops of some 40 farmers in Catalonia and
    Aragon. Contamination of between 0.07% and 3.8% by GM maize MON810
    and Bt176 was detected in different localities (see Table below). In three cases,
    the contamination affected local farmer varieties of maize and thus, following
    years of gradual selection, the seed could not be used. This clearly demonstrates
    that the contamination of local farmer varieties is a crime against biodiversity as
    use of the few varieties that are still held in usufruct by farmers themselves
    becomes impossible.

   In 2002 the English organization, Soil Association, published a report on the
    experience of US and Canadian farmers following six years of GM cultivation
    (Soil Association, 2002). Even at that early stage the following results were
    found:

       o Generalized contamination by GMOs in North American sources of
         conventional soy, maize and canola seed
       o Contamination of seeds by unauthorised transgenic material, which led
         to withdrawal from the market at extremely high cost.
       o Higher costs for organic farming due to the need to introduce new
         measures to try and prevent contamination and certify seed as GM-free
       o Abandonment by most organic farmers of cultivation of organic canola
         in Saskatchewan, Canada, amongst other reasons because it was almost
         impossible to acquire GM-free seed
              o Documentary evidence of contamination of seeds due to cross
                pollination, accidental mixing of seed and remnants of GM material in
                different shared farm machinery.



Summary of contamination of maize in Catalonia and Aragon, 2006

          Parish (Province)             Field location      Conven/    Transgene        %
                                                            Organic                contamination

1         Linyola (Lleida)              Area 15, Plot 43    Conven.    MON 810
                                                                                   2,6
          Almenar (Lleida)              Area 13, Plot 56.   Organic    Bt 176      0,15
2ª                                      Upper righthand      Local
                                        area                variety
          Almenar (Lleida)              Area 13, Plot 56.   Organic    MON 810     0,33
2b                                      Lower lefthand &    Local
                                        centre              variety

3         Arbeca (Lleida)               Area 18, Plot 14    Conven.    MON 810     3,8

4         Bellcaire d'Urgell (Lleida)   Area 14, Plot 98    Organic    MON 810
                                                                                   0,9

5         Bellcaire d'Urgell (Lleida)                       Conven.    MON 810
                                                                                   0,07
          Albons (Girona)               Area 4, Plot 48,    Organic                12,6
6
                                        Subsector 1.
          Gurrea de Gállego                                 Conven.    Bt 176
7a        (Huesca)                                          Local
                                                            variety                2.0
          Gurrea de Gállego                                 Conven.    Bt 176
7b        (Huesca)                                          Local
                                                            varietyl               0,2



Cases exposed by the CAAE


          Boquiñeni (Zaragoza)                              Organic    MON 810     1,90
8
                                                                                   0,41
          Quinto de Ebro (Zaragoza)                         Organic
9
                                                                                   0,23
          Huerto (Huesca)               Area 101, Plot 6    Organic
10
                                                                                   0,03


Source: Assemblea Pagesa eta al., 2006.


         Any analysis of the information available on the Internet reveals the degree to
         which contamination of seeds by transgenes has increased and that
         multiplication of seed for commercial sales is being transferred from North
         America to other continents.

        Lastly, the contamination of local maize varieties by GMOs in Mexico should be
         mentioned given the serious socio-economic implications it has for the agro-
         genetic heritage of that country and the planet in general and for maintaining
         and/or working in favour of food sovereignty. The case of contamination of
         Mexico’s maize is well documented on the Internet.
Numerous studies and manuals indicate the difficulties involved in saving pure seed and
the different measures that are adopted to be able to do so. Some of these measures are
only possible in small-scale farming. Other measures only work when all sources of
contamination are completely absent, particularly in the case of industrial farming. (See
EHNE, 2007 and the different references quoted in the same report, which also
mentions the problems that transgene varieties could cause in wild plant biodiversity).
The conclusion reached when bearing in mind most of the available studies is that
guaranteeing 100% GM-free seed becomes impossible once GM varieties are cultivated
within the area in which non-GM seed is produced.

The problem is becoming complicated by the growing monopoly exercised by
transnational companies in the seed market, as these withdraw those non-GM varieties
that constitute viable alternatives to their GM varieties from commercial catalogues, a
practice that is being detected in the Spanish Member State (Binimelis, 2008).


   3. The impact of MG crops for those farmers that cultivate them

Very little information has been made publicly available concerning the practical results
of using GM varieties for the farmers that have sown them in the Spanish Member
State. Thus the only data located, or at least readily accessible, refer to the surface area
cultivated with GM varieties and the price of GM maize, but no global, verifiable and
relevant data base has been found providing information on other important aspects that
would indicate the real impact of these crops throughout the Spanish Member State.

The organizations that have drafted this document would like to take the opportunity to
denounce the ethical implications of the way in which statistics concerning the surface
cultivated with GM varieties are currently made available and the fact that apparently
the Spanish government does not find this situation worth criticism. The relevant data is
provided by the seed companies and thus before being considered reliable should
undergo a process of verification, particularly when the seed companies are so
obviously manipulating their own data: for example, the Ministry of Agriculture (5)
calculates that GM maize was sown in a maximum of 79.269 hectares per year -
according to information provided by the seed companies- and yet, in the cartography
included in the annual reports of the same companies the Spanish Member State always
appears as a zone with more than 100.00 hectares of GM crops (James, 2008). This has
obvious implications for the adoption of this technology by other farmers.

Leaving this issue to one side, in order to undertake an appropriate analysis of the socio-
economic implications of GM varieties for those farmers that have cultivated them,
statistics and information on the following issues, amongst others, would have to be
gathered and made publicly available:

      on farm tendencies observed in the production costs (seed prices, quantities and
       costs of agro-chemicals employed…) of transgene cultivation

      information concerning the same parameters for cultivation of conventional and
       organic varieties of maize (in the case of the Spanish Member State) for
       comparison
        the tendencies observed in the yield of each field of GM maize, in both kilos or
         tons per hectare and euros per unit of harvest.




