Response to the :

Consultation on proposals for managing the co-existence of GM, conventional and organic crops.

In Three Parts

1. Preamble :
My current thinking on the GM consultation and examples showing why I consider people and the environment should have maximum protection against mutant crop spread.

2. Seven Major Concerns :
A list of the issues I consider important in the GM debate.

3. Detailed response by Paragraph :
Comments on the specific proposals and ideas submitted in Defra document : PB 12047 T12084

PART ONE

Preamble

First I would like to say I found reading the document firstmentioned, upsetting. It appears to be such a detailed set of proposals that it is onerous to have to trawl through the pre-set notions. There seems to be little scope for public input and I imagine that what I do say will be largely ignored.

I had arranged a small public meeting and the only other person who attended was so upset by what they read they felt they could not respond. Their view is that this is just a public relations exercise with no significant material setting where public opinions could effect the co-existence proposals. Most of the other people I invited said it was a complete waste of time as GM contamination will just keep growing. The significant factor here is that the people I invited were generally vegetarian or vegan and bought much of their food organically and almost all their food GM free. These people are the backbone of the 'concerned' food market and the most likely to be upset and find their preferred GM Free foods increasingly unavailable.

Whereas I agree with the above sceptical view, I have the added view that public relations are important, as it is only the demand for GM free crops that has encouraged the EU to develop legislation on economic grounds.

With the WTO intolerant to health and environmental arguments, the UK Farm-scale trials, deemed grossly inadequate by many, did provide information which encourages the notion that genetically mutated crops are not very benign in the majority of environmental factors.

So whereas I welcome the idea that non-GM crops should be protected from genetically mutant pollen contamination, once the contamination starts it's likely to gather momentum.

Examples of uncontrolled spread are :

• Canada (rape)

  • 'Superweed' invasion threatens farms

    Industry has created a canola monster on the Prairies: experts

    Southam Newspapers (Saskatoon Star Phoenix, February 6, 2001)

    By Tom Spears

    Ottawa --- Genetically modified 'superweeds' have invaded Canadian farms -- canola plants engineered to help farmers that instead escaped and crossbred with each other to form plants stronger than their parents.
    
    Most pesticides can't kill these canola superweeds, which are sprouting up in wheat fields and other areas where farmers don't want them, Canada's expert panel on biotechnology says.
    
    Three types of canola, each engineered with genes to resist one type of weed killer, have merged into new varieties resistant to many pesticides. Instead of helping farmers kill weeds, the canola itself has become the weed.
    
    The superweed-canola is especially bad on the Prairies,where canola is a multibillion-dollar crop, says a report released Monday from the Royal Society of Canada's biotech experts.

    The biotech industry has been "naive" in thinking that good farming methods alone will hold superweeds at bay, the report says.

    And the panel warns that as the next generation of genetically engineered crops becomes more complex, it will be tougher to head off the superweeds of the future.
    
    Canola "is the classic example" of a superweed, said Brian Ellis, a co-chair of the panel and a molecular biologist from the University of British Columbia. Canola varieties such as Liberty Link and Roundup Ready were engineered to use with a pesticide (such as Roundup). The idea was that a farmer would plant canola resistant to Roundup, then spray the field with Roundup.
    
    Everything except the canola would die.
    
    Where canola is nearly pesticide-proof, it can crowd out other plants -- crops and weeds -- in farm fields.
    
    But its resistance to pesticides doesn't help its survival in the wild, where there are no pesticides.
    
    "The next generation.....is crops that come along carrying genes that make them more frost-tolerant or drought-tolerant. They have an advantage over their wild cousins," Ellis said.
    
    That means they will have a bioengineered advantage in taking over farm fields and in moving through wild areas.
    
    'Herbicide-resistant volunteer canola plants are beginning to develop into a major problem' on the Prairies, the panel's report says. (Volunteer plants are those that seed themselves.)
    
    In Saskatchewan, Bruno-area farmer Percy Schmeiser was sued by chemical giant Monsanto which alleges Schmeiser illegally grew its Roundup Ready canola on his field without permission, violating its patent on the gene. Monsanto is seeking damages and legal costs that could reach up to $400,000.
    
    Schmeiser contends the herbicide-resistant seeds contaminated his land after drifting in from other farmers' fields. A trial was held and a federal court judge must now issue his decision on the case.
    
