GM-Coexistence-and-Liability-Consultation

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					AEBC Consultation on Research Agendas in Agricultural Biotechnology Response from the Five Year Freeze December 2004

Executive Summary The Five Year Freeze welcomes the AEBC’s review of Agricultural Biotechnology Research. We feel that greater benefit would arise from this work if the review was as broad as possible and covered all food and farming research. Economic and social issues are equally important in determining what constitutes a sustainable system. Research needs to cover these. The FYF believe that political and corporate influence over food and farming research agendas are far too strong. Truly “bottom-up” research would involve far more public and farmer inputs and oversight. Research projects, such as the Farm Scale Evaluations and BRIGHT Project, should be carried out by independent institutions with no connections to industry. Industry should finance research which could assist with a commercial approval application but with no strings attached The Government should set out a clear vision of what a sustainable food and farming system would look like to give direction to research agendas across all disciplines – science, economics and social. Mechanisms for public input and oversight of all types of food and farming research are very limited at present and are tokenistic. Political and commercial influence over research agendas is too great and does not always work for the public good. Public involvement in setting the direction of scientific research and playing a role in overseeing it would improve the standing of scientific research in the UK which is somewhat tarnished at present. The scientific community needs to become far more open to public involvement and improve their methods for dealing with disagreements. The public are well aware of uncertainties and distrust scientists who make claims of certainty. Public research institutes carrying out commercial research should be required to place such contracts on a public register of interests. Public funding for sustainable food and farming research needs to be increased as a matter of urgency. Research programme need to be better co-ordinated than at present to ensure objectives and potential synergies are achieved without excessive bureaucracy. We suggest that this would be best achieved by establishing a new research council for this purpose.

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There is an urgent need to address how sustainable farming techniques can be quickly adopted by farmers. We believe the restoration of a free advisory and extension service would greatly assist in this process

The FYF The FYF is an umbrella campaign that was formed in February 1999. In February 2004, the members of the FYF decided to continue the campaign until the core demands of the campaign had been fully met. The demands of FYF remain the same as in 1999 and were again endorsed by the membership:          A system where people can exercise their right to choose products free of GM; Public involvement in the decisions on the need for and the regulation of GM; Prevention of genetic pollution of the environment; Strict legal liability for adverse effects on people or the environment from the release and marketing of GMOs; Independent assessment of the implications of patenting genetic resources; Independent assessment of the social and economic impact of genetic engineering on farmers; Prevention of harm to human health; Proper assessment of the impact of GM crops on the global food supply; Animal welfare to be prioritised when decisions are made about genetic modification of animals for use in food and farming.

There are currently 126 members of the FYF covering a range of public organisations, private companies and NGOs which span UK society. The Freeze is unable to sponsor any original research because of lack of finance.

Introduction When the Five Year Freeze was established in 1999, one of the overwhelming motivations behind those supporting the call for a moratorium on GM crop and food commercialisation was a recognition that our scientific knowledge of genetic modification and the potential impacts of GM products on people, farm animals and the environment was far too limited to warrant commercial approval of any GM crop or food. Successive opinion surveys over the iiiiii iv last seven years and the results from GM Nation? The Public Debate demonstrate that the majority of the public support this view. As the report on GM Nation? highlighted, the GM issue is unusual in that the more people know the more concerned they become. The Five Year Freeze called for broadly based research into sustainable farming in both its v original statement of concern and in its revised statement issued in 2004 . We therefore welcome the AEBC’s investigation into what drives the UK’s agricultural research agenda. We will address the specific questions posed by the AEBC later but first we would like to make some general comments.