5.Data from the Ministry of Agriculture according to declarations of sales of seed .
        the results of monitoring the development of resistance of the corn borer to the
         Bacillus thurengiensis toxin introduced in the transgene varieties of the
         MON810 event.

        Cartography of the real incidence of the corn borer observed each year.



3.1. Practical data located concerning the Spanish Member State

A little data concerning some of these parameters has been located for some
geographical areas, but no complete, global set of statistics has been found for the
whole of the Spanish Member State. It is not very clear how to interpret this failure in
the search for data concerning the practical results of GM farming in the Spanish
Member State:

        Data is perhaps published but in archives that are extremely difficult to locate (in
         which case we would be very grateful to know which and where they are).

        Data is not published for the simple reason that it does not exist

        Data is not published because it is not of interest to do so for certain economic
         stakeholders

This situation is unacceptable under any of these circumstances given the implications it
has not only regards a lack of transparency, but also because it means civil society
cannot access one of the best instruments for adequately evaluating the impact of
introduction of transgene agriculture from a global point of view.

Needless to say, the little information and data that have been located reveal worrying
aspects in terms of socio-economic implications of cultivation of, in this case, GM
maize, as can be observed in the results of two as yet unpublished studies on the
outcome of cultivation of GM maize in Navarre (Mauleón, J., 2009a, 2009b). Based on
information and statistics supplied by farmers, cooperatives and the Navarre
Agricultural Research Institute (ITGA), these studies show that:

        A large number of different GM maize varieties are used in the La Ribera area in
         the south of Navarre and varies from year to year. Seven of these GM varieties
         were monitored over three years to calculate their average index of production,
         with the following results:
           o The Index of only 4 of these 7 varieties surpassed 100 (in other words,
             had higher yields than control varieties that were conventional or
             isogenic)

           o One of the GM varieties with highest sales (Jaral BT, 12.9% of sales)
             gave lower yields than the control varieties.

           o One of the GM varieties that gave highest yields per hectare was not
             popular with farmers (2% sales in 2008)

           o The highest yielding GM variety only surpassed non-GM varieties by
             3.5%

      The average cost of MON810 seed is higher than the cost of non-GM seed. This
       fact confirms the information offered by other authors: in the Spanish Member
       State, the price of GM Bt maize seed has increased by an estimated 20% or 36
       euros /hectare, although other authors quote a price increase of 38 euros per
       hectare (Gomez-Barbero, 2006).

      The number of farmers that sow a margin of conventional maize around their
       GM crops does not reach 10% of all farmers using GM maize

      GM maize harvests do not have a price premium, in fact they have no advantage
       in the market and are sold mainly for livestock feedstuffs (see section 2.3).

      The people interviewed in these two studies “considered” GM varieties to be
       efficient against the corn borer, but:

           o Were worried by the development of resistance of the corn borer to the
             Bt toxin

           o The corn borer does not pose a serious problem in Navarre, neither every
             year nor throughout its territory. Information provided in other studies
             indicates that use of insecticides against the corn borer has always been,
             in any case, practically non-existent in Spanish maize cultivation
             (Brookes, 2007).

      Transgene agriculture has not changed the dependence of farmers on the
       subsidies they receive to be viable (in terms of the profitability that the EU
       demands) and which amount to roughly 30% of their income.

There are signs that the same process that has already occurred in those countries with
large areas cultivated with transgenes is now affecting the Spanish Member State. As
the seed market becomes increasingly concentrated in the hands of just a few
companies, once transgene crops have been introduced, the seed companies reduce the
range of quality conventional seed they sell. This seems to be happening already in
Catalonia and Aragon (Binimelis, 2008). There are evident implications for the farmer’s
right to choose which production model to develop on his or her farm.
Additionally, studies undertaken by the EU Joint Research Council (for example,
Gómez-Barbero, 2008) have not shown that GM MON810 maize guarantees higher
yields in the areas in which it has been cultivated in the Spanish Member State. The
information gathered in interviews with farmers (which, again, needs to be verified),
showed that the yield of GM maize was not higher than that of conventional maize in
two of the three provinces analysed.

The little information that has been found suggests that GM maize varieties have serious
economic implications for the very farmers that cultivate them in the Spanish Member
State. Basically, there are many cases of farmers that buy a technology they do not need,
with higher costs in seeds, yields that are equal or even lower than non-GM varieties
and that do not reach a higher price in the market (and in fact may be lower according to
the final destination of the maize) and a gradual loss of access to non-GM seed.

Equally, farmers are not appropriately informed about the correct management of GM
crops and are being identified as the cause of conflict with neighbouring farmers (see
section 4) when contamination is detected. The Gómez-Barbero study (2008) also
concluded that farmer acceptance of GM seeds would be seriously diminished should
measures be introduced to try and guarantee coexistence between GM and non-GM
crops. The researchers called for further studies into the acceptance of these crops
should the costs of coexistence measures be borne in mind. Thus, transgene seeds are
being used in agriculture in the Spanish Member State mainly because of the pressure
exerted by multinational seed companies and because, due to a lack of legislation, their
production costs do not include those of guaranteeing protection of conventional and
organic crops.

Lastly, the Gómez Barebero study declares that any economic advantage gained by
farmers cultivating GM maize is a result of spending less money on insecticides.
However, only 5% of the surface area cultivated under maize in the Spanish Member
State was treated with insecticides to combat the corn borer prior to the introduction of
GM Bt maize (Brookes, 2007).

