AEBC Secretariat May 2004
Non-Food Agriculture Workstream
Biotechnology Commission Non Food Agriculture Workstream:
Biotechnology and non-food agriculture: The future of farming?1
Rationale 1. The planet now supports six billion people and our population is rapidly growing. If we maintain our current patterns of resource use and consumption the planet cannot support this population in the long-term. A sustainable future requires us to address environmental problems such as climate change and sustainable resource provision. It is now obvious that changing our agricultural practices, including the development of non-food agriculture will be an essential part of reaching sustainability. 2. As well as fundamental pressures, a large number of initiatives are now in place which are directly or indirectly designed to stimulate non-food agriculture. Biotechnology, be it the use of modern breeding techniques or genetic modification, will play a significant role in this process, both by reducing the time it takes to develop varieties for non-food use and developing new material which could not be produced on a pertinent timescale by conventional means. 3. These pressures and initiatives have developed very quickly so inevitably the regulations that cover the introduction of new plant varieties (that are often tailored to the identification of higher quantity rather than differentiated quality) are to varying degrees out of date. A key part of this workstream will be to assess the degree to which current regulatory framework is fit for this new purpose: are there systems in place to properly weigh the benefits against the risks of growing new varieties of crops, animals and microorganisms be they conventionally bred or biotech assisted? 4. AEBC can add value by looking at implications of the application of biotechnology to non-food agriculture. We will look at a series of case studies and analyse the regulations that pertain to them producing a gap and redundancy analysis, the objective being informed and appropriate new regulation and elimination of bad or irrelevant regulation. We will also explore public attitudes towards biotechnology in the non-food sector, where we believe the benefits are more obvious to people and the risks are less personal.
Scope 5. This workstream will have a dual focus: Firstly it will analyse the regulatory framework pertinent to the development of non-food agricultural products. Rather than attempt to look at the whole range of
1
The first three pages of this document are a summary; the full work stream document is attached at Annex A.
AEBC Secretariat May 2004
Non-Food Agriculture Workstream
non-food outputs it will focus on a small number of representative case studies to examine in depth. Secondly it will use the results of the case studies along with other collated information to inform the public about the issues raised by the use of biotechnology in the development of non-food agriculture. It will then test the public‟s views about these applications of biotechnology.
Methodology and outputs 6. The workstream will start with an over-view review of the general drivers and pressures fuelling development of non-food agriculture. At the same time the workstream will review the range of non-food agricultural products and production systems and use this work to identify a small number of case studies for detailed regulatory analysis. The first out-put will then be short paper setting out the results of this work and the reasons for selecting the particular case studies. This paper will be summarised in a wall-chart representing the range of non-food agricultural systems, highlighting the case studies. 7. The second stage of the workstream will be a set of in-depth regulatory analyses of each the case studies. These will aim to identify gaps in regulation and make assessments if the pertinent regulations are fit for purpose. They will also identify regulatory and policy interactions and implications. The output of this stage will be will be the write-up of each of the case studies (3 or 4 separate documents). 8. The third stage of the work stream will be to investigate public opinion in relation to non-food agriculture. In detail this will need careful expert design, but could follow the narrow-but deep approach using reference groups and charting how their views change when they are provided with balanced information relating to non-food crops and the application of biotechnology to it. The output of this report will be along the lines of the narrow but deep element GM Public Debate study. 9. The fourth stage of the workstream will be synthesis work. This will be the opportunity for the Commission to frame the earlier work and draw out the common themes and key messages. The output of this stage could be, in effect, an executive summary and the conclusions of a final report.
Innovative public engagement: a TV programme? 10. The Commission want to explore the possibility of working in partnership with a TV company to produce an interactive TV programme looking at the future of nonfood crops in farming and the role biotechnology might play (see programme pitch at Annex B). This might form part of the public opinion work by forming part of the material to educate a reference group, and though its interactive elements with a wider audience. The aim is to produce a programme which is accessible
AEBC Secretariat May 2004
Non-Food Agriculture Workstream
rather than highly academic. This is seen as important given the Commission remit to engage and involve the public. 11. However the Commission recognises that getting this proposal to work is by no means certain, and the work stream has therefore been designed for this aspect to be carried out in parallel with the other stages and not reliant on it proving successful.