General Comments How the land of the UK is managed has a profound effect on a large range of issues which impact on the quality of life for all citizens of the UK. Unlike farmers growing in other parts of the world, where huge tracts of land are turned over to intensive agriculture, the UK farmer is now expected to provide a range of goods and services. In the 1950s, 60s , 70s and 80s the major emphasis was on maximising production with minimum use of labour. To a large extent

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this ethos still prevails as farmers of all types are constantly being told that they need to be more competitive to gain greater access to world markets. However, farmers are also being directed to produce high quality products, connect with their customers, improve marketing, co-operate diversify, protect water supplies, reduce air pollution, enhance biodiversity, maintain the landscape, provide countryside access as well as becoming more efficient by cutting labour and input costs at the same time. Strangely, the Government persists is measuring the efficiency of UK farmers by the rather crude index of how much money is produced per £100 of investment. Farmers producing poor returns on each £100 invested are considered to be inefficient. This ignores the possibility that they may, for example, use natural resources more efficiently, have more biodiverse farms or employ more people than their more economically “efficient” neighbours. This approach also hides the fact that there are costs in intensive farming systems which do not get added the cost of food in the shops. A good deal of research has been carried out into the indirect costs of intensive farming methods which have arisen as a result of using such a narrow definition of efficiency. Researchers have highlighted the “hidden costs” of viviiviii modern agriculture ranging from pollution of soil and water to habitat destruction and damage and soil erosion. Increasingly, policies and regulations have been introduced to reduce the impact of farming on the environment eg nitrate sensitive zones and countryside stewardship. At the same time agricultural supply industry produces products largely aimed at increasing production or reducing production costs. Reduced costs frequently equate to less labour. GM crops are a case in point. GM herbicide tolerant crops with their promise of fewer applications of herbicides would logically lead to fewer workers being employed to apply weed killers if they became widely grown. However, the need to control herbicide tolerant volunteers and weeds in the longer term might increase costs and cause harm to the environment. The underlying point behind these general comments is that science alone cannot make farming more sustainable because many other factors combine to shape how the countryside is managed. These factors are largely political and economic by nature. Therefore the research needed to ensure the sustainable use of our countryside and natural resources necessarily has to be multifunctional just like farming. Research is also required to ensure that policies and regulations are based on sound information, and the outcomes accurately monitored to allow enforcement or correction to take place. Over the past five decades, the UK research has tended to focus on particular problems to find individual solutions. For instance, how can weed competition in this crop be reduced or how can this pest be controlled? Instead of approaching problems as part of a whole farming system, weed research has largely concentrated on ways of destroying weeds in the field. Thus highly effective weed killers were developed (eg the triazines) and these have been used on crops, such as fodder maize, for years despite the fact that they were regularly washing and leaching into surface and groundwater used for public supply which then had to be filtered clean at the public’s expense. Similarly the drive for increased production and efficiency in cereals has led to research and development that has produced winter sown varieties which require large inputs of artificial fertilisers, highly effective herbicides and pesticides and bigger machinery operated by fewer workers. All this has succeeded in producing massive increases in production and yields but at a cost elsewhere in the system. Intensive arable production has contributed to habitat loss, loss of biodiversity, water and air pollution, soil loss and damage, loss of agricultural biodiversity (fewer varieties being regularly grown) and indirectly to rural de-population and loss of services. Ironically, despite technological advances, growing cereals seems to have become an unreliable way to make a living because the UK farmer can be undercut by cereal farmers elsewhere in the world where the costs of production are inherently lower. Agricultural research and development has also suffered from being dominated by the needs of the corporations that supply farmers or purchase their produce. This has inevitably led to research being focused on products that can be sold season after season. Alternative