At this point it is worth raising a question for both farmers and consumers: is it worth
continuing to authorise cultivation of GM crops bearing in mind the almost if not
completely nonexistent advantages of GM crops in terms of improved yields for the
farmers that sow them, particularly when compared with their risks and socio-economic
implications (as documented in the present report) for those farmers that do not wish to
cultivate GM varieties, for the consumer population that does not wish to eat GM food
and for the environment of the public as a whole?


3.2. The experience of farmers cultivating GMOs in non-EU countries

Given the scarcity of practical information referring to the socio-economic implications
of GM crops for those farmers that cultivate them in the Spanish Member State, the
organizations that have drafted this document have collected theoretical and practical
information from other geographical areas to complement that presented here. The data
that has been located more than confirms the tendencies observed in the above
mentioned report on transgene farming in Navarre.
Data issued by different private and public bodies that have monitored the 13 years of
transgene agriculture in the USA, including statistics made public by the US
Department for Agriculture, reveal worrying tendencies for the very farmers that have
employed this technology:

      Production costs are higher for GM crops:

          o GM seed is more expensive than conventional seed

          o more agro-chemical products are used per hectare of GM crop than per
            hectare of conventional crop and are more expensive

      Average yields of GM crops are not higher than those of conventional crops

      GM harvests sell at a lower price than conventional harvests.

Some examples are quoted here, based on the documents mentioned above which are
generally based on information provided by the US Department of Agriculture. They
clearly illustrate some of the socio-economic implications of GM crops:

      In the 25 years between 1975 and 2000, the price of conventional (non-GM) soy
       seed rose 63%. In the 9 years since 2000, by when GM soy seed dominated the
       market, the overall price of soy seed rose by 230%. Specifically, US farmers
       who buy GM “RR2” soy seed from Monsanto in 2010 will pay 42% more per
       batch of seed than in 2009, in other words only one year later.

      Farmers who buy and sow the new GM maize variety “SmartStax” will pay over
       double the price of non-GM seed.

      GM cotton seed cost six times more than non-GM seed. Between 1975 and
       1996, the price of cotton seed doubled, whilst since the introduction of GM
       cotton, seed prices rose from $73 to $589.

      Farmers that sow transgene seed are forbidden to save seed for the next growing
       season and, thus, every year must buy new seed from the seed companies, the
       price of which includes an enormous technology “tax”. At the same time, it
       should be borne in mind that as farmers stop sowing and saving their own seed,
       this gradually loses its capacity to germinate whilst it is also increasingly
       difficult to find and acquire non-GM seed in the market and, so, a return to non-
       GM farming using farm saved seed or seed bought on the market is increasingly
       complicated.

      Between 1975 and 1997, soy farmers spent between 4 and 8% of their gross
       income on seed, whilst in 2009, GM soy farmers spent 16.4% of their gross
       income on seed. In 2009, GM maize farmers spent 19% of their gross income on
       seed, the equivalent of 39% of their production costs per hectare, more than
       double the proportion prior to the introduction of GM farming.

      These huge increases in the cost of seed would pay off if other production costs
       were lowered (or yields and the price paid for the harvest increased). However,
       the use of agro-chemicals in US farming, rather than falling, has increased
       significantly. The use of herbicides on transgene crops has increased by 144.4
       million kilos since the introduction of GM cultivation in 1996. Specifically, in
       2008, 26% more pesticides were used per hectare of GM crops than per hectare
       of non-GM crops.

      Lastly, it should be emphasised that the data collected by the US Department of
       Agriculture itself shows that, on average, GM varieties do not give higher yields
       than conventional varieties. Equally, there has been no case of companies such
       as Monsanto guaranteeing higher prices for harvests of GM crops and, in fact,
       farmers that cultivate GM varieties have lost whole markets (a very clear
       example being that of the European market for canola) and, thus, income.

As such, transgene agriculture is generating a huge transfer of money from farmers to
genetic engineering companies because of the dramatic increase in the price of different
inputs that have to be bought for GM crops (Amigos de la Tierra -Friends of the Earth-,
2009; Benbrook, 2009b). This tendency has enormous social and economic implications
(loss of economic sustainability in agriculture, increased dependence on seed and
agrochemical companies, loss of environmental sustainability, weakened options for
food sovereignty…) and should make us ponder the question in Europe. The fact that,
after 13 years of GM cultivation, the surface area sown with GM varieties, particularly
RR soy, is beginning to fall in the US should also make us think.



3.3. The development of resistance to agro-chemicals

This situation is further complicated by secondary and, according to the genetic
engineering companies, unforeseeable repercussions of the technology. The huge
increase observed in the amount of herbicide applied in transgene crops is mainly due to
the appearance of uncultivated, wild plants (“weeds”) that have become resistant to
herbicides. Bearing in mind that formal applications have been made for the
introduction of herbicide tolerant GM varieties, specifically glyphosate tolerant
varieties, in the EU in the near future, it is important to analyse what is happening in
other countries where such crops have been introduced:

      During the first 3 years of GM cultivation in the USA, the amount of agro-
       chemicals applied per hectare of GM crops decreased, but since 2000 the
       amount has steadily increased. There are already 9 species of “weeds” in the US
       that tolerate (are resistant to) “glyphosate”, the herbicide to which the GM
       varieties most cultivated in the USA are tolerant.

      The reaction of the farmer is:

           o   To apply additional active ingredients to crops
           o   To increase the amount of active ingredient applied
           o   To increase the number of times herbicides are applied
           o   To increase dependence on ploughing and tilling to control “weeds”
           o   To manually remove weeds (literally “to weed”)
    All of these options imply higher costs of production and some of them also
    imply greater presence of toxic residues in soils, the water cycle and harvests.