    Canola has been farmed for only a few generations and so it still has some wide tendencies - such as dropping its seeds before a farmer can harvest them. This plants seeds for the next year.
    
    And plants, the report says, 'can be quite promiscuous.' Canola plants will breed with and other canola they meet, creating the phenomenon of 'gene stacking,' or accumulating all the genes originally built into different strains by different laboratories.

    This forces farmers to retreat to 'broad-spectrum' pesticides and chemicals that kill just about everything, such as 2,4-D. These are chemicals that farmers were trying to get away from in the first place.

    The point is, technology is still driving agricultural production along a chemical dependence route. And I think that's something the government has to take a serious look at," Ellis said.
    
    Biotech industry reps told the expert panel that good farming will stop superweeds from evolving.
    
    'This perspective may be unduly naive,' the report says. 'In the real world, human error and expediency may often compromise guidelines for the growing of such crops.'
    
    View the entire report presented by The Royal Society of Canada View the entire report presented by The Royal Society of Canada

  • Studies show gene flow in GM canola likely widespread. 4th July, 2002

    The study was completed last year but remained under wraps until its official release last week.
    
    The news that pollen (and genes) from GM canola travel freely in the environment raises new concerns about genetic contamination.
    
    An Australian study found that gene-carrying pollen from GM canola can travel up to three km on the wind or insects. The present isolation distance in Canada between GM and non-GM canola is 100 metres

    In the Agriculture Canada study, scientists in Saskatoon found that nearly half of the 70 certified seed lot samples tested were contaminated with the Roundup Ready gene. Thirty-seven per cent had the Liberty Link gene. Fifty-nine per cent contained both.

• Mexico (maize)

  • TheNewsMexico.com - 6th December, 2001

    The Mexican Congress unanimously demanded this week that President Vicente Fox ban the importation of genetically modified (GM) corn, and claimed the new corn could affect the genetic integrity of Mexico's crops and threaten the country's food supply.

    GM corn has been a hot issue in Mexico since genes from U.S. GM corn were found in wild corn in the southern state of Oaxaca several months ago. The environmental organization Greenpeace has also claimed the Agricultural Secretariat, which has publicly supported introducing modified corn, is trying to open up the country's market to GM crops before legislation is passed prohibiting it.
    
    The Senate has also demanded access to the results of Agriculture's Secretariat's study of the affected corn in Oaxaca as well as advances in the creation of the federal commission for biosecurity. Meanwhile, the Oaxaca state assembly is scrambling to get agricultural officials to give out information on the status of corn in their state which "could have health repercussions for Oaxacans and damage the country's ability to feed itself," legislators said. --- Meanwhile in the mother of parliaments we can't even get a debate! source
    
    

  • The real story on Mexican corn contamination. 27th May, 2002

    (By Wayne Fisher)

    DICKINSON, N.D. - As North Dakota ponders the introduction of genetically modified wheat, farmers and policy-makers should take note of the alarming cross-pollination of Mexican corn, which now has been confirmed by the Mexican government.

    Jorge Soberon, secretary of the Mexican environmental ministry's national committee on biodiversity, reported the new findings to an international conference April 18 in The Hauge, Netherlands.
    
    According to two British newspapers, the Guardian and the Daily Telegraph, Soberon called the cross-pollination event “the world's worst case of contamination by genetically modified material.”
    
    Soberon gave his report three days after Agweek published biotech booster Dennis T. Avery's article (“Journal admits publishing phony biotech corn report,” April 15) crowing that the cross-pollination had been debunked. Evidently, Avery hasn't heard about Soberon's comments, or else he's trusting that his readers haven't, because May 6 (Activists should step aside”), he still was saying the cross-pollination was unsubstantiated.
    
    Tests
    
    The truth is that tests conducted by the Mexican government showed massive genetically modified corn contamination in the states of Oaxaca and Puebla in southern Mexico.
    
    In tests of 1,876 seedlings grown by local farmers, scientists found GM contamination in 95 percent of all sites. Contamination rates at specific sites ranged from 1 percent to 35 percent and averaged more than 10 percent.
    
    The tests confirmed a study conducted last year by Ignacio Chapela and David Quist of the University of California and published in the journal Nature.
    
    Soberon conjectured that the contamination may have come from corn imported from the United States and planted by farmers unaware it came from GM crops, Mexico outlawed GM corn in 1998.

Sadly DEFRA's proposal are minimal and can be seen to support the EU's conformity to WTO principals. It does little to protect consumer choice and even less for the choice of future generations and the biosphere as a safety net for benign evolution.