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approaches based on management of the whole rotation have received less emphasis because the techniques can only be sold once and do not lend themselves to repeat sales. In the 1980s, universities and research institutes were encouraged to concentrate on “nearmarket” research. This meant that management-based approaches have played second fiddle to research aimed at products with commercial potential. It has also led corporations gaining influence over research and the direction of research. At the same time public funding of scientific research has been cut. In combination these trends have been damaging to UK science. Firstly, by bringing into question its independence and objectivity. Secondly, by narrowing the scope of research and therefore limiting the range of solutions potentially available. Public influence, scrutiny and oversight over publicly funded scientific research have been minimal. This has been damaging to science because a gulf of mistrust has opened up between scientists and the public which has not been helped by the series of food disasters that have bedevilled UK in the last two decades. Thankfully, there has been a small shift away from this product driven approach to research but the underlying assumption remains that technology will provide solutions. GM crops are an excellent example of how scientific research has been pushed in one particular direction and it was only when civil society and the public intervened that the wisdom of this direction was seriously questioned and found wanting. The AEBC’s enquiry is therefore very timely. The Five Year Freeze fully supports the need for such a review and urges the AEBC make it as broad as possible so that it really puts the agriculture and food research agenda under the microscope. The Freeze fully supports the use of independent scientific information being a vital part of the decision making process. This is an important issue. It is vital if science and the regulatory processes are to regain public confidence that important research on risk is carried out independently with no industry inputs whatsoever except for the necessary finances. AEBC’s Specific Questions 1. What are the key drivers behind agricultural biotechnology research agendas and how are they balanced? The key drivers behind the research into biotechnology in agriculture are mainly commercial. The developments in molecular biology in the 1970s and 80s were quickly seized upon by corporations as an area where production could be developed with global sales potential. Round Up Ready soya being an excellent example. Monsanto were faced with the end of their patents on glyphosate and developed a package for farmers in which RR soya seeds and Round Up were only supplied together thus securing continued sales for the herbicide despite the fact that it was available via generic pesticide manufacturers at greatly reduced prices. Similarly Liberty tolerant crops were developed as a driver to increase sales of Bayer’s glufosinate ammonium herbicide which had a relatively small market share compared with cheaper alternatives. GM seed varieties are all hybrids and therefore require fresh seed every year to ensure that GM traits are present in the majority of seeds. Companies have used Intellectual Property Rights and Patents legislation to prevent farmers saving the seeds from GM crops. Indeed, only a huge civil outcry around the world stifled the development of the so-called “terminator technology” which was designed to ensure that farm saved GM seeds were infertile unless treated with a proprietary chemical. In the UK, the drivers behind the first generation of herbicide tolerant crops were also commercial. It was clear before there was any public outcry that the main benefit of GM crops was promoted by the biotech industry and research organsaitions as a means to achieve improved weed control. Only when concerns were expressed about their indirect impact on farmland wildlife were the other supposed benefits put forward. In fact, in the FYF’s opinion the technology’s main impact has been to increase the market control of a few large corporations.

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From the 1980s the indirect and hidden impacts of intensive farming have become more apparent. Consequently, there has been a shift in emphasis in government sponsored research towards sustainability. Some corporations have also recognized the need to develop crop protection methods with reduced environmental impact eg Unilever and the CWS. Other specific interest groups have had a much longer history of research into reducing the impact of farming, eg the Game Conservancy and RSPB. In the mid 1990s corporations had huge influence over government, and the first GM varieties (oilseed rape) were on course to be commercially available in 1998. Since then the corporate agenda has somewhat been knocked off course by public opinion. 2. Do you think the AEBC’s initial analysis accurately describes the key drivers behind agricultural biotechnology research in the UK and how these have evolved over time? Are there any omissions or gaps in the study? The AEBC’s paper provides an excellent summary of the historical development of food and farming research in the UK. However, there are significant omissions. The first is the lack of analysis of the influence of political patronage and the influence of corporate finance and lobbying on the public research institutions. Both the Prime Minister and Lord Sainsbury (the Science Minister) are known to be very probiotechnology and have sought to push research in this direction. Indeed it has been reported that The Sainsbury Laboratory in Norwich, which the Lord Sainsbury originally ix funded via charitable donations, was funded more generously than other similar institutions . x The Prime Minister has made several pro-GM speeches in the last seven years which sought to promote GM technology and neglected to consider alternative approaches. In a political climate such as this, those charged with deciding where research funding should go cannot fail to be influenced. Corporations are funding scientific research in food to a greater extent than ever before. Although most institutions still receive substantial amounts of public money for research there is a real danger that their need for additional funding to ensure the financial security of their organisation might lead their research towards areas favoured by business rather than those benefiting the public good. In such circumstances scientists “pursuing topics they found xi interesting” may inclined to pick topics for which industry research funding is more likely to be more forthcoming. Public scrutiny of who funds what in research institutions is generally lacking and commercial funding is subject to commercial confidentiality which can be used to prevent full transparency. A second area where more analysis would have been useful is the apparent lack of coordination of research on sustainable agriculture. Public and private money has been devoted to a whole range of research projects. Some focus on organic and consequently new techniques applicable right across farming may not necessarily be picked up. This leads us to another weakness in the AEBC’s paper which is the lack of analysis of how innovative research is translated into farm practice in the UK. In particular we would have liked to see analysis on what effect the removal of a free extension service (ADAS) had in this area and how this has opened up the advisory sector to more commercially driven consultants often representing the ag-biotech companies. Finally, we feel that the use of industrial levies for research merits more attention. Although farmers pay so much per litre or per tonne to fund research in their crop there is no apparent means by which they can have influence over the research undertaken. In addition as the research is focused on just one production system, eg sugar beet, cereals or milk, the opportunity to assess the sustainability of whole farming systems is being missed.