    Two examples of the many plant species that have developed resistance to
    herbicides and the implications of this development are described below:

       o carelessweed (Amaranthus palmeri) that has developed resistance to
         glyphosate has spread dramatically throughout the south of the USA
         since the first resistant plants were reported in 2005 and now poses a
         serious threat to US cotton crops. The degree of infestation is so bad that
         in some cases cotton producers have had to abandon farmland or use pre-
         industrial methods of eliminating weeds mechanically with a mattock.

       o Erigeron or fleabane (Conyza canadiensis) is the most widely spread non
         arable plant that is resistant to glyphosate. It was first reported in
         Delaware in 2000 and by 2009 had invaded several million hectares in at
         least 16 states in the South and Midwest of the USA, particularly in
         Illinois. The proliferation of C. canadiensis and the other 8 glyphosate
         resistant “weed” species is not only resulting in applications of greater
         amounts of the said product but also an increase in the use of more toxic
         herbicides, including paraquat and 2,4D, a component of the Orange
         Agent used in the Vietnam war as a defoliant.

   In Argentina in 2007 the surface area under GM soy crops reached 16.5 million
    hectares, three times the area existing in 1995/6. Apart from deforestation of
    woodland and savannas, areas that were previously grazed or used to produce
    important food crops such as maize, sunflowers, sorghum and wheat are now
    being turned over to GM soy (Benbrooke, 2005), with important consequences
    for food security and sovereignty. The rapid expansion of soy has been
    accompanied by soil erosion, a progressive loss of family farms and the
    concentration of land ownership in fewer and fewer hands (Loensen, 2005).

    It is estimated that since the introduction of GM soy, the use of glyphosate has
    increased threefold between 1999 and 2006 in Argentina. But it is also important
    to note that during the same period, the use of other herbicides such as 2,4D
    increased spectacularly aswell, which proves that the increase in the use of
    glyphosate is not substituting other herbicides (Benbrooke, 2005). The National
    Service for Agriculture, Food, Health and Quality of Argentina (SENASA) has
    calculated that, in 2007, approximately 120.000 hectares of GM soy crops had
    been invaded by glyphosate resistant “weeds” (Amigos de la Tierra, 2008).

   In the case of Brazil, according to data provided by the Brazilian government’s
    Institute for the Environment (IBAMA), use of the 15 main active ingredients of
    the most used herbicides in soy cultivation rose by 60% between 2000 and 2005.
    The use of glyphosate rose 79.6% in the same period, increasing more rapidly
    than the increase in the hectarage cultivated with GM Roundup Ready soy
    (Amigos de la Tierra, 2008). In 2005 and 2006, another three species of “weeds”
    developed resistance to glyphosate in Brazil. The Brazilian Agency for
    Agricultural Research (EMBRAPA) has already admitted that glyphosate
       resistant “weed” species constitute one of the major threats for farming in the
       country (Cerdeira, 2007).

It should thus be emphasized that, apart from all the other negative socio-economic
implications of GM crops for farmers that cultivate them mentioned in the present
document, the technology developing herbicide tolerance is generating a series of
problems for the control of wild, non-arable plants that the very same farmers will have
to face in the short and medium term.


3.4. The failures of Bt technology

Spanish farmers (and those from other countries) that cultivate MON810 maize (and
those farmers that, in the past, cultivated Bt176 maize) are employing a technology that
has not been sufficiently researched nor has sufficient guarantees concerning the
possible secondary impacts it is generating, with a series of agronomic, economic and
social implications for the near future.


3.4.1. Lack of knowledge concerning the concentration of the Bt toxin in MON810
maize

There are certain doubts concerning the exact concentration of the Bt toxin in crops that
have been genetically modified to incorporate it. MON810 maize has been genetically
modified to produce a modified insecticide (Cryl Ab) that is synthesized in nature by
the soil bacteria Bacillus thuringiensis (Bt). Information concerning the exact
concentration of the Bt toxin in MON810 maize plants has rarely been published.

A review of the relevant literature on MON810 Bt maize reveals that, today, the exact
concentration of Bt produced by these crops is unknown, despite having been cultivated
during a decade. There are very few studies concerning the environmental impact of
transgene plants nor data concerning how the concentration of the Bt toxin evolves in
real life conditions of commercial crops (as opposed to experimental plots). As such,
one is led to believe that Bt plants produce stable and consistent levels of the Bt toxin
that are independent from environmental impacts or specific genetic conditions (6).

A 2007 report by Nguyen & Jehle (7) on the production of Bt by MON810 plants
reveals important variations between individual plants and significant differences
between different fields. The concentration of the Bt toxin also varied with the seasons.

In May 2007, Greenpeace published a report summarising analyses in specialized
laboratories of a series of samples of Monsanto’s MON810 transgene maize in the
Spanish Member State and Germany (8). More than 600 samples from 12 different
fields were analysed: the samples were gathered between May and September/October,
weekly in two fields in Bavaria and four in Bradenburg and fortnightly in five fields in
the Spanish Member State. Additionally, three samples were taken three times a week
from an experimental plot run by Monsanto in North Rhine-Westphalia between July
and August, 2006. The samples were gathered at a greater frequency than the Nguyen &
Jehle study, in order to obtain a clearer picture of any changes over time.
6. Monsanto, 2000. Safety assessment of Yieldgard insect-protected event MON810. Published by
agbios.com as Product Safety Description. http://agbios.com/docroot/decdocs/02-269-010.pdf
7. Nguyen, H.T. & Jehle, J.A. 2007. Quantitative analysis of the seasonal and tissue-specific expression
of CrylAb in transgenic maize MON810. Journal of Plant Diseased and Protection, 114(2): 820-87
8. How much Bt toxin do genetically engineered MON810 maize plants actually produce?
http://www.greenpeace.org/espana/reports/que-cantidad-de-toxina-bt-pro
The research showed tremendous variations in the concentration of the Bt toxin in the
experimental plots, with differences of up to a factor of 100 in plants of the same plots.
This research confirmed the results of the Nyugen & Jehle study, which concluded that
“monitoring of the expression of CrylAb has shown that this varies greatly between
different individuals”. The variation found by Greenpeace was even higher than that
found by Nyugen & Jehle. Greenpeace also found continuous change in the
concentration of the Bt toxin during the growing season, with maximum levels in July
and August.

