The Royal Society of Edinburgh (RSE) is pleased to respond to the Advisory Committee on Releases to the Environment (ACRE) consultation on draft guidance on the assessment of risk to biodiversity from Genetically Modified (GM) crop management. 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 by the General Secretary with the assistance of a number of Fellows with substantial experience of agriculture and the environment.

As a statement of principles the document appears generally satisfactory, although experts in this field of work may feel that it does not add much to the present approach. The emphasis on post-release monitoring, however, is worthwhile and guidance of this nature is essential if novel or modified crops are to be accepted by the public for growing in Scotland. Anything, therefore, that can make the guidance more user-friendly will improve the likelihood of it being accepted, and the more important it will be in developing appropriate GM technology.

The document does not, however, mention that there might be a need to cover any effects of harvesting, storage and processing. Disposal of by-products, effects on storage microorganisms and mites should be included in any discussion of biodiversity. Consideration should also be made of seeds left in the field, lodged on farm machinery and lost during transit.

Comments on the different sections of the draft guidance are addressed below:

Aim
There would be merit in assessing both the risks and the benefits associated with the growing of these crops, and therefore including the word 'benefit' in the aim. There is also a need to define a little more clearly what is meant by biodiversity. The aim refers to something called 'farmland biodiversity'. However environmental effects could extend to other environments outwith the farm environment. It would be preferable therefore to see the word biodiversity unqualified by the adjective 'farmland'.

Risk to the environment
In assessing the risk to the environment there will need to be details of the nature of the genetic modification made to crops, for example in terms of the precise number and type of genetic material inserted.

With regard to paragraph 2(b) second last line, mention is made of the 'likely impact' across the whole of a crop's potential range in the UK and more widely. There should be some explanation of what might be meant by this term as it could prove to be very expensive to determine.

In paragraphs 2(e) and (f), there is reference to Biodiversity Action Plan (BAP) animal and plant species. Whilst these are likely to be a priority, there are many other species that contribute to biodiversity. If the BAP species are being used as indicators, then this may be satisfactory, though their value as indicators should be tested. However, in Scotland, these BAP species do not cover all aspects of Scotland's biodiversity, and further indicator species may need to be considered.

In paragraph 2(g) there is reference to insecticidal and fungicidal properties of crops and it is suggested that the impact on farmland habitats should be considered. In this context, the likelihood of increased resistance in pest and disease populations should be included, as well as the impact of the insecticidal and fungicidal properties on decomposition fungi and bacteria.

Post-release monitoring
Post-release monitoring can involve cultivating crops before all the possible impacts of the crop are known. In reality, no matter how much testing is done under laboratory and field experimental conditions there is always a potential unknown risk from the introduction of any new crop on a commercial scale. These risks, however, are minimised by careful testing and by monitoring in the post-commercialisation stage. Nevertheless, value judgements are inescapable. For example, paragraph 3(b) states, in part:-

"If the risks associated with a proposed release are acceptably low, then a post-release monitoring scheme may not be necessary, or need only be minimal. If the impacts of the management of the crop on wildlife cannot reliably be predicted, but are sufficiently low or reversible to allow field testing..." [Note: italics added]

This decision-making process is centrally concerned with determining what is 'acceptable', 'minimal', 'reliable' and 'sufficient', which are crucial value-loaded decisions that cannot be avoided. The decision-making processes within these Guidelines should therefore be open, transparent and inclusive in a way that will satisfy the public at large.

The monitoring itself also needs to be considered in terms of who does it, who ensures that it is done to an approved standard and what is monitored. Some indication of what might be expected should be included in the Guidelines.

Risk management
This section should be strengthened. If there are unacceptable risks to the environment from the proposed crop management regime, that cannot be sufficiently negated by risk management measures, then by the 'precautionary principle' there should be no release of that crop. Further research and development would then be needed in order to derive a similar, or new, crop that did not carry unacceptable risks. Key to this assessment will be the undertaking of multi-factorial risk evaluations in order to construct risk models and to undertake sensitivity analyses. Similarly, measures need to be in place to ensure that proposed risk management methods, such as reduced pesticide application rates, are applied in practice.

There should also be recognition of the importance of communicating the risk assessment to the public. Public consultation, and achieving public confidence before a novel or modified crop is grown, are essential. If there is no public confidence in particular crops, then there may well be reasons for not growing them. More emphasis, therefore, should be given in the guidance on ways of consulting and involving the public, and achieving confidence in situations where environmental risks are assessed to be negligibly small.

Appendix A: Key Farmland Habitat Types
Appendix A lists five above-ground habitats (crop, within-crop flora and fauna, headland flora and fauna, field margin and hedgerow), but only lists one below-ground habitat, namely 'soil beneath the crop'. A much more holistic view needs to be taken of the biota that live in the soils in which, and near which, crops might be grown. The soil ecosystem habitat should, therefore, be expanded to include the soil biota in the headlands, in the field margins and in hedgerows. Again, as noted above, the Appendix implies that we are dealing solely with agricultural ecosystems, which should not be the case.

Additional Information
In responding to this inquiry the Society would like to draw attention to the following Royal Society of Edinburgh responses which are of relevance to this subject: Review of the Framework for Overseeing Developments in Biotechnology (February 1999); The Scientific Advisory System – Genetically Modified Foods Inquiry (March 1999); Science and Society (June 1999); The OECD Edinburgh Conference on the Scientific and Health Aspects of Genetically Modified Foods (February 2000) and the Agriculture and Environment Biotechnology Commission's Work Plan (November 2000). 

For further information, please contact the Research Officer, Dr Marc Rands.

December 2000