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3. What do you think has been the relative importance placed on the following drivers that we have identified? (Please give reasons for your answers as appropriate.):  advancing fundamental knowledge and scientific curiosity; maintaining/developing the UK science base; The FYF considers this to be one of the drivers for research but of diminishing significance due to political and corporate influence over research agendas.  wealth creation and building the “knowledge economy”; The FYF considers this is still an important political driver. We feel it is pursued at the expense of more important drivers of sustainable development and improving the quality of life. Wealth and knowledge are seldom equitably shared. If research is pursued solely to produce technological advances then it is likely to lead to deeper divides in society between the rich and the poor. Put simply, if the rich decide the criteria for research then they will naturally choose projects that favour them at the expense of the poor. This tendency can be even more divisive in developing countries. Current developments have a tendency to remove skill and knowledge from the farmer and concentrate it at company level.  international competitiveness; The drive to reduce production costs through scientific research has been very important over the last 50 years and this remains so. This has been very successful in that food, in relative terms, as has never been cheaper. However, this has been at a cost. Agricultural employment has been falling every year for as long as this driver has been in place. Animal welfare has suffered in the pursuit of higher output per beast or per bird. Human health has also suffered not least from the shift to processed foods high in salt, sugar and fats. The environment, landscape and wildlife have suffered from the introduction intensive production systems. The FYF is concerned a similar approach to research applied to developing countries would prove to be even more catastrophic. Ironically, the UK’s drive for international competitiveness has not proven successful because other producers also adopt the same technology but have inherently lower costs because of bigger fiields, higher labour costs, higher costs of regulatory compliance and the costs of multifunctional management of the land.  private sector product and process development in the „near market‟ research The FYF believes that this remains an important driver for research despite a shift towards sustainability research recently. Too much research is focused on products that can be repeatedly sold into the market instead of systems research looking at changes to rotations or crop management. GM sugar beet is a good example of how research can be driven by the desire to get a new technology established.  government policy, regulation and legislation; These are increasingly important drivers of research. However, the FYF considers that the research community would benefit from a clear political vision of exactly what the government sees as sustainable land management. Too often conflicting messages come from the government which lead to confusion about the main objectives of government policy – which is most important: international competitiveness or sustainable development given that the first seriously undermines the second in a world in which there are no global production standards? The Government’s reluctance to fund an extension service that would be required to deliver many of the changes necessary to meet for sustainable farming objectives leads to doubts about how committed they really are.  EU and international policy, regulation and legislation; EU regulations are influencing the research agenda in the UK. The GM Farm Scale Evaluations were largely prompted by Directive 2001/18’s risk assessment which required that the potential long term, cumulative and indirect effects of GMOs needed to be assessed.  public attitudes and aspirations; There is little evidence to support the view that the government takes public concerns into account when setting the research priorities for food and farming. Only when there is a massive public outcry do the public have real influence over what research is carried out and even then the broad direction is not overtly influenced. The traditional paper consultation are viewed with great scepticism by most people and a feeling that “they” will

