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AgBioView 'Special on UK Farm Scale Evaluation - Comments and Analysis'
- From http://www.agbioworld.org : November 18, 2003

(Click here for more FSE articles and analyses)

* Can Birds, Weeds and Sugarbeets Coexist?
* Media Pounce on GM Data
* Chain Reactions
* GM Trial Results Reverberate
* Evaluating the Farm-scale Trials
* Submissions to ACRE on the Farm Scale Evaluations

Can Birds, Weeds and Sugarbeets Coexist?

- Leonard Gianessi, AgBioView, Nov 16, 2003 http://www.agbioworld.org; (National Center for Food and Agricultural Policy, Washington, DC; gianessi@ncfap.org

The release in the United Kingdom of the Farm Scale Evaluations (FSEs) that compare the planting of genetically engineered (GE) maize, sugarbeets and oilseed rape with plantings of conventional crops has sparked a useful discussion of the tradeoffs involved in the adoption of agricultural technologies.

The bottom-line message from the FSE experiments is that in fields of sugarbeets and oilseed rape, there are fewer weeds in the genetically engineered fields than in the conventional fields while in the maize trials, the reverse is the case. The genetically engineered crops have the ability to tolerate certain herbicides that kill conventional varieties. Thus, the only change between the fields is that in the GE fields, growers switch to a different herbicide applied at a different time of the season to kill the weeds in the field. In sugarbeets and oilseed rape, this herbicide program is more effective than herbicides used in conventional fields, while the herbicide program is less effective in maize.

Hence, the result is more dead weeds in sugarbeets and rape and fewer dead weeds in maize with the switch to the herbicide used with the genetically engineered varieties. One concern raised in the U.K. is that fewer weeds in a field means fewer weed seeds and insects that are food sources for birds.

The FSE report cited our estimate that the adoption of herbicide-tolerant GE sugarbeet varieties in Europe could lead to a 60 per cent reduction in herbicide use (available at www.ncfap.org). The FSE report showed a 36 per cent reduction in herbicide use in the comparison of conventional and GE fields in the U.K. The FSE analysis did not compare sugarbeet yields nor did it compare the costs of the weed control programs. In our study, we estimate that sugarbeet yields would be about 5 per cent greater in GE fields, and that the cost of weed control would be 56 per cent lower.

Herbicides are used on almost 100 per cent of the UK's sugarbeet acres. A small minority of U.K. sugarbeet acreage is organic (0.2 per cent), and the biggest problem for organic growers is controlling weeds without herbicides. Our aggregate impact estimates can be compared with aggregate estimates extrapolated from the FSE experiments to more fully identify the potential tradeoffs of switching from conventional weed control to GE varieties on the U.K.'s 422,000 acres of sugarbeets.

Weed control in conventional UK sugarbeet fields is currently very effective with conventional herbicides. The FSE data indicate that 132,000 weeds per acre persisted with conventional herbicides, which represents 95 per cent fewer weeds than an acre not treated for weed control (2.5 million). Conventional sugarbeet growers in the U.K. are currently killing 999 billion weed seedlings each year. The gain for killing these weeds is that U.K. farmers produce 9 billion kg of sugarbeets, of which 81% (7.3 billion kg) would be lost due to uncontrolled weeds.

The FSE data indicate that in the GE field, 101,000 weed seedlings would remain. This implies that the planting of GE sugarbeets would lead to the death of another 13 billion weed seedlings, or about a 1% increase over current conditions.

One other possibility that is described in our sugarbeet case study is that the U.K. could forego the overall five per cent yield increase on every acre currently planted to sugarbeets and instead maintain current overall production levels on five per cent fewer acres. Farmers could take every twentieth acre out of production, and it could be devoted to some other purpose, such as growing weeds for bird feed. If five per cent of the U.K.'s sugarbeet acres were devoted entirely to growing weeds (21,000
acres) those acres would produce an additional 49.7 billion weed seedlings, a far greater number than the additional weeds that would be killed in GE fields.