Timeline 12. The project will take between 12 and 18 months, but with regular outputs along the way. This flexibility is built in to allow for the uncertainties associated with working up the potential TV programme and phasing it with the other stages of the project. At this stage timings are provisional estimates Stage 1: Approximately April- June/July (background work on each of the case studies may be staggered). Background information gathering exploration of assumptions, policies and pressures behind regulatory framework. Approximately June/July-December/January 2005 (work on each of the case studies may be staggered). Detailed regulatory ansysis of each of the case studies. February 2005-August 2005 (this includes contingency so that the public opinion work can be synchronised with the proposed TV programme) Public opinion work. September 2005 -October 2005 Synthesis work. In parallel with stages 1 to 3.
Stage 2:
Stage 3:
Stage 4: TV Prog:
A diagrammatic timetable is given in Annex C.
AEBC Secretariat May 2004
Non-Food Agriculture Workstream
Annex A: Work Stream Scoping Document: [Working Document, Last Updated 10 May 2004]
Biotechnology and non-food agriculture: The future of farming?
Abstract The planet now supports six billion people and our population is rapidly growing. If we maintain our current patterns of resource use and consumption the planet cannot support this population in the long-term. A sustainable future requires us to address environmental problems such as climate change and sustainable resource provision. It is now obvious that changing our agricultural practices, including the development of non-food agriculture will be an essential part of reaching sustainability. As well as fundamental pressures, a large number of initiatives are now in place which are directly or indirectly designed to stimulate non-food agriculture. Biotechnology, be it the use of modern breeding techniques or genetic modification, will play a significant role in this process, both by reducing the time it takes to develop varieties for non-food use and developing new material which could not be produced on a pertinent timescale by conventional means. These pressures and initiatives have developed very quickly so inevitably the regulations that cover the introduction of new plant varieties (that are often tailored to the identification of higher quantity rather than differentiated quality) are to varying degrees out of date. A key part of this workstream will be to assess the degree to which current regulatory framework is fit for this new purpose: are there systems in place to properly weigh the benefits against the risks of growing new varieties of crops, animals and microorganisms be they conventionally bred or biotech assisted AEBC can add value by looking at implications of the application of biotechnology to non-food agriculture. We will look at a series of case studies and analyse the regulations that pertain to them producing a gap and redundancy analysis, the objective being informed and appropriate new regulation and elimination of bad or irrelevant regulation. We will also explore public attitudes towards biotechnology in the non-food sector, where we believe the benefits are more obvious to people and the risks are less personal. Rationale 1. The rural economy is never static. The pre-industrial rural economy was highly diversified producing materials for building, oil for fuel and lubrication, fibre for rope and textile, food for humans and feed for animals. From pre-industrial times through to the last few decades increased international trade, the uptake and then mass exploitation of fossil fuels and rapid technological innovation have driven change in the nature of farming. Farming is now generally mechanised, intensive and specialised - essentially focused on food and feed production. Within this trend, individual farms now tend to be specialised producing a defined range of
AEBC Secretariat May 2004
Non-Food Agriculture Workstream
products. With the exception of forestry, the growth of crops for non-food use is so far very limited in the UK/Europe. 2. The factors driving change in the rural economies are changing: trade is becoming freer and fairer, concerns about the use of precious non-renewable resources are growing (particularly in terms of the continued supply fossil fuels and the impact of greenhouse gases) and the need for environmental sustainability is slowly being recognised. This change is being driven by a large number of interrelated initiatives including, CAP reform, the EU anything but arms initiative, EU policy and regulation on GMOs, the EU‟s response to the wider WTO agenda and European working groups on Climate change and the ERRMA grouping, the Curry Report, the global climate change agenda, the Water Framework Directive and the Energy White Paper. 3. A common theme resulting from these initiatives is a change in the focus of landuse away from food production towards other priorities including, water management, environmental mitigation/nature conservation, public amenity and, in particular, the need to preserve scare and valuable non-renewable resources. Non-food agriculture has been cited as a way of addressing all these issues as well as having the potential to provide alternative economically viable uses for farmland2. 4. Non-food crops are crops grown for purposes other than food or feed. The potential range of non-food crops is huge (particularly if looked at in terms of nonfood agriculture) from wood and leather to anti-cancer drugs important applications include: Energy crops: crops grown for direct heat/power generation (e.g. coppiced willow) or a feedstock for liquid fuels, most of these crops used for these fuels are traditionally used for food i.e. oilseed rape for biodiesel, cereals and sugar beet for bioethanol). Other non-food crops: crops grown for other purposes of which examples include: fibres (cotton, hemp, flax etc), lubricants and waxes (oilseed rape, linseed), printing inks (oil seed rape) essential oils and dyes (wood), compostable plastics (starch-crops). Pharmaceutical3 crops: (or pharma-crops): crops (plant, animal, microbial), largely in development at present, grown for the production of pharmaceuticals or their precursors, e.g. vaccines, antibodies or therapeutic proteins.