PART TWO

Seven major concerns

1. Levels of contamination.
   • Why as little as WTO.?
     As mentioned above and below, apart from reports of uncontrolled contamination, common sense says that the contamination is highly likely to spread even with the most rigorous co-existence measures. Therefore it would be better to start of with a more prudent threshold than that required for EU labelling regulations
   • There is a market for GM free even if the label cannot guarantee absolute contaminate-free foods.
     The argument is that the WTO won't allow restrictions that effectively reduce the growing of GM crops. Yet the hypocrisy of the WTO, EU, UK and ministerial departments is, not to give the same criteria for organic crops.
   • Surely anything that restricts the economic viability of GM crops is equally a WTO issue. See Canada's inability to sell GM Free, non-GM or organic canola since cultivation of GM canola.
   • There may be an argument that there is an unreasonable rejection of GM crops in the UK and the US(Monsanto and the likes) are unhappy about this. But WTO trade regulations seems only to provide legal backup for those least likely to need it, namely the big Bio-tech dictators. The organic farmer has no backing as it doesn't have the large financial entanglement with taxes, and governments.
   • Contamination levels are invisible to the public and reliance on the Bio-tech companies and complicit authorities is unnerving
   
   
   
2. Separation distances are a mystery.
   • First the separation distances seem laughable, given the contamination reported in Canada and Mexico (ante)
   • Whatever data used, whether from UK Farm-scale trials or elsewhere cannot be verified by the public, so as great a distance as possible would be the acceptable precaution. Anything less shows little concern to properly limit GM contamination spreading.
   • So although a lower threshold would be preferable, there is no way the public can tell what is going on. Organic food is easy to grow
   • An example of the alternative approach for human health, environmental security and consumer confidence is the organic market.
     The organic methods of cultivation do not need testing unlike the conventional chemical application or plant inherent GM pesticide creation.
     Common sense prevails in organic farming. Industrial and now bio-tech farming generators also generate data to tout advantages and the levels of toxicity. Organic farming is inherently benign and doesn't require such consumer persuasion by the self appointed do-gooder sceintolgist eggheads.
   
   
   
3. Organic produce contamination
   • In itself a small amount of contamination doesn't matter to health, and will be unrecognisable and in itself would not amount to a boycott of organic products
   • Organic products are bought for the whole idea that health is not a body centered commodity but consequence of the joy and happiness in knowing that I am creating a better place for all living things, not just myself
   • Consequently organic degradation is health issue due to its underlying input of carelessness consumer approach to life. This is tantamount to a purge on a religious choice to be free to practice a chosen lifestyle.
   • Hence the the requirement of organic food converts is the best possible environment to produce food. So any general increase in overall separation distances will be the preferable options
   • Failing a more general contaminate free environment, organic growers and consumers would prefer a greater threshold as this would encourage others to apply for the same.
   
   
   
4. How to test for contamination.
   • Well that there should be testing shows there are concerns.
   • Testing will be random
   • Cost of testing for organic producers will add to their burden
   • Increase separation distances so that there is a no reasonable likelihood of breaking the EU labelling threshold of 0.9%
   
   
   
5. Financial compensation

   Make the polluters pay. All partners in the GM venture should pay.

   • The seed producers should pay as companies like Monsanto are often careless and deceitful, misrepresent their products and pollute the environment. Despite their claims to be helping the world they are helping themselves to the world, yours and mine too by the way.
   • The EU labelling regulations are created to appease the market, not to check what Monsanto are up to or to protect the environment, so farmers are hardly the ones to blame. However they are complicit in using questionable bio-technology and should also pay. Farmer working hard to make ends meet will not have the time to query the accuracy of people like Monsanto. In fact as long the farmers think they are conforming to regulation the majority of farmers probably don't care, after all they'll get their subsides whatever.
   • If there are cases for compensation then the EU must take some responsibility. Creating and managing a detailed database and implementing fines for contamination should be their lot.
     
     
6. Environmental compensation
   • This is my greatest concern. Given the reports of rampant spread of GM in Canada, the US and Mexico there is an environmental impact that will be difficult to reverse, so separation should be more severe to stop GM contaminating the general environment.
   
