COPY OF THE BDAA'S REPLY TO THE MINISTRY OF AGRICULTURE RE THE PLACING OF CHARDON LL ON THE NATIONAL SEED LIST

 B.D.A.A

The Painswick Inn Project

Gloucester Street

Stroud

Glos

GL5 1QG

Tel/Fax 01453 759501

Email: daa@biodynamic.freeserve.co.uk

Website: www.anth.org.uk/biodynamic

Mr J Edgley

Ministry of Agriculture,

Fisheries and Food Plant Varieties and Seeds Division

White House Lane

Huntingdon Road

Cambridge CB3 OLF

Re: Proposed decision to add Chardon LL to the National List: written representations pursuant to Regulation 21 of the Seeds (National Lists of varieties) Regulations 1982.

Dear Mr Edgley,

I am writing on behalf of the Biodynamic Agricultural Association (BDAA) and wish to object most strongly to the proposed listing of Aventis' T25 GM Fodder Maize Chardon LL on the National List of Agricultural Plant Varieties (The Seed List)

The Biodynamic Agricultural Association is a registered charity founded more than fifty years ago to promote biodynamic farming and gardening in Britain. This unique and well-respected approach to organic agriculture is practised throughout the world with considerable success. The potential contamination of organic and biodynamic production as a result of the indiscriminate release of modified genetic material is clearly of direct concern.

The BDAA operates the internationally recognised Demeter symbol within the UK as an organic sector certifying body (UK6). It is registered with the United Kingdom Register of Organic Food Standards (UKROFS) and therefore clearly has "sufficient interest in the matter" to lodge an objection. Furthermore, through its network of affiliated producers, processors, retailers, and concerned consumers, the BDAA represents a wide range of interests directly effected by this proposal.

These interests include: · Registered Demeter producers growing sweet corn who are in danger of losing their certification if their crop is contaminated by pollen from GM Maize growing in the vicinity. · Many of our members growing sweet corn in their gardens or allotment who are very concerned about possible GM contamination and its potential side effects on health and the environment. · Consumers of biodynamic and organic produce concerned about possible GM contamination transmitted via wind, water, mutant organisms or by other means.

Grounds for Objection:

1) By placing GM Fodder maize - Chardon LL on the Seed List the government is clearly inviting immediate commercial planting, for once listed, it can be obtained and grown commercially anywhere in the country. This is unacceptable and directly contradicts government policy, a policy reiterated by Michael Meacher on March 11th 2000 with the announcement of a series of full scale GM crop trials: "I want to make it perfectly clear that there will be no commercial growing of GM crops in this country until we are satisfied that there will be no unacceptable effects on the environment." It also contradicts an agreement with the Supply Chain Initiative on Modified Agricultural Crops (SCIMAC) that: "there will be no commercialisation of GM Maize varieties in the UK until the farm scale evaluation has been satisfactorily concluded."

The current series of trials, set up to assess the impact of herbicide resistant crops on the environment, are due to be completed in 2003. It is irresponsible under the government's own terms to propose registering Chardon LL on the seed list at the present time. Chardon LL should not even be considered for inclusion on the Seed List until the trials are completed in 2003 and the results assessed.

2) In response to growing evidence of the potential dangers posed by GMO's to human health and the environment, the EU Deliberate Release Directive has been revised to require a more extensive and stringent safety assessment before any application to market a GM crop is approved. As a result, new applicants must include an assessment of: - indirect and delayed effects of the release - the delayed effects on animal health and consequences for the food/feed chain - impacts on the soil and soil nutrient cycles - the immediate, delayed, direct and indirect impacts of changes in agricultural practice brought about as a result of the release of the GM crop. An ongoing monitoring plan is also required.

The UK government and the EU council of ministers deemed these amendments so important that they were immediately implemented (December 1998). (i) To date no GM crops have been approved under this regime.

Since Aventis received EU marketing approval for its T25 GM cultivars before this revision took place; it was not obliged to submit them to these additional tests. - Unless it is required to do so, the good intentions of the EU Council of Ministers and the commitment of the UK government to place the health and wellbeing of its citizens before the interests of big business, is put in question - The registration of Chardon LL should therefore be withheld until these current regulations are met and this anomaly resolved.

3) Very little research appears to have been undertaken regarding the effect of feeding transgenic crops to animals. Since this maize variety is to be used exclusively for animal feed either in its green state or as silage, the lack of meaningful data is worrying both for livestock health and its effects on the human food chain via milk and meat products. Due to the likelihood of large quantities of GM forage, being fed to livestock on a daily basis as part of their feed ration, any side effects occurring would be magnified on through the food chain and the soil-plant nutrient cycle. This is recognised in the UKROFS Standards which state that: "Fertilisers, composts, manures and other nutrient inputs containing GMO's or their derivatives are prohibited. Manures from livestock that have consumed feeds containing GMO's or their derivatives within three months are prohibited. Fertilisers or manures derived from genetically modified crops, plant residues or by products are prohibited" (ii)

British agriculture is still suffering the consequences of BSE caused by ill thought through agricultural policies and a cavalier attitude towards animal feedstuffs. It would be tragic and foolhardy to allow a repetition of this disaster. Indeed the farming community as a whole could not survive another such scandal.