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not take any notice. From our perspective there are simply no other mechanisms for such a process to occur apart from street protest and actions.  social need and the public good There is no evidence that scientific research in food and farming is largely driven by social needs or the public good. Occasionally, a crisis necessitates that this should be so, for example BSE and nvCJD, but generally the public good is not one of the main drivers. Even the “consumer’s watchdog”, The Food Standards Agency, seems to be more preoccupied by their own internal agenda than serving the public’s needs. For instance, on one hand they have allocated £0.5 million expenditure on developing a test chemical test for organic food when there is no evidence that the certification system is failing and on the other they seem reluctant to finance enforcement of the GM traceability and labelling regulations which the public is fully in support of. This seems to stem three main factors –the lack of a mechanisms by which the public can meaningfully participate, the ongoing, and the erroneous, attitude of the scientific elite that they know best and the fact that corporations tend to invest in projects that benefit them.. 4. The AEBC’s information gathering suggests an increasing emphasis on research to support government policy and the knowledge economy. Are you aware of any significant trends/changes over time in the drivers behind agricultural biotechnology? What impact have these had? The FYF believes that there is still much confusion about the drivers behind government policy and hence it is no surprise that science research programmes and extension lack coherence. Certainly the level of research on sustainability of farming has increased in the past 15 years since incontrovertible evidence on the long term harm being caused by intensive production systems was widely accepted. However, there is no sense that publicly funded research is being directed towards an ultimate vision of what a sustainable system might look like. Sustainability covers a large number of disciplines – for example, economic, social, plant breeding, hydrology, toxicology, soil science, ecology, agronomy and logistics. Current research programmes tend to deal with one issue in isolation and then fail to fit this into the larger picture that is necessary if sustainability food production is to be achieved. One of the main failings of GM research and development was that it was product led. Sound management of the land and crops was not the concern of the companies developing those products. The recognition that farmland biodiversity is now an important consideration in developing new arable systems was also missed by those engaged in GM research until very recently. Other research on arable systems has focused on species which have declined in intensive systems. Such research has led to minor changes in the way farms are managed, eg no spray field margins and bare patches in field. However by concentrating on fairly narrow areas of research, opportunities for wider gains are missed. The use of broad spectrum herbicides in combination with a simple three crop rotation (cereals, cereals, break crop) has not only been linked to the decline of some farmland birds but also in the loss of arable weed species, water pollution, soil erosion, and herbicide resistance to name a few. The validity of this approach to crop production has not yet been adequately examined nor have alternative approaches, for instance longer rotations and mixed farming. Current research on the sustainability tends to be crop specific and look at a narrow range of factors and largely tinkers with unsustainable systems. For example, winter wheat has many problems associated with its cultivation including a lack of winter feeding for birds, problems of disease control, herbicide resistance in economically significant weeds and run-off of herbicides but the wisdom of persisting with this crop is seldom challenged despite its recent poor returns. 5. Do you feel that the right balance is achieved between the drivers that you believe to be most significant? If not, please elaborate. As we indicated in the answer above, research into the full range of potential solutions is stifled by a reluctance to shift from traditional conventional techniques and rotations by Governments, research institutions and farmers. Part of the problem is that policies are geared to enable farmers compete on the world market and consequently monoculture