   
7. Consumer compensation
   • Whereas there numerous references to financial compensation to farmers if they cannot sell 'premium' crops due to contamination above the threshold, there is no concern for the consumer.
   • To say consumer compensation is of little significance shows that there is no real concern for the consumer other than their current spending pattern. If the pattern changes then there will be no need to separate GM crops form others
     
   • Consumers are not easily compensated for lack of choice. Air and water free from chemical toxins was lost many years ago. Now we are to have our food contaminated with mutant chromosomes.
   • It seems that whereas the majority of consumers do not want these contaminates, toxic or otherwise, there is little that has been done to stop an increase in this bullying of the environment. Consumers do not have the financial weight to persuade the WTO or subject governments to care for their health or environment. Only by consumer boycotting of products can any leverage be applied. Yet most are so addicted to their immediate and short term comfort they cannot effectively boycott the plethora of products that degrade the environment and our personal health.
   • Where companies like Monsanto, with PCBs, Agent Orange etc have the necessary backing, they can get official sanctions (due to consumer growth and taxes) to spray and dump whatever they like wherever they chose. The fines issued for breaches of the biased legislation is a pittance to the profits made by the multinationals and the taxes paid to the authorities.
   • So what redress is there for consumers. GM Free seeds may become unavailable and so may GM free food if contamination is tolerated by a fine. Some practical redress is a backup store of non-GM or GM seeds and crops. Although this may seem unpracticle and difficult, it is not impossible. It just that it is an extra burden. However if farmers hope to financially benefit from this mutant crop, some thought ought to be given to what the consumers want. presently consumers do not want GM food hence the EU labelling. So what do you offer the consumer when the food is tainted??????

PART THREE

Detailed Responses by Paragraph

COEXISTENCE MEASURES: INITIAL CONSIDERATIONS

I am afraid you used these words flippantly.

• .... safe .... human .... environment .... minimise .... ' You use the words as though they have definitive meaning, whereas you decide what is acceptable in a society that will tolerate a certain number of deaths and ill health due to GM production and consumption.
• By 'safe' you mean politically safe. I.e that the current economic juggernaughts can maintain their momentum.
• By 'human' you choose to exclude all life forms that do not, can not or will not pay taxes and worseso, given the above item, enough taxes.
• By 'environment' Well what more can I say. This catch-all word is somehow supposed to transfer the idea that you care about safety on the whole of biological, material and cultural spheres of experience and expression, but this can hardly be further from the truth. The single purpose of the generation of GM technology is for those in control to exert more control on anything and anyone weak enough to succumb. Plants are an ideal inroad to the biosphere. Control the vegetation and you control all moving creatures.
• How can you be so complicant and uncaring. There's not a speck of spiritual value in your proposals. There is no regard for life as sacred to those that carry it, but focus on the carrier as a commodity to be exploited. Whether that commodity is a blade of grass, a new born calf, acres of habitat or the minds and thoughts of those creatures of passion, to you it is just a job trying to control it all. How you must revel in the prospects of genetic mutations. Be warned that you are also selling yourself to the future of bio-dictation. Hitler would be proud of how we have advanced.

There are two disturbing parts to this statement

• First. It appears you have no real intention to minimise any unwanted GM presence in non-GM crops, and don't use the EU label of 0.9% threshold as an excuse for defining non-GM here as that is partly what a consultation is to decide. Secondly you can't minimise a non-GM crop "so that it is below 0.9%." as if was above 0.9 it wouldn't be a non-GM crop. The logic of your statements is so flawed I wonder if the authors are either really stupid or think the readers are and then purposefully write misleading and deceptive statements.
• To minimise a 'non-GM crop' (i.e. that having less than the EU labelling threshold of 0.9%) requires a target of lets say 0.1%.
• As you declare later in your document, can hardly call them proposals really, as they are ludicrous with reference to the claims in this paragraph(1.) there is an expected contamination from other sources. So to try and get crops below 0.9% hardly fits the idea that there is any intent to minimise contamination, quite the opposite. The proposals and intention seem to provide a practice on how to achieve the maximum contamination that EU legislation will permit without regularly going over the limit. This is like encouraging drinking and driving as long as you only drink so much.