We estimate that in the U.K., a switchover to GE sugarbeets would reduce pesticide use by 222,000 kilograms/year, increase sugarbeet production by 450 million kilograms/year and improve grower net income by 41 million euros/year.

The FSE analysis did not address the question of how many fewer birds would live in GE sugarbeet fields or estimate their aggregate value. To directly compare our impact estimates with FSEs, it would be useful to know the number of birds and their estimated value.

****************

Media Pounce on GM Data

- Bernard Dixon, Current Biology, Vol 13 No 22 R856

'Bernard Dixon reports on the reaction to the publication last month of the results of Britain's three-year field-scale trials of three genetically modified crops.'

Readers of the Britain's Daily Telegraph must be confused. 'Field trials show GM crop farming could be 'disastrous' for wildlife' said its news report ont he UK's field-scale GM crop trial results. Bumblebees, butterflies, skylarks, yellowhammers, house sparrows, beetles and slugs all faced disaster if ministers approved the nation wide cultivation of transgenic plants

Anyone turning to the leader page, however, found a very different picture. 'All that motivates anti-GM feeling is fear of the new, a perfectly justifiable emotion until tests such as these show how unfounded and irrational it is,' an editorial announced. The findings did notp rove that genetically modified crops were dangerous. 'All they show is that GM beet and spring rape crops encourage fewer weeds… than conventional crops. And when it comes to maize, more weeds grow… And that's it -- no venomous seeds, no wiping out of organic food, no spectre of agricultural holocaust.'

As for superweeds which 'pickup genes from GM plants and turninto nightmarish, irrepressible triffids', there was no indication that transgenic plants were more likely to do this than conventional ones. Anyway, what was wrong with transgenes which make' exactly the same toxins that organic farmers slosh all over heir crops'?

The Daily Telegraph's robust defence was a conspicuous exception to a media scene characterized largely by gloom and even terror. The Daily Mirror's headline 'Silent Spring' introduced a grim portrait in words and pictures of a landscape ravaged by recombinant DNA technology. 'Green campaigners say the results… foretell a future without birdsong in the spring as their food and habitats are hit,' wrote parliamentary editor Paul Gilfeather.

He quoted Tony Juniper of Friends of the Earth as saying that 'The impact of GM crops on wildlife is very dramatic. The government has no alternative but to stand by its pledge to ban GM crops.' Greenpeace's view was that 'Tony Blair should close the door on GM for good.' Only the Guardian published a comparison of favourable and unfavourable reactions to the trial results. Headlined 'Outright ban, caution or green light?', and occupying a whole page, it set out responses from industrial, activist ,scientific and consumer sources, together with opposing personal testimonies from two farmers.

The Guardian's own conclusion was simply that 'the government has yet to find an argument that has convinced the public that GM is a green revolution we can ill afford to miss out on. Until ministers do so, GM crops will remain a much talked about idea, but never an eaten foodstuff.'
'Proven: environmental dangers that may halt GM revolution' headed The Independent's coverage. 'British scientists delivered a massive blow to the case for genetically modified crops yesterday when they showed, in a trail-blazing study, that growing them could harm the environment,' asserted environment editor Michael McCarthy

Apparently unaware that the pharmaceutical industry has been using recombinant organisms for many years to make life-saving drugs, the Independent's editorial writer added: 'It may yet be that genetic engineering could produce huge benefits to human kind, helping to feed the multitudes and cure them of all manner of diseases. These were the promises that lured a technocratic prim minister into uncritical support for Britain's biotechnology industry.' 'The verdict could hardly be more devastating for a government that always thinks it knows best,' said the Daily Mail.' Three years of farm trials on GM crops have shown that they risk creating a biological desert, with our countryside denuded of butterflies, bees, beetles and songbirds.'