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rotations persist. It is essential that there is a major change direction for UK food and farming research towards sustainable food production. As changes in practice will take many years to bear fruit it is also vital that the new direction is supported by all political parties to ensure that it is not undermined by a change of government. 6. Our analysis suggests that there is still a significant “bottom-up” influence on research agendas, but that directed programmes and central Government control and scrutiny of research are increasing. In your opinion is the current balance between responsive mode (bottom-up) and strategically directed (top-down) research about right? If not, what should be changed? The Five Year Freeze does not agree with the view that scientists following up their own interests or curiosity is “bottom-up “. Scientists are an elite and privileged group in our society and therefore could be prone to promote research that favours them rather than the public good. They have a very poor record of listening to the public and too often tend to patronise and belittle the views of people from outside their peer group. Indeed, the controversy surrounding GM crops has highlighted the fact that the scientific community has real problems dealing with dissent within its own peer group. In the opinion of the Five Year Freeze, the way the views and work of Arpad Putszai, Andy Stirling and Ignacio Chapela were handled by the scientific community was appalling and would not have been tolerated in any other walk of life with the possible exception of politics. In our view “bottom-up” should mean real engagement with the end users – the public and farmers. We hope that the AEBC process will highlight this need. MECHANISMS FOR SETTING AGRICULTURAL BIOTECHNOLOGY RESEARCH AGENDAS, AND HOW WELL THEY WORK 7. Do you think appropriate mechanisms exist for determining research agendas and the balance that has to be struck between drivers when deciding what research is done? Please refer to what type of research and which funding agencies you are referring to in your answer. How well do you think these mechanisms work in practice? The Five Year Freeze considers that there is still work to be done to ensure that research reflects the needs of society. Political and corporate influence over research agendas needs to be greatly diminished. DEFRA’s and the Research Councils are heavily influence by both and have no perceivable public input or oversight of research programmes beyond token consultations. It is important that science moves away from token engagement with people and non scientific interest groups. We believe that the AEBC could do much to catalyse change in this direction and make the whole system more transparent. 8. Is horizon-scanning an important and useful tool for establishing research agendas? How significant has the government's Foresight exercise been? Horizon scanning can be a useful process for deciding research agendas but only if it is an inclusive process that involves all sectors of the community. Horizon scanning by elite groups runs the risk of mistaking the edge of their furrow for the horizon and hence wholes approached to solving problems. 9. Who should be involved in establishing policy and priorities in scientific research? Should the public and/or society more widely have a role in these decisions? If so, at what stage, through what mechanisms, and to what extent should they be involved? If not, why not? The Five Year Freeze has been calling for greater public involvement in setting scientific research agendas. As we have indicated above this has to move beyond tokenism so the influence of society brings changes and developments. GM Nation? Public Debate showed that there is a public appetite for involvement in decision making on policy. The debate also served to shore how large a gulf there is between people and scientific community and policy makers. The public input into GM Nation? showed that people have views on the social and economic impacts of new technology and weighed these equally with scientific considerations. These insights should not be ignored and should be used to provide guidance on the directions science should be going as well as policy.

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There is no evidence that the current mechanism for public involvement in decision making, for example FSA consumer committee, consultations and consumer representatives on advisory committees, makes any difference to the final decisions. The role of the consumer representative on the advisory committee is hampered by the fact that they are selected by ministers rather than consumers and, once appointed, are not given any support by which they could seek the opinion of others on policy or decisions. This greatly devalues the role of consumer or lay representatives.

IMPLICATIONS FOR RESEARCH AND DEVELOPMENT 10. Are you aware of any significant gaps in the UK research agenda that have been caused by an imbalance of research drivers? For example, do you believe an emphasis on wealth creation has led to significant gaps in public good research? Has the withdrawal of Government from near-market agricultural research created gaps? The Five Year Freeze believes that there are major gaps in scientific research in agriculture and food which arise from corporate and political influence over research agendas. As stated earlier the shift of focus to sustainable farming research has not led to research aimed at management based solutions. Instead the research effort has concentrated on the tinkering with the margins and new technology, eg more specific herbicides. What is required is better coordinated research programmes that link across disciplines and the amalgamated result could then be used to provide guidance to farmers on the best options for waste management, pollution prevention, rotations and crop management techniques to ensure that sustainability targets are met. For instance, how can research on reducing herbicide pollution of rivers and groundwater dovetail with research on enhancing biodiversity because both involve how broad spectrum weed killers are used and could involve different approaches to weed control. We suggest that the best way to achieve the co-ordination required is to establish a new sustainable food and farming research council which, in addition to the allocation of funding to projects would ensure that opportunities for several outputs to research projects and collaboration between teams are not missed.