GENERAL BACKGROUND

As I said above. You appears to engineering a situation whereby farmers don't need to minimise any unwanted mixing but one whereby they are permited to mix to a predetermined level, set only by the EU labelling legislation

• First you create a scenario where there is unwanted mixing of GM and non-GM crops" creating the notion that there is 'wanted mixing'. Then you create regulations to add weight to the erroneous idea that you are going to protect those that don't want mixing. Whereas the truth is that you are doing you best to facilitate the mixing albeit restricted by consumer-led legislation half-heartedly draw up by the EU under great pressure form the WTO to allow as much US born mutant food onto our tables.
• The public do not want mixing of GM and GM-Free crops to create a mix of non-GM crops.
• The only people wanting a mix are those bio-tech dictators like monsanto who want us to eat their mutant seed and experimental farmers who want to get rid of their mutant crops

Here we go again with this Weapon of Mass Deception. UK Consumers do not want these mutant products, so how can you claim to be creating measures to alow this choice when you use EU 0.9 legislation to permit levels of contamination and do nothing to reduce any contamination further. I know you are afraid of what the WTO will do if we want GM free food, bomb us back to Stonehenge I suppose.

Well there's some hope then. Lets make separation distances greater for organic crops and start a precedent for consumer choice. You never know it may even be an economic breakthrough and catch on world wide. God, I mean US forbid!

This considers the impact of the dispersal of pollen or seed from the GM crop, and of cross-pollination with non-GM crops or related wild plants.

Please pay attention to the creation of superweeds in Canada. This is after only few years and a few mutant crop deployments.

The two ideas "must aim to minimise" and "do not exceed" are not compatible.

• In the first part you imply a desire to minimise and the second a desire to have a maximum.
• Whereas there may be an almost randomly selected threshold for statutory labelling that products contain GM. Any attempt to minimise the mutant contamination cannot be tied to the maximum permissible level purely on a labelling criterion.
• What you should be clarifying that there are no statutory coexistence measures aiming to minimise unwanted GM transfer into non-GM crops so that they do not exceed the EU 0.9% threshold."
• And that the measures proposed are so that farmers can maximise the unwanted contamination up the EU labelling threshold of 0.9% or

• Paraphrase

  "This means that any statutory coexistence measures must aim to minimise unwanted GM transfer into non-GM crops so that they do not exceed the EU 0.9% threshold."

  to:

  This means that any statutory coexistence measures must aim to maximise unwanted GM transfer into non-GM crops but that they do not exceed the EU 0.9% threshold.

  As you feel restricted from minimising because of fear of the WTO

I assume that alternative arrangements will be made for

• 1. Seed banks
• 2. Certified seeds
• 3. Farm seeds

This second point is very disturbing and goes to the heart of the matter.

• It creates a situation where someone not wanting GM food may not be able to grow it themselves as their garden or allotment is contaminated and will have to find a non-GM source.
• It emphasises that the only reason for any regime is to support large economics.
• Home growers will just have to accept contamination with no recourse to compensation.
• This shows the inadequacy of financial compensation.
• Many home growers and allotment owners sell their produce as non-GM and sometimes 'organic'. It is unreasonable to deprive them of the foods and income they have generated by there own labour.
• It would seem that anyone selling produce that is to be non-GM should be protected, not just 'farms'
• Own grown food is still an 'income in kind' and obviated the need to purchase otherwise. To remove the ability for people to grow the food they want and to force them to buy from the market is to effectively close down another avenue of expression.
• This is exactly the creeping contamination and takeover of consumer choice that is the real fear, growing from uncontrolled genetic mutation.

Varying Distance by field depth.

Varying distances by field depth although understandable only benefits the polluter.

• It is possible that the adjacent non-GM growers area maybe a narrow field and if the level of contamination is an average of a larger field the product will be severely contaminated
• The best option is to a single distance whereby the worse contamination, i.e. from the adjacent the GM crops is of the order of 0.3% to allow for other contamination before marketing and the 0.9% threshold for labelling
• Dumbing-down separation distances should only be done with consent of the adjoining land owner, not by statute, as allowances for small fields could be hard to measure and ensure.

I strongly disagree with derfa's compromise on small fields. You seem to be allowing more contaminated produce on the market purely by it being part of a larger mix.

With this theory any farmer finding his crop is GM contaminated can just find other similar low-level crops to mix it with

This is an all to common, subversive, way of dealing with contaminates and should not be allowed.

* oilseed rape (fully-fertile varieties): 35m
* forage maize: 80m
* grain maize: 110m
Distance must be specific for the type of GM plant and the level of GM material in the plant how is this measured.

It is hard to imagine how defra accepts such figures given the widespread contamination experienced in Canada with canola(rape). So no, these figures are totally unacceptable.