5. Biotechnology clearly has the potential to improve the utility of conventional nonfood crops e.g. through selective or marker-assisted breeding of grain and oil seed crops for higher yields of specific starches and oils, the creation of genetically modified trees with enhanced disease resistance or lower lignin content for the paper industry or for bioethanol production by lignocellulosic digestion, or the development of crops which remove certain pollutants (e.g. heavy metals) from contaminated land. Conversely, it could be targeted at far more trivial issues. For example, the development of new plants, with novel or
2 3
See accompanying background from page 5 Pharmaceutical crops are taken here to mean any crop grown to produce a medicinal product i.e. including antibodies etc.
AEBC Secretariat May 2004
Non-Food Agriculture Workstream
unusual characteristics (e.g. colour) for ornamental applications is a potentially high value market. 6. New crops are in development using various biotechnologies including GM to produce pharmaceuticals from „conventional‟ drugs through to therapeutic proteins. These crops are being developed with the aim of reducing the cost and dramatically increasing the availability of various medicinal products e.g. proteins for antibody therapy. The development of nutraceuticals (i.e. dietary supplements and functional foods) is closely allied to this. 7. ‘GM Nation?’ was focused on food production and GM, but what are the public‟s views on other uses of biotechnology? From this and other work we see that only a minority of people oppose GM/biotechnology per se (i.e. most are willing to acknowledge, at least some, potential benefits)4, although few say they would be happy to eat GM food. Another minority are strong proponents of biotechnology. 8. What is the nature of public opinion, in the context of non food uses of biotechnology, particularly where it is orientated to address significant and pressing societal needs? An investigation of public views on the various types of biotechnologically developed crops and their applications may be useful in gauging the depth of public opinion and the nature of public values, perceptions and beliefs. 9. This area poses important questions, which the AEBC is well placed to answer. It could provide the Commission an opportunity to engage with stakeholders and the public in general. Pharmaceutical crops specifically offer an opportunity to explore the agricultural / medical interface. There are also interesting and useful questions raised about peoples‟ views with respect to biotechnologically developed crops, specifically questions on how much benefit justifies a certain level of risk, and about conditionality of opposition. This area also offers the chance to test a relatively unbiased field without preconceptions – as applications of biotechnology to non-food crops are comparatively new to the public, how will they react? Scope This workstream will have a dual focus: Firstly it will analyse the regulatory framework pertinent to the development of non-food agricultural products. Rather than attempt to look a the whole range of non-food outputs it will focus on a small number of representative case studies to examine in depth. Secondly it will use the results of the case studies along with other collated information to inform the public about the issues raised by the use of biotechnology in the development of non-food agriculture. It will then test the public‟s views about the applications of biotechnology.