Journalists on all sides told readers that, as the Daily Mirror put it most succinctly, 'the technology damages wild life'. Few voices pointed out that the trials were actually about the (intended and predictable) effects of powerful weed killers rather than about transgenic manipulation as a generic process. Likewise, few observed that GM was being blamed for environmental consequences of the increasing intensification of agriculture that has occurred ever since the industrial revolution.

One person who did offer this wider insight was Andy Coghlan in the weekly magazine, NewScientist. 'Although these farm scale evaluations are being portrayed as tests of the environmental credentials of GM crops, it is really the weed killers to which they are resistant that are on trial,' Coghlan wrote.If the aim of the exercise really was to save farmland wildlife, then banning any of the transgenic plants tested was unlikely to make much difference.' That's because herbicide use in the UK is soaring even before any GM crops are introduced. And in the long term, farmers denied GM crops may instead turn to non-GM crops bred to be resistant to the herbicides.' Now being developed, these do not have to undergo the same regulatory scrutiny as transgenic plants.

The Independent's report hinted that GM per se should not be the target of criticism, but did not explore the idea further. It did provide a telling quote from Brian Johnson of English Nature: 'The results confirm our long-held concerns that some (my italics) GM-herbicide resistant crops could further intensify (my italics) arable farming and harm wildlife.'

Cogent remarks not from journalists but from newspaper readers amplified these much more reasonable perspectives. 'I can hardly believe it,' wrote Michael Egan in the Independent.' An intensive scientific investigation reveals that the use of aggressive weed killers reduces the number of weeds, which in turn has an effect on wildlife further along the food chain.' Inconsequence, transgenic technology 'carries the can.' 'Can we please have a more adult reflection on the whole context?… It is intensive, monocultural farming practice that has the real environmental impact, and it is our desire for cheap food that has made this happen. To portray GM technology itself as being fundamentally responsible for the study findings… is wholly misleading and deflects attention from deeper considerations.' True.

But why leave it to readers to make the most crucial points of all?

--
Bernard Dixon is the European editor of the American Society for Microbiology

********

Chain Reactions

- Nigel Williams, Current Biology, Vol 13 No 22 R854

The farm scale trials were the largest and most thorough of their kind in the world. But, as the previous article argues, they were essentially a test of the herbicides in common use today. The results however, reveal just how potent the use of herbicides can be on the wild life living in and around modern arable fields.

Scientists had never previously been able to observe how changing farm practices are affecting wildlife across the country. They costed £5 million and lasted four years. 'It is the first time a novel agricultural technology has been trialed extensively before it has been introduced rather than examine the consequences after it has been introduced,' said Chris Pollack, chairman of the scientific steering committee which oversaw the studies.--

The trials were designed to test whether weeds and insects fared better in fields of conventional crops or crops which had been genetically modified to be resistant to a herbicide In GM crops it meant the farmer could use one application of herbicide to kill a large spread of weeds in one go without harming the crops. Conventional crops might need several applications of different herbicides at different stages in order to keep weeds undercontrol.—

The trials were held becauset here had already been a steady decline since the 1960s in the number of weeds because of increasingly intensive agriculture. As a result, there has been a reduction in a wide range of animal species, including bumblebees, grey partridges and corn buntings. They were losing both their food sources and their habitats. Scientists were surprised to find considerable differences between conventional and GM crops and that they were so marked – as much as five to one in the number of weed seeds produced in conventional oilseed rape compared with the GM variety. The results were also remarkably consistent across Britain, although scientists had expected regional variations. This led them to believe the results would apply across the whole of Europe