As a result, concentrations of the Bt toxin do not correspond to the statistics concerning
concentrations of the Bt toxin that Monsanto submitted in order to obtain gain
authorisation for cultivation in the USA, a fact that raises some far-reaching questions
concerning the security and technical quality of MON810 plants and basic
methodological principles.


3.4.2. The development of resistance to the Bt toxin

The development of resistance by targeted insects is considered to be one of the major
socio-economic risks of commercial cultivation of transgene plants, in this case for the
very farmers that are cultivating Bt varieties.

The MON810 maize cultivated in the Spanish Member State expresses the Bt toxin
throughout most if not all the plants’ life cycle which thus implies continuous presence
of the insecticide toxin in large areas and during a long period of time. As such, it exerts
a huge pressure of selection for unwanted resistant insects, one of the biggest such
processes of selection that has occurred in the history of agriculture (9).

Strategies to manage resistance have to be introduced to maintain the efficiency of the
insecticide in these plants, basically to try and prevent or delay adaptation by pest
insects. The main such strategy in Bt crops is the so-called “high dose/refuge” strategy,
based on the theory that using plants with a sufficiently high concentration of the Bt
toxin will kill even resistant insects and that maintaining a refuge of non-Bt maize
around Bt fields in which insects reproduce will permit random crossing between
resistant and non-resistant insects.

However, various agroecological factors may influence the success of this strategy in
the Spanish Member State, particularly the following:
9. De la Poza, M. (2004). Maíz Bt: seguimiento de la resistencia de Sesamia nonagrioides (Lepidoptera:
Noctuidae) y Ostinia nubialis (Lepidoptera: Crambidae) y efectos en artrópodos depredadores. Tésis
doctoral. Universidad Politécnica de Madrid. Escuela Técnica Superior de Ingenieros Agrónomos.



       In the Spanish Member State, most transgene maize is irrigated and in such
        fields mobility of the European corn borer (Ostrinia nubialis) is reduced before
        laying eggs and the existence of the refuge maize therefore loses efficiency (10).

       Females of the Mediterranean corn borer (Sesamia nonagrioides) mate before
        moving to lay eggs and thus the frequency of females from the refuge maize
        mating males from the Bt maize and vice versa would be very low (11).

        The amount of Bt toxin expressed in MON810 maize varies enormously from
        field to field, from plant to plant within one given field and throughout the
        growing season (12), as also concluded in the Greenpeace 2007 study quoted
        above. This means that the condition that Bt plants eliminate at least 99.99% of
        target insects in Bt crops (high dosage) is probably not being fulfilled, thus
        reducing the efficiency of the high dosage / refuge strategy (13).

Some of the other problems that have been detected are:

       Lack of strategies adapted to regional conditions, lack of information for farmers
        concerning the importance of maintaining refuge zones and lack of systematic
        monitoring of crops for early detection of resistance.

       Lack of information and monitoring: due to the interest the genetic engineering
        (GE) industry has had to introduce this sort of crops to Spanish farms as quickly
        as possible, the information given to farmers concerning the need for refuge
        zones has been reduced to a minimum and there is no control over the degree to
        which they are acting on the recommendations given on this matter. Public
        authorities have simultaneously left this matter in the hands of the GE
        companies and abstained from providing information and/or monitoring
        fulfilment of recommended measures.

       There has been no systematic, widespread programme for the early detection of
        resistance, a vital element for the prevention of resistance and it is hard
        (impossible in some cases) to access the results of any monitoring that has taken
        place and which have not been published in the Ministry for Agriculture’s
        website nor are available in the Ministry’s information outlets on this issue (see:
        http://www.mma,es/portal/secciones/calidad_contaminacion/omg)

Bt varieties have been introduced in the National Register of Plant Varieties – the
equivalent of an authorisation for commercial sowing – without prior drafting of their
obligatory Monitoring Plan which, according to the Order for the register of such plants
“should be presented at the latest two months since the publication of the current Order”
10. De la Poza Gómez, op cit.
11. De la Poza Gómez, op cit.
12. Nyugen & Jehle, op cit.
13. On the question of the 99.99% limit, see Tabashnik, B.E., van TEnsburg, J. B. J. & Carrière, Y.
(2009). Field-evolved Insect Resistance to Bt crops: Definition, theory and Data. Journal of Economic
Entomology, 102(6): 2011-2025.

(14). This has meant that, in some cases, Bt varieties have very probably been sown
before such a Monitoring Plan was approved, which is very irregular and makes the
efficiency of the Plan itself very doubtful in at least the first year of commercial
cultivation.

Equally the secrecy that has surrounded the authorisation of these Monitoring Plans–
which have not been made public – in the Spanish Government and the absence of
information concerning their results has made the public participation that is necessary
in monitoring impossible, thus reducing the efficiency and legitimacy of the process.
The little information available concerning the results of Monitoring Plans has only
been provided by the Spanish authorities after direct and repeated requests by some of
the farm and environmentalist organizations that undersign the present document who
had to recourse to the legislation on the right to information, or has been published in
specialized scientific journals that are inaccessible to most farmers and the public at
large.

The 2006 study by Catangui et al. states that “Cry1Ab Bt maize favours the survival of
the western corn borer (effectively eliminating competition from the European corn
borer). In the future the ecological impacts of Bt maize hybrids on numerous species of
insects associated with maize production should be researched, as well as researching
the borer pest that they wish to combat. Although considerable amounts of time and
resources have been invested in prolonging the utility of transgene crops against pests,
almost no research has been undertaken into the new pests that have appeared in such
crops or potential pests in the future”. (15).