4
See accompanying background from page 5
AEBC Secretariat May 2004
Non-Food Agriculture Workstream
10. This study will not try and investigate all the possible the uses of biotechnology with respect to non-food crops. This would be unrealistic given the Commission‟s resources, and there has already been a great deal of work done in this area. The commission would add little value. 11. However, the project needs to be carried out in the overall context of the policy, regulatory and economic pressures that are driving and restraining the non-food crop agenda. These will be set out in general for the project and in detail for each of the case studies. This will be important background for the project but will not constitute a major out put of the work stream. 12. Similarly any regulatory analysis needs to be carried out in the context of the (potential) benefits/impacts of biotechnologically developed non-food crops compared with conventional crops (e.g. for energy crops), and manufacturing methods (e.g. for pharmaceuticals) including environmental impact, energy efficiency etc. For each case studies a review of the available information will be carried out with an assessment of how robust evidence is for the (potential) benefits/impacts of each of the studied routes. Again although clearly important, these will not form a major output of the work stream. 13. Public opinion on the use of biotechnologically developed organisms used in nonfood agriculture will be a major focus of the workstream. In particular we will look at how public perception varies when presented with different applications of biotechnology to agriculture, specifically for: a) Crops grown for food compared with crops grown for energy and pharmaceuticals/‟medicines‟. b) Crops grown in the general environment compared with crops grown in closed environments (from closed greenhouses to secure laboratories).
Methodology 14. This workstream will be taken forward as series of discrete pieces of work leading to regular short reports as project progresses. A timetable/work-plan is attached at Annex B Stage 1a: Scope existing work. This stage will review exiting being done by others and policy drivers e.g. identifying the policy contexts and the regulatory framework into which non-food crops play and interact. This will be a summary and not attempt to be the definitive text. Government Legislation/Policy: Curry report => Strategy for Sustainable Farming and food. Forthcoming rural white paper Energy White Paper International European Legislation/Policy Water Framework Directive Waste Framework Directive Trade/economic drivers
AEBC Secretariat May 2004
Non-Food Agriculture Workstream
Bio-safety e.g. Cartagena Protocol and the EU Deliberate releases regulations Research Agendas Environmental impacts – what analysis has already been done US Technology Road Map
Stage 1b: Final selection of the case studies. The case studies will be selected on the basis of what society/industry requires in terms of (agricultural) outputs rather than focus on individual crops. Three sectors have been identified where agricultural products either are beginning to have or have the potential to substitute for “conventional production methods”. These are: Bio energy Packaging Pharmaceuticals
These case studies will focus on outputs rather than individual crops. Where there are a large number of alternative agricultural production routes. A small number of the most likely routes representing the range will be described and mapped for each of these three areas, which would then serve as exemplars for the whole. In February the Commission held a stakeholder dialog event at which aimed to engage with stakeholders in developing its future work programme. At this meeting stakeholders identified a set of issues around the non-food agriculture agenda, which they agreed should covered collectively by the case studies, these are: i. ii. iii. iv. v. vi. vii. viii. ix. Crops with food and non-food applications (co-existence of food and non-food varieties). Non-food crops to include including things which are non-GM, and even non-biotech. Crops whose wide cultivation implies significant land use impacts Diverse scope of non-food applications, including crops and other agricultural organisms (i.e. microbes and animals). Different degrees of confinement Environmental Remediation angle Geographical scope, production in UK elsewhere Moral obligation (e.g. to cure diseases in the developing world) Examples that are Likely to be good tests of public opinion (e.g. a range of desirability: cure to cancer/AIDS through to energy crops) Cover the point that GMOs that are used to produce things like vaccines already.
x.
Case studies will be chosen to ensure that each of these issues is covered while aiming for individual case studies to be quite narrow.
AEBC Secretariat May 2004
Non-Food Agriculture Workstream
Outstanding Issue: Case studies On the above basis the non-food agriculture sub-group have selected two definite case studies covering the bio energy and packaging sectors (Wood and Polylactic Acid respectively) bold in the table below. No decisions have been taken on selecting case studies to cover pharmaceuticals as sub-group members to talk to experts in this field before making a decision. Alternative case studies have been identified for the bio-energy and packaging sectors, (biomass and starch respectively) bold in the table below. These will be explored if the initial set of case studies fails to adequately explore the above criteria.
Sector Bio energy Packaging Pharmaceuticals Possible case study TREES Biomass POLYLACTIC ACID Starch Therapeutic proteins Vaccines i ii X X iii X X iv v vi X vii X X viii ? X ix X ? x
X
x
x
x
x
x
x
x
Outputs:
1) A short paper reviewing existing work and setting out the background to the non-food agriculture agenda. This paper would solely be a literature review exercise but working it up will feed into the final selection of the case studies and help identify the areas where the AEBC could add value. The final paper will include the rationale for choosing the case studies. 2) A “wall chart” showing the range of products of non-food agriculture [showing current, near term and potential products/different levels of biotech-ness?]. The chosen case studies will be highlighted on this.