Yes farmer agreements can be a simple option. However although there may be no apparent reason to inform anyone else an entry on a local register will provide openness and confidence as well as information for third parties and future analysis and should be a requirement.

It provides less work on the farmers part and should remove the GM farmers liability to his neighbour.

However their joint agreement would still constitute a need to control the spread of the GM contaminate and both should be held liable if the spread crosses both parties land.

Non-GM oilseed rape produced from farm-saved seed

The idea that a non-GM farmer and moreso an organic farmer should have to buy fresh seeds every other year is not only onerous and costly, but there is an increasing likely hood that GM free seeds will be available.

It is imperative that more is done to protect the seed bank and farmers that wish to use their own seeds. Where a farmer intends to grow seed for future growing special arrangements should be taken i.e increase the separation. (The Canadian standards for genetic purity are 99.95 per cent for foundation seed and 99.75 per cent for certified seed.)

COEXISTENCE BETWEEN GM AND ORGANIC PRODUCTION - POSSIBLE SPECIAL ARRANGEMENTS

Introduction

This statement above :

1. Possible introduction? :- Given the WTO's support is seems inevitable the GM crops will be grown. I imagine you use the word 'possible' to minimise any materially useful 'due account'. It seems from the following paragraphs you pay no heed to the needs of the organic sector other than it should succumb to the greater lobby of conventional/chemical farming liabilities.
2. Organic farming, as a premium crop, needs special treatment to show that there really is concern for : 
   1. the idea of biodiversity integrity, which you claim is important
      "Defra is supporting organic production because of the contribution it can make to environmentally sensitive farming." and
   2. that organic production is also an economically viable growth business.
      "In particular, there is a specific scheme that offers financial help to farmers converting to or maintaining organic methods".
3. Why then ruin the environmental and economic benefit of organic cultivation by not having improved tolerance for GM near organic crops.?

The government should argue for a different criteria for GM crops, not based on a measurable threshold, but on crop separation. The organic label should be applied to crops having sufficient distance from GM crops that there is no perceivable contamination. The current allowance of approximately 1% contamination will undermine the organic status. Further there is the possibility that in creating room for GM crops contamination will become rife and further measures will have to be taken to protect all crops. It is better at the outset to set a more stringent target for a sample crop market and organic crops are the ideal testing ground.

• This argument is misplaced as the benefit to organic farmers is based on GM free produce not non-GM standards of 0.9%. Consequently they do not seek a lower threshold but no decernable contamination to show integrity with wholistic concern for the environment.

• As mentioned above organic farmers are not trying to produce a special standard, it is the government that requires the standard. Organic farming does not seek to measure the amount of chemical pesticides that may float in their direction but

  a) chose not use them and
  b) provide themselves with ample room from non-organic agriculture to keep any perceived contamination to a consumer-perceived acceptable level.

• There seems to be a misconception as to what organic farming is. Although standards may be placed on foods being labelled organic, which may contain non-organic ingredients, organic farming is a method that does not seek a lower GM threshold or a lower pesticide level.
• The incorporation of a threshold for organic farmers is seriously flawed. Customers of organic food expect the absolute minimum i.e. zero tolerance. this may become increasingly unattainable and close the organic market.
• The proposed coexistence measures of distance would not achieve the same consumer confidence.
• Consumer confidence cannot be measured by facts and figures but by care and control. As a producer and consumer I want to know the best is being done for the environment irrespective of scientific data.
• As the organic market is a premium business it should not be threatened to the same degree as conventional crops so a contamination level of 0.1% should be considered and the crops coexistence distances increased to accompany this level.
• The employment of greater distances for organic crops is less likely to financially burden the GM farmer, than lesser distances would that of the organic. As the regulations are only generated due to the WTO preoccupation with economics then why should the economics of organic farming be ignored, unless of course the criteria of the WTO is not Fair Trade, but backing the multinationals that pay them. 

If there was a material intent to minimise GM contamination there would be no talk of thresholds. Thresholds for labelling make sense.