The proliferation of secondary pests in Bt cotton crops in China meant the initial
benefits reported for these crops soon disappeared (16).

The Monitoring Plan for Bt crops in the Spanish Member State requires monitoring of
“Possible effects on entomofauna and soil microorganisms in fields sown with these
varieties”. Between 2000 and 2003 a team from the Council for Scientific Research
carried out studies that monitored the population of predatory insects in Bt crops in
which no adverse impacts were observed. These studies are important but insufficient
and their conclusions should be confirmed by wider, longer term studies to evaluate the
impacts of large scale cultivation of Bt varieties on ecosystems and the possible
appearance of other pests. This research is perhaps being undertaken, but as in the case
of monitoring of resistance, the complete lack of transparency of the Spanish
government regarding these issues means no relevant information is available.
14. See the Order for the register of Bt MON810 varieties in the Official Papers of the Spanish
Government
15. Catangui M.A. & Berg R.K. (2006) .Western bean cutworm, Striacosta albicosta (Smith)
    (Lepidoptera : Noctuidae), as a potential pest of transgenic Cry1Ab Bacillus thuringiensis corn
    hybrids in South Dakota Environmental Entomology 35 1439-1452.
16. Wang, S., Just, D.R., Pinstrup-Andersen, P. (2006) Tarnishing Silver Bullets: Bt Technology
Adoption, Bounded Rationality and the Outbreak of Secondary Pest Infestations in China. Selected Paper
prepared for presentation at the American Agricultural Economics Association Annual Meeting Long
Beach, CA, July 22-26, 2006.
3.5. The implications of the current inability to draw up insurance policies to cover
the risks involved in GM farming

According to a study undertaken by the Complutense University of Madrid and
published by the MAPFRE Foundation and the Institute for Insurance Science (Corti,
2008), it is not currently possible to consider developing an insurance policy that would
cover the environmental and economic risks of GM crops. This confirms previous
studies undertaken by Munich RE, Swiss RE and the European Committee for
Insurance.

A detailed analysis that was orientated towards obtaining a practical vision of both
Directive 2004/35/EC and the Spanish Law on environmental responsibility, confirmed
that despite appearances, the practical application of these legislations in the context of
GM crops is rather limited, firstly because, the concept of Environmental Damage is
very restrictive; secondly, due to all the exemptions included in the law, particularly
those related to damage to property and cases in which no causal relationship can be
established in diffuse damage; and, lastly, because the subject causing damage can elude
any sort of responsibility for paying costs of amendment in the (frequent) cases of
authorized emissions and “damage to development”.

Although the system of obligatory guarantees introduced in Law 26/2007 foresees the
possibility of, for example, obligatory insurance policies, it relegates their obligatory
constitution to only those activities the environmental impact of which could provoke
high costs of amendment. A first problem related to introducing monetary limits to the
obligatory constitution of obligatory guarantees is, thus, prior quantification of the costs
of amendment. Additionally, in the case of GMOs, that are included in the second
category (damage between 300.000 and 2 million euros), environmental audits are also
placed at a disadvantage due to the lack of clear criteria of coexistence that define the
obligations of farmers in the isolation of GM crops.

The study showed that the risks of GM crops can be classified into economic and
environmental risks and that the latter can be classified between those that are covered
or not covered by Directive 2004/35/EC. With regards to GM maize and the
environmental risks covered by Directive 2004/35/EC, there are scientific studies that
demonstrate that Bt spores affect beneficial insects (butterflies and bees) and soil micro-
organisms and that improper use of glphyosate can lead to contamination of ground
water.

Examples of environmental risks outside the remit of Directive 2004/35/EC include the
development of resistance in wild plants (“weeds”) due to overuse of a sole herbicide,
glyphosate and impacts in beneficial insects that are not linked to the Nature 2000
Network. Finally, economic risks or those related to coexistence include the risk of
impurities in seeds, cross pollination, mixture of seed in drills, harvesters and storage
units, whilst there is a last category of risk that could be denominated “juridical” that
special norms of responsibility are trying to solve.

It can be concluded that there is no clear evidence that a secure policy can be created,
even for exclusively economic risks. The absence of uniform criteria regards
coexistence measures could alter scientific models for quantifying risk and imply the
need for laborious individual studies of adaptation. Additionally, the astronomical costs
involved in the necessary study and preparation of each policy means the marketing of
this type of insurance would not be viable in economic terms.

For all these reasons, which confirm the studies undertaken by Munich RE, Swiss RE
and the European Committee for Insurance, it can be concluded that it is not currently
possible to consider drawing up an insurance policy that covers the risks derived from
GM cultivation, whether environmental or economic. In the former case, the problem is
the absence of the relevant scientific information for calculating the risk to be covered,
an absence that cannot be filled by applying existing statistics. In the second case,
although there is sufficient scientific information and it would be possible to cover the
damages, the absence of clear rules for coexistence hinder calculations to demonstrate
the economic viability of a policy. The socio-economic implications are clear.


4. Social conflict generated by the introduction of GM crops

The introduction of GM crops has generated a series of social conflicts, not only due to
the intrinsic characteristics of these crops but also because of the context and the way in
which they have been introduced.

4.1. In farming

During the last decade, the introduction of transgene agriculture has exacerbated
divisions and confrontation between farmers, who have to bear responsibility for the
risks and problems caused by transgenes, whilst the companies that introduced these in
the first place merely look on. The feelings perceived in farming areas are a certain
degree of fear and a great deal of worry. Consequently, many farmers and farm
cooperative managers and workers prefer not to express their opinions nor make
comments on their experiences with GMOs, something the GE companies and pro-GE
politicians use to claim that the use of transgenes has had no negative social
implications.

This situation is documented in scientific research by, for example, the Autonomous
University of Barcelona (Binimelis, 2005, 2008), which has identified several sources
of conflict caused by transgenes in rural areas.