Stage 2:
Case studies: Each case study will compose of: A. The reasons why the case study was chosen and a literature review setting out the back ground to each case study, specifically: i. The various agriculture routes available to produce the products, and their (potential) environmental impacts (both positive and negative The (potential) role of biotechnology in enabling or increasing the facility of these routes; and How robust the evidence is for any claims.
ii. iii.
B. An analysis of the existing regulations which (would) apply to the commercialisation of the agricultural systems needed for each route. This will be the core part of each of the case studies.
AEBC Secretariat May 2004
Non-Food Agriculture Workstream
Outstanding Issue: Who will do the legal analysis (part B)? The core group agreed that this needs some expert legal input. The idea of using legal students has been dismissed the lead-in times are too long. There are to other options. 1) Using a trainee in a law firm with a more senior sign off there maybe scope get this done on a pro bono basis. David B and Justine are looking into this. 2) Using the secretariat working under a limited amount of contracted-in legal guidance and quality control. 3) Subcontracting the work out to either a legal firm or a legal academic. As this is a key part of the case study it is imperative that that the Commission I fully confident about the quality of the work. C. An analysis of the implications of 2 assessing the degree to which current regulations are fit for purpose and highlighting policy interactions current and potential and advising how policy might be developed. For each case study the Secretariat will draft the first part of the case study this will be then finalized by the commission (in working group) and used to set the scope of the second part of each study. Part two of the case studies (i.e. the regulatory analysis) will need legal expertise. This work could be contracted out (on a commercial or pro bono basis), or be done by the secretariat (which legal guidance and quality control). The third part of each case study will be carried out by the commission (in working group) with secretariat support. Output: Accessible, interesting but balanced reports, setting out the findings from the above case studies. These would include a comparative analysis of the (potential) benefits of biotechnologically developed crops compared with conventional crops in terms of environmental impact, energy efficiency etc. This work could also feed into a possible TV/Radio programme (to be discussed at the May Commission Meeting)
Unresolved issue: Innovative public engagement – a TV or Radio programme? [To be discussed at the May Commission Meeting] Comment from David Carmichael: I would see any programme more as a Robert Winstone type programme imparting information on emerging technologies and sociological changes rather than setting up a debate. I suggest that the substitution of non-renewable resources by renewables is an emergent technology; the possible use of GM is a detail that is not an essential element. Surely then our concern should be to ensure that the transition is appropriately regulated to leave a minimal environmental footprint and with acceptable sociological consequences. In which case a debate is not called for but an entertaining and informative (I hope the two adjectives are not mutually exclusive) programme could be.
AEBC Secretariat May 2004
Non-Food Agriculture Workstream
Comment from David Buckeridge: I agree with this and this is exactly the kind of programme I have in mind – more of a documentary but with clever virtual reality type graphics, that starts in the past with diversified agriculture and lots of sepia tones, marches through the post war production agriculture with all its warts, but acknowledgment for what was achieved against a clear post war policy framework…then brings in the significant societal challenges of non renewables, aging populations, more leisure time etc. and introduces the new policy agenda to the public – how will agriculture and the fabric of our green and pleasant land be impacted by the biggest shake up in the policy agenda for 60 years? Will we see the side effects this time around? What are the possibilities, who is working on what, what have the other EU states already achieved in this changing agriculture world? Comments/interviews in evocative locations… from the boffins, the industrialists, from the activists, the farmers, the economists, from the politicians…press the red button on your remote now to interact!!! As well as being an input into the public opinion work the programme will allow the commission to engaging with the public generally. Comment from David Buckeridge: With regard to Non-food crops the public are generally uninformed, there will need to be provision for the public to be given an overview in association with define short report in the hope that they will be able to develop a more informed response The Commission will also want to use this work and other communications to influence other players in the area (i.e. not just Government and the Public). Comment from David Buckeridge: With regard to the agricultural community and alternative energy sources there has been considerable debate, much of it illinformed, I hope that we can serve to correct much of this, i.e. generate some light rather than the heat that has been all too much in evidence. Stage 3: Public Opinion Work: Using the above reports from stages 1 and 2, as source material (along with the TV/radio programme that might be developed along with the workstream) An external body will be commissioned carry out a “narrow but deep”-style reference/focusgroup study addressing how public perception varies when presented with different applications of biotechnology to agriculture? Specifically for: i. Crops grown for food compared with crops grown for energy and pharmaceuticals/”medicines”. ii. Crops grown in the general environment compared with crops grown in closed environments (from closed greenhouses to “laboratories”). The methods to be used to examine the public‟s attitudes will need to be carefully developed; in this respect at least we can derive benefit from our past experience with the National Debate. This will be part of the tendering process.