'The introduction of GM cropping will affect wildlife. We were asked to see differences and we found them,' said LesFirbank, a senior scientist at the Centre for Ecology and Hydrology at Monks Wood in Cambridgeshire. There were 273field trials, 68 fields of maize, 67of spring-sown oil-seed rape an66 of beet, both for sugar and fodder. Studies on winter-sown oil-seed rape are still to come. The GM maize and rape were resistant to Liberty (glufosinate ammonium) made by Bayer Crop Science, and the GM beet to Roundup (glyphosate) made by Monsanto. Each trial field was divided into two, half sown with the GM crop and half with its conventional equivalent. Farmers were allowed to treat the crops as they would normally, deciding when to plough and when to plant crops, and when to treat with herbicides.T he researchers monitored the plants and animals in the fields, around the ploughed edges oft he fields, before, during and after the crops were grown. Each field was visited 15-20 times peryear

Researchers measured the number of grasses and broad leaved weeds. This gave a good measure of the quantity of foliage, flowers and stems that were above ground and available for animals to eat, as well as how many seeds the weeds produced. Another measure was how many seeds fell from the weeds on to the soil surface, known as 'seed rain'. This allows researchers to predict how many seeds would be available for insects and birds to eat. This is particularly important because some farmland birds – skylark, corn bunting and yellowhammer -- which rely on weed seeds in the autumn and winter have been declining. The number of weed seeds left to provide plants for the future was also measured. The researchers monitored the numbers of insects in and around crops including butterflies, bees, ground beetles, springtails (which live in the soil), and true bugs, as well as spiders

In spring the density of weed seedlings in the GM beet fields was four times that in the conventional crops because many farmers had sprayed to kill weeds in conventional crops before the beet seedlings emerged. However, applying Roundup to the GM crops in May halved the weed density compared with conventional crops. After this the biomass of the remaining weeds was six times lower and the 'seed rain' was three times lower compared with conventional crops. Although there were never many bees or butterflies in beet crops, there were even fewer in the GM beet crops, probably because there were fewer flowering weeds to attract them. There were also fewer butterflies in the tilled margins. Bee numbers, generally low everywhere, were even lower in the GM crops. Growing GM beet is likely to affect populations of weeds in the long term as seed stores will shrink

In the spring-sown rape trials, the researchers found 70 percent less volume of weeds in GM crops and 80 per cent fewer broad-leaved weed seeds. Springtails were significantly more abundant in July and spiders in August, just before the harvest. This was probably because the springtails feed on rotting weeds, which were more abundant in GM crops sprayed later in the year. The spiders were probably feeding on the springtails

Both the density and size of broad leaved weeds was three times higher in the GM maizef ields than in conventional maize fields. Taken together the weeds in the GM crops produced twice as many seeds as the weeds in the conventional crops. Over the growing season butterflies were attracted to the GM maize fields and field margins in the same numbers as conventional fields. There were three times as many honeybees in the GM field boundaries because of more flowering plants, but researchers stress that even in GM fields numbers were low. Growing GM maize would be an option for farmers wanting to replace more intensive and persistent herbicides such as atrazine, which is being phased out as too toxic. More weeds and seeds were produced in GM fields, suggesting that birds as well as small mammals like mice might benefit.—

But the glimmer of hope that some GM crops may be of environmental benefit compared to conventional crops comes against a backdrop of blanket consumer hostility to the crops. This has been so strong some research companies, such as Monsanto, have withdrawn their research programmes in Europe. This is leading to the loss of jobs and demoralisation amongst the plant research community. Insurers have also panicked, according to media reports, and are unwilling to insure any farmers who might wish to grow GM crops if the authorities give them the green light.

Whatever, it is the plant science departments bearing the brunt of future prospects. Chris Leaver, head of plant sciences at the University of Oxford, has had abusive phone calls and faxes and other direct attacks following his willingness to enter the public debate on GM crops

In Cambridge, three researchers are leaving the plant science department as a result of public hostility and dwindling industrial opportunities. Mark Tester, has written that his imminent move from Cambridge to the Australian Centre for Plant Functional Genomics marks a personal frustration at trying to carry out his work in the UK

Twenty-eight incidents of vandalism targeted at at basic plant research trials were reported between January 1999and April 2003, according to preliminary findings carried out by the independent body Senseabout Science. These are in addition to 52 incidents reported against the government's field scale evaluations programme

'The UK is now left with excellent plant-science research, but only at a fundamental academic level. The universities and the large research institutes now compete in similar research areas for a relatively modest budget compared with that enjoyed by US and Canadian colleagues.' says Tester. 'In my view, UK plant science is an unsustainable and risky passion, and so too is UK agriculture,' he says.