To start with, it should be stressed that when a farmer’s non-GM crop is contaminated
by GM material, it is practically impossible to establish exactly which GM crop is the
cause and, thus, which farmer is responsible. As there is no public register of GM crops
nor are data of farmer CAP declarations made public, farmers that suffer contamination
cannot identify its source.
The studies conclude that when a farmer’s crop is contaminated in an area of relatively
widespread GM cultivation, it is extremely difficult to establish a causal relationship to
know exactly which field the contamination came from.

Binimelis (2008) also documents the fact that some farmers whose fields that have been
contaminated have not dared to make an official complaint due to pressure applied by
seed companies. This pressure is also a result of the social context in which GM crops
have been introduced, with use of concepts such as “modernization” and “application of
technology”). The tension between intensive high production farming models and more
environmentally respectful farming practices generates tension in rural areas. There is
still prejudice against organic farming in rural areas and lack of social support is one of
the main reasons why younger farmers do not enter organic farming.

The introduction of transgene seed is critical in this context because it creates conflict
regards the responsibility of those farmers that cultivate GMOs and, yet, existing
legislation transfers costs and responsibility to the victims of contamination.

As a result many farmers affected by cases of contamination do not make an issue of it
in areas such as small rural villages and parishes where a high degree of social cohesion
is necessary. Farmers renounce conflict with their neighbours, which could mean taking
them to court, as this would mean conflict with their former school mates, life long
neighbours, kin, etc.


4.2. In scientific circles

The almost systematic defamation of any scientist that questions the profitability,
security and ethics of GM crops in any publication or proposed publication of results of
their research is causing important conflicts within and outside scientific circles and has
important socio-economic implications regards the degree of control that the big
companies that promote genetic engineering have and the pressure they apply in this
field. The cases of Arphad Puztai of the Rowlett Institute, Ignacio Chapela of the
University of Berkeley, Richard Burroughs of the US Food and Drug Agency and Shiv
Chopra of Health Canada are well known but are not the only ones. In order to prevent
the total disappearance of all research orientated towards the independent monitoring of
GM crops, this practice requires an urgent and decisive response from public
institutions.


5. Implications for the right of consumers to GM-free food

Both transgene crops as such and the legal context in which they have been introduced
have clear socio-economic implications for consumers. These can be summarised as the
loss of the right of consumers to eat GM-free food. This question is analysed in the
document entitled “Statement concerning the lack of legal protection of GM-free
(genetically modified free) farming and food” drawn up by farm and social
organizations from the Spanish Member State (Amigos de la Tierra et al., 2009) and
recently presented to the Spanish Ombudsman.
Apart from their tremendous risks for both the environment and health, GMOs
constitute an unprecedented attack on the general public’s right to choose. In fact, they
represent a technological imposition of the sort that has not previously existed in human
history and reflect a general failing of democracy in our societies, in which an alliance
between big capital and techno-science is trying to dismantle any social resistance.

There have been many cases in which the rights of consumers have been attacked in the
Spanish Member State during the last decade of transgene cultivation. A clear example
is provided by the information gathered in an interview with Fernando Llobell,
President of the Association of Organic Consumers of Albacete “La Tierrallana” which
works to further the interests of organic and environmental consumers (Greenpeace,
2008).

410 families are members of “La Tierrallana” Cooperative because of the opportunity
the Cooperative provides to eat food containing no “poisons” (agro-chemical residues,
for example) or transgenes. The Cooperative also provides an opportunity for
guaranteed income for many farmers in the Castilla – La Mancha region of the Spanish
Member State. The Cooperative has received several prizes over the years, including the
Prize for the Best Spanish Organic Consumer Association and the Prize for Sustainable
Development of Castilla-La Mancha.

In his interview Mr. Llobell declared that “we wish to eat healthy food and protect the
environment. But we are also at the end of the food chain and we suffer problems
caused by transgenes, either because there is no supply of organic goods, or because
their production has become far more expensive”.

When asked about contamination by transgenes, Mr. Llobell replied that “The situation
is dramatic when, in a democratic country, the victims of contamination are those that
pay the consequences of a situation that that has been provoked by a multinational
company whose only objective is to eliminate any alternative to GM food production”.

“European institutions and the Spanish Government should not put public health and
protection of the environment at risk and relegate the general interest of those of us who
wish to eat without damaging the environment, in order to promote the interests of a
handful of agro-chemical multinational companies”.

This situation, that repeats itself throughout the Spanish Member State, is largely due to
European legislation that does not allow consumers to exercise their right to eat 100%
GM-free food. Apart from the absence of labels on livestock produce (meat, milk or
eggs, for example) from animals that have been fed with GMOs, processed foods can be
contaminated with up to 0.9% GMOs per ingredient without any indication as such on
their labels. This presence, which according to existing legislation should only occur
when a food company can demonstrate that it is “accidental”, is, in fact, generalized in
processed foods that contain maize and/or soy (for more information on the concept of
“accidental presence” and the lack of legal protection of those consumers that wish to
eat GM-free food, see Amigos de la Tierra et al., 2009, document available in English).

Various studies undertaken by the Ministry for Health and Consumer Rights (Agencia
Española de Seguridad Alimentaria y Nutrición, 2006), the Basque Government
(Valcarcel, 2007) and civil society (Amigos de la Tierra, 2007), have shown that, in the
Spanish Member State:

      Between 15% and 17% of all foods on sale in supermarkets contain maize or soy
       that has been contaminated by GMOs. In most cases the degree of contamination
       is under 0.9% and there is thus no obligation for information to be made
       available on their label and consumers are not properly informed.

      Contamination of up to 0.9% has been detected in sensitive products such as
       baby foods and milks and others such as yoghurts, maize flour and starch,
       biscuits, meat products and pre-prepared dishes.