Until more research is undertaken and published regarding possible effects on the health of livestock and on the human food chain, it is irresponsible to consider registering Chardon LL on the Seed List.

4) The clear labelling of all animal feeds and especially feed compounds is a long overdue reform. The Governmenthas recently established an Advisory Committee on Animal Feedstuffs (ACAF) to look at this and other related issues.

There is no GM labelling of animal feeds as yet and until farmers can make an informed choice on the matter no further GM releases should be permitted. Without GM labelling it is premature to consider placing Chardon LL on the Seeds List.

5. A healthy soil life is absolutlely crucial to sustainable agricultural systems. The herbicide Glyphosate-ammonium which Chardon LL is modified to resist, is toxic not only to all kinds of plants but also to micoorganisms both bacterial and fungal and hence inimical to soil life. The decomposition of modified genetic material from plant remains in the soil could seriously affect the balance of soil microorganisms and be an ideal medium for horizontal gene transfer - What are the consequences of interferring in this sphere? What affect will it have on humus formation? A five year decontamination period is required before land previously down to GM crops can achieve organic/biodynamic certified status (ii) - an important consideration in view of the current rapid expansion of the organic sector.

Until thorough scientific research to answer these questions is undertaken, the results published and an impact assessment based on the results carried out, Chardon LL should not be listed. A land registry of land used for GM crops will also need to be in place before any GM seed listing is considered.

6) Since this GM cultivar is modified to be resistant to the herbicide Glyphosate-ammonium it follows that the main advantage to would be growers is the opportunity for more indiscriminate and likely heavier applications of herbicide to the crop. This being so, an increased toxic burden on the ecosystem would be the result and be of great concern to all organic producers especially those in the vicinity. Glyphosphate based herbicide compounds are extremely toxic to the health of livestock and humans coming into contact with them as well as poisoning soil organisims and effecting wild plants and trees up to 100 metres away. (iii)

It is apparent that the planting of Chardon LL would run counter to efforts being taken elsewhere by Government Departments to reduce toxic inputs in agriculture. It should therefore not be listed.

7) All registered organic and biodynamic symbol holders are commited to the minimum production and processing standards agreed through UKROFS.

The use of GMO's and their derivatives is prohibited under these organic farming regulations which also require that "all necessary measures to prevent any such contamination of organic systems during production, processing, storage, and transport" be taken (ii) "….once GM crops are released they like all crops, cannot be completely contained" (iv)

To prevent contamination, the growing of GM crops in the proximity of organic units and in the vicinity of other non-GM crops cannot be allowed. By placing Chardon LL on the Seeds List the cultivation of organic and non-GM crops are put at risk.

8) From the results of the VCU assessment for Chardon LL submitted by the Herbage VCU Group in February 2000 it appears that the only characteristic to have shown a significant improvement on existing non GM varieties is that of its dry matter content at harvest. While this variety could clearly have a value for cultivation and use, traditional varieties out perform it in most other areas assessed (v)

In weighing this small improvement against the many unresolved safety issues however, it is questionable if Chardon LL merits being considered for the seed list at all.

9) The government appears very eager to promote GM crops on behalf of the biotech industry and yet who will be liable in the event of an environmental disaster caused by these releases? Ultimately it is the tax payers who will have to foot the bill and they have not been asked.

The issue is currently under discussion in the European parliament and until this has been clarified and clear liability accepted by the industry, Chardon LL and other GM crops should not appear on the Seeds List.

In summary, there is considerable concern that the premature listing of Chardon LL on the Seed List will pave the way for its commercial planting before sufficient safeguards are in place; that lessons from the BSE disaster may not have been learned and that irreversible damage to our ecosystem may be recognised only when it is too late. While there are undoubtably some short term advantages in developing GM technology as a plant breeding method, the consequences over the longer term are unknown and could prove disatrous.

It is especially worrying that the interests of the biotech industry appear to override all other concerns. The recent newspaper article (Observer 16th April) even implicates the scientific research itself. This is extremely serious and inevitably throws the entire GM research programme into question.

The issue of the independence of scientific research urgently needs to be addressed. A full and public enquiry into the governments GM Research Programme needs to be completed before any further GM releases - either food trials or seed listings - are permitted.

Yours Sincerely

Bernard Jarman (Executive Director)

Enclosures: Cheque for £30

REFERENCES

i) ACRE/DETR Guidance Note 12. Guidance on Principles of Risk Assessment and Monitoring for the Release of Genetically Modified Organisms December 1999

i) UKROFS Standards for Organic Production Chapter 1 section 2 - Genetic modification - Incorporated 1.1.2000

 iii) Gyphosate (Round Up) Herbicide Fact Sheet - Journal of Pesticide Reform Autumn 1998 Vol 18 No 5

 iv) Organic Farming and Gene Transfer from Genetically Modified Crops Published by: John Innes Centre, May 1999

v) Herbage VCU Group February 2000, Published by MAFF Results of Tests and Trials Carried out on Chardon LL under Seed (National List of Varieties) Regulations 1982