*****************

GM Trial Results Reverberate

- Philip Hunter, The Scientist, Nov. 17, 2003 http://www.biomedcentral.com/news/20031117/06/

'The UK's farm scale evaluations are shaking things up in Europe'

The results of the world's largest study of genetically modified (GM) crops' impact on biodiversity, completed last month in the United Kingdom, were mixed and limited. But the huge scale of the project is ensuring that the results are being carefully digested across the whole of Europe.

The mixed results, with GM oilseed rape and sugar beet faring badly while maize appeared to have beneficial results for the environment, have provided ammunition for proponents and opponents of genetically modified organisms (GMOs) contacted by The Scientist. "People in favor of GMOs say the results mean we should analyze all crops case by case," says Daniel Evain, a French farmer and keen observer of the GMO debate as a former agronomist with Monsanto, a food biotechnology company.

This line also has a significant number of advocates in Germany, according to Hartmut Meyer, coordinator for the European NGO-Network on Genetic Engineering. "These results have had quite an impact, at least in so far as they make clear that you can't have a one-size-fits-all approach to risk assessment," says Meyer. "You have to look in a specific country and circumstance."

On the whole, the UK Farm Scale Evaluation (FSE) results have tended to swing journalists and opinion formers against GMOs within Europe, certainly in France, Evain argues. "Before the results, they were either in favor or agnostic," says Evain, "but now they tend to be more skeptical, asking more questions."

However, biotechnology companies have taken great heart from the results, according to Bernard Marantelli, spokesman for the Agricultural Biotechnology Council representing biotech companies such as Monsanto and Dupont. "The results show that GM crops can be grown in a flexible manner, with benefits for biodiversity. An aspect of the results that was not well publicized was that the three GM crops in the FSE trials all had reduced amounts of spraying, compared with the non-GM versions," notes Marantelli.

The FSE trials concentrated on the effect on biodiversity of managing genetically modified herbicide-tolerant (GMHT) plants compared with conventional varieties, with particular emphasis on weeds within crop fields. About 180 fields in total were sown with maize, sugar beet, and spring oilseed rape in equal proportions. "The results were quite clear for two of the crops, the beet and the oil seed rape--there was no doubt that wildlife was reduced for those spots that have GMHT," says Professor Joe Perry, the statistician with co-responsibility for design of the FSE studies and analysis of the results within the consortium conducting the research.

For maize, the results were completely the other way around, but the fact that the herbicide atrazine, used to control weeds for the non-GM part of the study, had just been banned throughout the EU puts the relevance of those results in some doubt. However, the study's architects suggest that the results would have been broadly similar if alternative herbicides to atrazine had been used.

The results will shape public policy and determine the fate of applications involving release of GMOs throughout the European Union for years to come, says Perry. According to Chris Pollock, chair of the scientific steering committee for the £5.9 million ($10 million) FSE study, the results will provide the baseline data for ecological modeling and extrapolation of the impact of GMO crops on biodiversity worldwide. “This is a bloody good piece of science and will have a huge impact in its subject area for a long time to come,” says Pollock. The results go beyond the GM issue, Pollock insists. "The essence here is the new agronomy. The natural balance in a country like Britain where wildlife and farming go hand in hand is very sensitive between productive and nonproductive use of photosynthesis."