• 100% Meaning predominantly GM with no intention to minimise.
• 10% providing a product that was not grown GM but where there is some desire to minimise GM presence, maybe for animal feed.
• 1% A limiting factor for an easily verifiable low level
• 0.1% Showing a clear desire to minimise GM
• non-Gm Showing levels so low that accurate figures cannot be defined accurately but presence is detected.
• GM Free : Showing no recordable contaminates using current technology

You can't have it both ways. "this is the effective practical limit for reliably detecting a GM presence" and "Such a low level could not be enforced because testing is not accurate at this level"

Yes consumers of organic produce will buy the least contaminated produce :- 0.5,  0.1 or GM free

• The issue is not one of 0.51 or 0.49, but that a minimum crop separation has been implemented. The organic sector is about care for the environment and biodiversity. Knowing the best has ben done to protect it is more important that 0.01 above or below some arbitrary figure that seeks to bring confidence to the public that GM crops and the WTO do not decide what we consume.
• As you state, the cost of testing is prohibitive, hence all that is required is that crop separation is at a maximum.
• If contamination is at the square root of distance then increasing the distance two-fold should result in organic crops with an estimated 0.25 contamination level. I would like to see the drop off in contamination, presumably discovered via the 'Farm-scale trials/
• I suggest the distance is increased four-fold
  • This shouldn't be a problem as there is little organic production.
  • I imagine many organic producers have there own barriers which limit chemical drift so the introduction of a increased separation distance which includes that should easily be obtained.
  • A fourfold increase bring estimated contamination below 0.1%

A process-based standard

• Well !! yes it is best practice but any extra measures that are as invasive as mutant pollen etc should be liability of the GM farmer. Where the GM farmer is adjacent organic then extra crop separation should be employed. i.e four times the 'norm' created with agreement between the two growers.

The onus cannot be placed on the organic grower either.

1. to create the necessary crop separation to achieve a 0.1% threshold nor
2. to repeatedly pay for GM contamination testing

A situation where best practice on the organic growers part and increased separation by the GM grower would enable an organic label that meant GM Free to best practice and no testing required.

Any perceived extra cost the the farmer should be minimal. Anyway the seed producers can pay for it if they are so keen for their products to contaminate the environment.

REDRESS FOR ECONOMIC LOSSES

To limit redress to bona-fide farmers is a political-economic measure.

To discriminate against home/allotment producers, whether they financially benefit from selling their produce or from not having to buy 'GM Free' by consuming their own crop, is a breach of human rights.

* GM crops will only be grown in the UK if there is a market for them, and it should generally follow that a non-GM grower with an affected crop (GM presence >0.9%) will have a market in which to sell it.

* the potential need for a redress mechanism is predicated on non-GM crops (conventional or organic) trading at a premium. If the market does not distinguish between GM and non-GM (or if GM crops are grown which offer consumer benefits and themselves trade at a premium) no economic loss would occur to non-GM farmers and therefore redress would not be required.

* if effective coexistence measures are in place, then the instances where non-GM growers might face a loss due to a GM presence above 0.9% should be very infrequent; in addition, the value of any redress claim is likely to be relatively low (details on costs are given in the

A PUBLIC REGISTER OF GM CROPS

If non-food crops require registration, then it would seem more that sensible to register food-crops:

Include all fields.

As some farmers may not register promptly it will be

• a) good to have a pre-register and
• b) to have a record of past growers.

1. facilitate coexistence between farmers, by providing a clear source of information on proposed GM plantings around which arrangements can operate.
2. be a clear and transparent system for confirming the location of GM crops (or land on which they have been grown).
3. enable others with an interest to have ready access to information they may want (e.g. people growing plants in private gardens or allotments who might be concerned about GM cross-pollination, organic farmers, farmers thinking about setting up or maintaining a voluntary GM-free zone, or people buying land who may want to know if it has been used to grow GM crops)

All arguments are useful. Please keep them.

1. it is not needed to support Defra's coexistence plans if, as proposed, GM growers are required to notify neighbouring farmers as necessary of their intention to sow a GM crop.
   
   
2.  moreover, it is unlikely to be particularly helpful or practical for coexistence. Instead of the proposed notification requirement, GM farmers would need to register their cropping plans on the system and then neighbouring farmers growing non-GM crops would have to register any compatible crops. The GM farmer would then have to check to see whether this was within the separation distance and take action accordingly. This may be a more burdensome approach than direct communication between farmers.
   
   " moreover, it is unlikely to be particularly helpful or practical for coexistence".
   

   Either it is or it isn't you can't seriously state both. The EU states it would be useful (176) and so does (178.) ante.
   
   "Instead of the proposed notification requirement, GM farmers would need to register their cropping plans on the system and then neighbouring farmers growing non-GM crops would have to register any compatible crops".
   