      Products have also been detected with over the 0.9% limit of GMOs and no
       indication as such on their labels, which do not thus conform to law. Examples
       include bread, biscuits and other bakery goods, meat products and maize flour
       and starch.

This contamination is the result of all the problems documented in the previous sections
of the present document, from cross pollination to lack of segregation of harvests, non-
existent traceability and lack of adequate controls by the authorities.

Additionally, the growing control of GE companies over one end of the farm-food
chain, seeds, means that the possibilities for consumers to choose which food to buy
according to the way in which it has been produced are diminishing, food being at the
other end of the farm-food chain.

Lastly, the organizations that sign the present document wish to denounce the lack of
monitoring of the health risks of transgenes. It is worth noting that the Monitoring Plans
of transgene crops in the Spanish Member State include no obligation whatsoever to
study the potential impacts of Bt crops for human health and one can only suppose such
monitoring is not taking place, a situation that, apart from contravening EC law on the
deliberate release of GMOs that requires such monitoring, puts human and livestock
health at risk.

The lack of monitoring of impacts on health is particularly negative when bearing in
mind that the authorisation of the MON810 event that is currently being cultivated in
the Spanish Member State is, at present, undergoing a process of re-evaluation, and that
a 2008 study has revealed that there is a high probability that the Bt toxin produced in
MON810 maize in the countryside is different to that used in evaluations of the impacts
of this GM maize (17). This would make most, if not all, of the trials undertaken to test
for the “security” of MON810 invalid.

Equally, given the possible introduction of glyphosate tolerant GM crops in the near
future, more independent research into the impacts of this product in human health is
urgently needed, both because of the agro-toxic nature of the product itself and to study
the impact of the agro-chemical in conjunction with specific GM varieties. (The
organisations that undersign this document are well aware that glyphosate is currently
used in conventional farming, but consider that this fact only further underlines the need
for greater research from the point of view of both human health standards and
environmental contamination).
17. Rosati, A., Bogani, P., Santarlasci, A. & Buiatti, M. 2008. Characterisation of 3 transgene insertion
site and derived mRNAs in MON810 YieldGard maize. Plant Molecular Biology DOI 10.1007/s11103-
008-9315-7.

6. Conclusions

The introduction of transgene crops has important socio-economic implications for:

       Arable farmers that cultivate GM varieties

       Arable farmers that wish to cultivate non-GM varieties

       Livestock farmers that wish to feed their animals with non-GM feedstuffs and
        maintain their end products free from transgenes (bee-keepers)

       Consumers who do not wish to buy GM food

The negative socio-economic implications of GM cultivation can be summarised as the
loss of the right to produce and consume GM-free food; loss of independence and
monetary losses for farmers that cultivate GM varieties; and a huge transfer of money
and power from farmers and consumers to those companies that control the genetic
engineering market.

Despite a frightening lack of information and the apparent reticence of public authorities
to analyse the socio-economic implications of GM cultivation, the economic data that
has been gathered points to a series of very negative socio-economic implications that
greatly surpass the economic benefits these crops give to four big transnational
companies, with absolutely no positive impact for the general public. The introduction
of transgene crops constitutes the ultimate consolidation of the industrial farm-food
model and condemns all other models to extinction, particularly agro-ecological
farming and food sovereignty.

The clear conclusion that is reached following analysis of available practical and
theoretical information is that all transgene varieties should be withdrawn from the
market in the European Union and existing legislation should be adequately reformed to
protect and promote the production and consumption of 100% GM-free food.




7. Summary of aspects of the European Commission questionnaire covered in the
present document

7.1. Economic stakeholders considered in the present document
Arable and Livestock farmers:
      - farmers cultivating GM crops;
      - and/or conventional crops;
      - and/or organic crops;
      - beekeepers;
      - seed producers producing GM seeds;
      - seed producers producing conventional seeds;
      - seed producers producing organic seeds;
      - livestock farmers that employ organic and/or conventional feedstuff

Seed industry:
       - seed producing farmers

Consumers
Cooperatives
Insurance companies
Scientists

Economic context:
     - local market
     - specifically, sectors linked to the maize market


7.2. Chapters of the European Commission questionnaire covered in the present
document

Farmers (impact of GM cultivation on):
   - farmer income (yield and prices of harvests)
   - production costs in agriculture
   - price differences for GM and non-GM harvests
   - availability and prices of seed
   - dependence on seed companies
   - farmers’ privilege
   - use of agricultural inputs
   - farming practices
   - conflicts in rural areas
   - labelling of harvests
Other impacts mentioned:
   - viability of non-GM farming methods
   - markets
   - food sovereignty

Seed industry (impact of GM cultivation on):
   - sales and income of seed companies
   - supply of seed (GM, organic and conventional)
   - seed markets (GM, organic and conventional)
   - protection of fitogenetic resources
Impact of marketing GM seed in the seed industry:
   - for the production and multiplication of non-GM seed
   - for availability of non-GM seed
Consumers (impact of GM cultivation on):
   - consumer freedom of choice
   - information made available to consumers and protection of consumer rights
Other impacts mentioned:
   - conflict and loss of confidence in food
   - food sovereignty

Food and feed industry (impact of GM cultivation on):
   - range of products available
   - costs-income
   - administrative difficulties (supply of raw materials)
Other impacts mentioned:
   - food sovereignty

Insurance companies:
   - drawing up insurance policies for GM crops

Research and innovation:
   - conflicts in scientific circles

Agronomic sustainability (impact of GM cultivation on):
   - the use of agro-toxics (pesticides and herbicides)
   - the development of resistance to Bt
   - Biodiversity (non-arable species and varieties)
   - Farm biodiversity

Other implications:
   - for the option of food sovereignty

Environmental sustainability/climate change/energy: see documents of our sister
European organizations




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