Although statistically powerful, the FSE study was confined to biodiversity. And according to Perry, further trials are needed to provide more data on contamination by GM crops of conventional crops growing in the vicinity. As he points out, the maximum limit for GM contamination tolerated throughout the European Union has been reduced from about 1% to 0.09%. “There's not much data about contamination at such very low levels,” Perry notes. The GM community is eagerly awaiting two UK studies looking at contamination both at very low levels and over long distances resulting from wide-ranging pollinators or unusual winds, but these are not due to report for up to 3 years.

Among other studies still needed are further investigations of different GMO categories, including crops engineered for virus resistance, according to Meyer.

The problem is that such studies would be expensive on the scale required for statistical significance, at a time when public resistance to GM foods is hardening across Europe. GM farmers are having to cope not just with vandalism from protesters, but with growing difficulty obtaining insurance. A recent UK survey by the campaigning group FARM found that many leading UK insurers will no longer provide indemnity cover for liabilities arising from growth of GM crops, such as claims from neighboring farms over contamination.

Links for this article
R. Walgate, Mixed results for GM crop trial, The Scientist, October 16, 2003. http://www.biomedcentral.com/news/20031016/08/ 

European NGO-Network on Genetic Engineering http://www.genet-info.org/ 
UK Farm Scale Evaluations http://www.defra.gov.uk/environment/gm/fse/index.htm 
Agricultural Biotechnology Council http://www.abcinformation.org/ 

************

Evaluating the Farm-scale Trials

- Conrad Lichtenstein, Spiked Online, Nov. 13, 2003 http://www.spiked-online.com/Articles/00000006DFBF.htm

The findings of the farm-scale evaluation (FSE) of spring-sown genetically modified crops were recently published in a special issue of the Philosophical Transactions of the Royal Society. The FSE was designed to evaluate farmland biodiversity, comparing genetically modified herbicide-tolerant (GMHT) crops to conventional crops.

That the evaluation involved GM crops is not relevant: herbicide-tolerant crops can also be, and indeed have been, developed by conventional methods. GM is a process not a product - and, as demonstrated by this study, each new product (whether it is GM, conventional or organic) needs to be evaluated on a case-by-case basis using rational evidence-based science.

Indeed, the FSE was actually a herbicide experiment, comparing the direct effects of different herbicides and treatment regimes. The robustness of the data surprised the research teams in being remarkably consistent across a wide variety of soil types and weeds in different parts of the country. It was also the first large-scale ecological study of its type.

Over three growing seasons, GMHT maize, sugar and fodder beet, and oil-seed rape were compared in about 65 split fields to their adjacent non-GM equivalents. Similar studies on autumn-sown oil-seed rape should be published in spring 2004.

There is no early or pre-emergence spraying for the GMHT crops, so it is not surprising that the FSE found higher weed numbers and biomass early in the growing season. But for beet and rape the regime for GMHT was found to be more effective at weed control than for the conventional crops, giving lower late-season weed biomass and seeds. Indirect effects further down the food chain on the animals that feed on weeds - such as bees and butterflies - showed a net reduction in numbers.

In maize, however, the opposite result was found: GMHT maize herbicide regimes support more weeds and feeding invertebrates than conventional maize. For all three crops there was an increase in detrivores (animals that feed on the increased amount of weed detritus arising from later spraying). Importantly, differences in biodiversity between crops - for example, maize versus rape - are greater than differences between GMHT and conventional rape, or beet or maize. There were also lower inputs of herbicides for the GMHT crops.

The FSE did not evaluate differences in yields of GMHT compared to conventional crops. But since farmers elsewhere choose GMHT crops we must assume that they outperform conventional varieties. And since GMHT gives better weed control it makes farming more efficient, which allows: more food to be grown, cheaper food, less land under cultivation, increased profits for farmers, reduced farm subsidies, or any combination of the above, according to the rules set by the government. Nonetheless the FSEs were of course presented to us as bad news for the environment by most of the national press and the anti-GM pressure groups.

