The Royal Society of Edinburgh is pleased to respond to the Scottish Executive Rural Affairs Department’s consultation on the Assessment of Value for Cultivation and Use (VCU) of Agricultural Plant Varieties. The RSE is Scotland’s premier Learned Society, comprising Fellows elected on the basis of their distinction, from the full range of academic disciplines, and from industry, commerce and the professions. This response has been compiled with the assistance of a number of Fellows including those with direct experience of agricultural and crop research.

There are likely to be considerable difficulties and costs involved in the full inclusion of Genetically Modified (GM) crops in the VCU system and further work is likely to be required on the specific details of implementation, especially in connection with the trialling issues which arise. Three major questions in this respect are:

• Will separate sets of trials be grown for GM and non-GM varieties?
• If so, how will GM and non-GM varieties be compared? If non-GM varieties are used as controls in the GM trial, will special statistical designs be required to ensure separation standards are met?
• Will GM trials allow implementation of individual crop management packages for different varieties, for example, the use of different herbicide products? This could not be done without a significant increase in plot size and separation, or change in method of herbicide application.

The specific issues identified in the consultation document are addressed below:

Current approach to VCU assessment

The current scheme is currently criticised for the strong elements of subjectivity in determining ‘value’ and potential harmful impact on the genetic diversity of crops. With these caveats, Part 1 and Annex 1 appear reasonably straightforward. The use of Least Significant Difference in the determination of superior/inferior characteristics in paras 14 and 15 of Part 1, however, presupposes a normal distribution of the values. However, the distributions indicated are skewed and not normal suggesting that the use of ranking and non-parametric methods would be better. It has also been suggested that in the assessment of value for cultivation of food crops, the characteristic of flavour be included.

The standards for GM varieties should be no lower than those for non-GM varieties with the same characteristics

The Society welcomes the proposal that the standards for GM varieties should be no lower than those for non-GM varieties and believes they could in fact be higher than for non-GM varieties if restrictions or additional requirements are to be placed on growers.

It is appropriate to establish separate categories for GM and non-GM varieties so that non-GM varieties are not displaced if they are outperformed by GM varieties

The establishment of separate categories for GM and non-GM varieties focuses on the process which created the finished variety, rather than the quality trait or characteristic of the variety itself. However, separate assessment of GM and non-GM varieties is likely to be necessary as long as public concern remains and the market requires the distinction between the two categories.

In addition, there are likely to be initial problems in creating special categories for GM varieties in that these categories are likely to be very small. This could make it relatively easy for a new candidate to show a clear improvement on the small number of existing GM varieties, when considering its qualities as a whole. This would, in turn, make entry onto the National List relatively easier for GM varieties, especially if the different types of GM were put into different categories. The alternative is to introduce appropriate modifications to the threshold standards. For example, in wheat a Group 1 Full bread-making variety has a lower yield threshold than a Group 3 Biscuit-making variety and the Group 4 Feed wheats have the highest yield threshold. Applying a similar system to GM varieties would continue to expose them to competition on other characters, such as disease resistance, while not putting non-GM varieties at a competitive disadvantage in terms of entry onto the National List.

It may be necessary to consider separate categories for characteristics resulting from genetic modification

The Society agrees that new categories may have to be produced when completely novel beneficial characteristics, resulting from genetic modification, appear in conventional crops. Distinctions could also be made between genetic modifications which could have been introduced, although less surely and easily, by traditional selective breeding, and on the other hand genetic modifications which introduce ‘foreign genes’, such as animal genes, into plants.

It would also be useful to assess the variation in risk of a GM variety contaminating subsequent crops. Recent work at the Scottish Crop Research Institute has shown that in Oilseed Rape secondary dormancy induced by cool temperatures increases the risk of gene-flow. It would be relatively easy and cheap to assess secondary dormancy using a low temperature germination test, where subsequent contamination is important. Varieties with a high degree of secondary dormancy would therefore need additional compensating factors before entry to the National List.

It has also been suggested that there would be merit in estimating possible environmental impact as acharacteristic for both GM and non-GM varieties. This would focus the attention of breeders and variety assessors on possible deleterious effects on the environment and take into account such factors as the greater or lesser need for spraying, fertiliser requirement etc.

Other standards for varieties with such a characteristic should be no lower than those for varieties without the characteristic, unless the value of the characteristic can be reliably demonstrated

The Society agrees with this proposal.

Further information is available from the Research Officer, Dr Marc Rands