11. Do you feel that the relationship between the public and private sector has changed, and what are the implications of this in terms of the industry influence on public sector research agendas? The Five Year Freeze believes that the influence of the private sector over research agendas of mainly publicly funded institutions is too great. This influence works in many ways. It directs research efforts towards potentially high profit, technological solutions for which there are potential markets and neglects examination of whole systems and management based solutions. It leads to interesting “embryo” developments being under funded because they have no potential for repeat sales or the market potential is too small. There is also a risk that it can lead to research into potential impacts of new technology being under funded or underplayed. There is a risk that members of staff with genuine concerns over the prudence or safety of new technology will be deterred from articulating their concerns or worse still stay silent. The public standing of science has suffered in recent years because commercial factors have been seen to be too influential. It would greatly benefit science as a whole if public institutions were truly independent of corporate influence and funding. This can only be achieved by increasing public funding. The close association of corporations with research institutions also clouds the issue of who owns the results of research and how they can be used for the public benefit. 12. In your view, is the UK sufficiently supportive of research and innovation in general, and more specifically in the field of agricultural biotechnology? Do you have any views on how research funds are deployed within the field of agricultural biotechnology? Innovation has come to mean patentable because this is where profits are to be gained. Yet much potential innovation is neglected because it is not susceptible to IP protection.

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Until the attempt to commercialise GM crops in the mid 1990s, the UK has allowed new technology to be used in farming in a haphazard and uncoordinated fashion. Generally new technology entered the market with little or no regard for sustainability issues. The GMO Deliberate Release Directive 2001/18 demands that applicants for GMO commercial licences provide evidence that there would be direct, no long term or indirect harm caused by the release of their product as well as an absence of short term acute effects. The inclusion of long term and in direct effects was a major step forward in terms of the level of proof required of risk assessments. This provision could also be included in other regulatory processes, eg pesticides and seed approvals, and to agricultural policy changes. These are essential checks and balances if new technology is going to be used across large areas of the countryside. Innovation must therefore include such considerations from the start. For too long we have been blinded by the white heat of technology be it machinery, chemical or seeds and ignored the potential for harm to arise from them individually or collectively. The use of knowledge on molecular biology can be applied in a number of ways. However, commercial pressures have resulted in genetic modification of crops being the dominant technology because this enables companies to retain greatest control and hence make most profit. Other techniques, such as marker assisted breeding, have not been widely used. But intellectual property rights and patent laws complicate the use of these techniques for the public good and also limit access to potential beneficial genetic materials for plant breeding. The FYF would welcome the AEBC’s views on how whole crop plant genomes could be available to all researchers and plant breeders. 13. What are the implications of the various drivers and mechanism behind research agendas on the openness and transparency of public sector research? The Five Year Freeze is concerned that private influence on research agendas lead to unnecessary level of secrecy (based on the demand for commercial confidentiality). The FYF supports an open and transparent system of research in which the objectives, methodologies and results are automatically in the public domain and therefore all can benefit from the findings. If public research institutes engage in privately funded research then this should be placed on a public register of potential conflicts on interest. An increase in public funding for food and farming research would greatly assist in this respect and ensure that sustainable research was given the highest priority. 14. Are there any issues around the setting of research agendas that the AEBC may have missed? If so, please elaborate. The Five Year Freeze feels that the AEBC have made an excellent start in assessing the drivers for setting research agendas. One omission which we would like to see addressed is an assessment of if and how greater public involvement has occurred in other countries around the world. Of particular interest would be an examination of farmer centred research in eg: the Philippines. If so, was this successful and beneficial and what lessons could be leant by the UK?

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http://www.defra.gov.uk/environment/gm/research/pdf/epg_1-5-213.pdf http://www.which.net/campaigns/food/gm/index.html iii http://www.genewatch.org/www.genewatch.org/press%20releases/pr02.htm iv http://www.gmnation.org.uk/ut_09/ut_9_6.htm#summary v http://www.fiveyearfreeze.org/indexb.htm vi Pretty JN et al, 2000, ‘An Assessment of the Total External Costs of UK Agriculture, Agricultural Systems 65 (2000), 113–136. vii Hartridge, O. and Perce, D. (2001) Is UK Agriculture Sustainable? Environmentally Adjusted accounts for UK Agriculture. CSERGE Economics Paper. UCL/UEA viii Environment Agency, 2002. Agriculture and Natural Resources: Benefits, Costs and Potential Solutions, Environment Agency, Bristol. ix Barnett A, 2003 The Observer 13th July 2003
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http://news.bbc.co.uk/1/hi/uk_politics/2003596.stm
AEBC Research Agendas Work stream Draft Information Paper page 22.

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