   • The two are not mutually exclusive.
   • There is no disadvantage.
   • Farmers should register their intent nationally for an historic database and for third parties as well as informing their immediate neighbours for any co-existence regime.
   • It could be the legal requirement that farmers notify local government as a planning notification.
   • The local authority then inputs the information to a national database.
     1. The farmers should  provide contact details for their respective neighbours.
     2. Where these are not available, the local authority would still register the intent and would perform a search for the title holder at a cost to the farmer.
     3. The cost will encourage the farmer to take due care in finding the neighbours details.
     4. Where ownership of land cannot be found, after 3 months, notification will be waived.
     5. Local registration will also help local authorities and partners such as English Nature and other conservation bodies to object to GM planting where they deem the measures may have undesired effects, monitor the situation and/or make alternative arrangements with the GM farmer.
        
        
3. in relation to garden or allotment plants, there are no formal rules in respect of these being cross-pollinated by ordinary commercial crops, and it is important to remember that GM crops will only be approved for release if they are considered safe for health and the environment. Rules are needed to protect the interests of non-GM farmers because they must label their crops as 'GM' if they have a GM presence above 0.9%, but people growing plants for their own use or consumption are not affected by this legal requirement41. In these circumstances it would be difficult to justify introducing a statutory requirement for a GM register in relation to plants that are not for sale.
   
   
   • Gardens and Allotments can also be used for local produce for sale, so allotment owners, i.e. Local Authorities need notification. as will private homes where gardens are used to sell a small amount of vegetable and fruit etc.
   • Not to provide for the many small growers would remove a valuable service and some small, but significant, income, lifestyle and livelihood for many people.
     
     
4. If prospective purchasers of land want to know if it has been used to grow GM crops they can ask the vendor for appropriate details. The EU traceability and labelling Regulation 1830/2003 facilitates this by requiring farmers to keep records of where GM crops have been grown for 5 years. It would be difficult to justify setting up a detailed crop register for this purpose.
   
   
   • The detailed register would not be set up for this reason but could still be used by the public, and they could pay a nominal charge, easing the financial cost.
     
     
5. a public register may be misused. The Government’s policy of disclosing the location of GM trials has been abused by a small minority intent on ‘trashing’ the crops. There is clearly the potential for a similar situation to arise with commercial GM crops, and Defra is aware of one organisation that was set up with the specific intention of removing commercial GM crops from the ground. There has to be a concern, therefore, that a legitimate activity may be hindered if details of GM crop sites are made freely available.
   
   
   • misuse of the register can be limited by:
     • charging for access.
     • limiting access to, prospective buyers and local land owners
     
     
6. a register will cost money to operate. RICS has estimated that its proposed GM land register would cost about £150,000 to develop and £40,000 a year to maintain. Cheaper options are likely to be possible, but the Government would be hard pressed to justify using taxpayers’ money to fund a register, or pass on the costs to the industry, unless there was a strong justification in public policy terms.
   
   
   • Finances can be raised by :
     • A nominal charge to register
     • Charging for access

• Do it and
• Charge for it

• There is likely to be an increase in GM contamination with consequent, ecological and economic liabilities. A register would be a prudent measure.
• Further, despite the 'wriggling out of responsibility' tone of the above Defra arguments the EU does suggest it is a good idea. (176. ante)
• Do you always lean on the minimal conformity to external laws? Do you have no backbone to take your own steps?

VOLUNTARY "GM-FREE ZONES

Legal position on GM-free zones

ANNEX B

SECTION TWO - RISK ASSESSMENT

SECTION FOUR - RISK ASSESSMENT

Benefits

I am afraid you are considering that the premium paid for non-GM and/or organic produce is a personal health criteria based on the consumption of mutated genes, but the premium can also be paid the protect the environment from mutant contamination and to stop multinationals copyrighting biological entities.

The social impact of permanent damage to the environment and being slaves to bio-tech food dictators is far more worrying that eating a bit of GM food.

Accepting GM crops with the current level of laxity is arguably a threat to current life forms. It is an act of compassion and support not to partake in the current attitude of complicity to its uncontrolled spread. Knowingly allowing such degradation is harmful to the soul and I don't want to live like that.

A caring consumer-led society says no. With effective misinformation, industry-led consumers will swallow anything.

END

Yours sincerely

Roger Lovejoy

www.rogerlovejoy.co.uk/soapbox

0777 94 92 95 3

www.rogerlovejoy.co.uk