But let us look at these FSEs in the context of agriculture in the UK as a whole. Any increase in agricultural efficiency must be at the expense of the wild ecosystems with which they compete. Conventional and organic farming both 'damage the environment' and 'reduce biodiversity'. In the UK, 75 per cent of the land is given over to farming, with the remaining 25 per cent shared with cities and towns, roads and managed forestry, leaving little in a virgin wild state of what was once mainly forest. The destruction of hedgerows, the use of fertilisers and silage, the introduction of winter-sowing and of 'foreign' crops have all added to the destruction of the natural environment and the reduction in biodiversity.

Thus we are faced with choices in how to provide the balance we desire between wild ecosystems and the agriculture and industry with which they conflict. And clearly we should use the most economical and least damaging methods to achieve this desired balance.

For example, beet and rape support more biodiversity than maize (which is much taller, inhibiting the growth of weeds beneath). Crops in the FSE, in ranging between one and four per cent cultivated land area, are dwarfed in their coverage of the national cropped area by the cereals - for example, winter wheat is about 44 per cent. Yet the cereals, which were not the subject of this FSE, also support less biodiversity than beet and rape.

Surely it is more rational to make large-scale strategic decisions about which crops to grow for biodiversity? Dramatic changes in biodiversity could be effected by changing the crops grown - such as growing less wheat or maize and using beet and rape as break crops more extensively. Relatively small changes here might dwarf the effects on biodiversity of GMHT beet and rape in relation to conventional varieties.

But inefficient agriculture requires more land. If GM technology produces crop varieties with increased yields, another strategic decision would be to maintain current production quotas, so leaving more land for wildlife.

The FSEs set a new precedent in being the first studies of their kind conducted before the implementation of a new technology, allowing a decision as to whether to shut the stable door while the horse is still inside. The studies took three years and cost almost £6 million; they have given radical new insights into the ecology of agricultural systems that may allow future predictive mathematical modelling to be performed that may make future evaluation cheaper and more rapid.

However, the studies were based on very specific herbicide regimes. For example, the maize studies indicated that GMHT crops supported greater biodiversity than conventional crops - but atrazine, the herbicide used by 75 per cent of the farmers in the trial, has now been banned. So presumably, any decision as to whether to approve the use of GMHT maize will require its evaluation against the new conventional herbicide regime that replaces atrazine.

Indeed, the logical and most honest extrapolation from this FSE is surely that any future change in a herbicide or spraying regime on any crop - be it GM, conventional or organic - will also require a farm-scale evaluation. If not, what was the point of this recent FSE? But will newly evaluated herbicides remain still-born within an FSE, to become superseded coincident with their approval by the continual need to re-evaluate them against the latest new technology? The FSEs were funded by the public sector. So if this Kafkaesque nightmare is really unleashed upon us, and indeed this new precedent is set, who will pay for these future evaluations?

Meanwhile, back on the organic farm, the 'organic horse' bolted long before 'stable doors' had been invented: organic farmers use old-fashioned herbicides that, because they are less specific in their toxicity, are rather poisonous beyond their intended victims, the weeds. Yet they are in use, because their adoption preceded the regulations now required for approval of modern herbicides. As we know, organic farmers and consumers are concerned for the environment - surely they should therefore also be willing to submit their herbicides to the same farm-scale evaluations?

Organic farmers should also accept that the process of GM technology, which indeed is by definition a very organic technology, is simply another tool for plant breeding and can also provide future new products. In other words, new plant varieties that can be more readily grown by the 'organic' process. For example, GM crops that themselves produce safe pesticides against target herbivorous insects would pre-empt the need to spray with pesticides. It would also make organic food safer by preventing the damage inflicted by feeding insects that allows invasion by fungal pathogens producing carcinogenic toxins. The fact that GM can be used to produce these kinds of crop varieties, suggests that there is no contradiction between organic and GM.

---

Conrad Lichtenstein is professor of molecular biology at Queen Mary, University of London. He is committed to the public understanding of science within the GM debate and is a member of the CropGen panel.