AEBC Secretariat May 2004
Non-Food Agriculture Workstream
The Commission will then produce a report analysing and commenting on the results of public consultation. Output: Results of focus-group study commissioned and framed by AEBC fronted by an AEBC report analysing and commenting on it. Synthesis. The fourth stage of the workstream will be synthesis work this will be the opportunity for the commission to frame the earlier work and draw out common themes and key messages. Depending what the outputs of the previous stages the output might just be an executive summary and the conclusions and a final report which uses previous work as the middle chapters. Or it could be larger document summarising the previous work as well.
Stage 4:
Output:
AEBC Secretariat May 2004
Non-Food Agriculture Workstream
Annex B: Programme Pitch
Scene Setting
Population growth, food, resources, inequalities. Need for sustainable provision of resources. Environmental stress: problems are imminent e.g. climate change. Fuel and other resources running out/harder to get at. Population in west getting older (and iller). In developing world disease is the big problem e.g. AIDS in Africa. Second agricultural revolution in last 150 years: re-diversification of agriculture. Examples: (current and in development) – willow for power, starch for plastics, oils for fuels and feedstocks, microbes for drugs and in the future plants for vaccines? Etc.
Programme structure:
Start back at the effect of the industrial revolution on agriculture? The past with diversified agriculture and lots of sepia tones March through convoys across the Atlantic and rationing The post-war production agriculture with all its warts, but acknowledgment for what was achieved against a clear post-war policy framework Then bring in the significant societal challenges above of non-renewables, aging populations, more leisure time etc. Introduce the new policy agenda to the public – how will agriculture and the fabric of our green and pleasant land be impacted by the biggest shake up in the policy agenda for 60 years?
Introduce questions:
Will we see the side effects this time around? What are the possibilities? Who is working on what? What have the other EU countries already achieved? What are the trade-offs? Why should we worry this time around? What is the social dimension to all this – restoration of rural communities and economies?
Comments/interviews in evocative locations
Experts: what are the problems we face? Boffins: what technological solutions are in the pipeline? Industrialists: what's needed to make this deliverable? Activists: need for urgent action vs. precautionary principle Farmers: can new generation meet this challenge? Economists: is all of this affordable? Politicians: what are they doing about this?
Conclusion: A re-diversification of farming? Biotechnology will play a role. Government needs to act fast to secure the benefits and manage the risks.
Interact! …Has agriculture come full circle? …What‟s the proper role of biotech?
*Press the red button on your remote now*
Work Stream Scoping Document - May
Annex C: Non-Food Agriculture: preliminary timetable/workplan
2004 Apr. May 2005 Jan
June
July
Aug.
Sept
Oct
Nov
Dec
Feb
Mar.
Apr.
May
June
July
Aug.
Sept
Oct
Stage 1: Back-ground work and selection of Sage 2: Carry out the 3 case studies - regulatory case studies analysis Specific Bioethanol Polylactic Acid Overall Specific Specific Pharmaceuticals Draft pitch Lead-in time
Stage 3: Public opinion work
Stage 4: Final deliberations
Programme making Opinion Poll work Synthesis work
Background paper Wallchart of non-food products highlighting case studies.
O U T P U U T S
Bioethanol case study Polylactic acid case study Pharma. case-study
Innovative out put e.g. TV programme on biotech and non-food crops. Results of public opinion work Plus initial commentary?
(Three separate documents)
Commission writes a short overview report (effectively an executive summary plus conclusions