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November 17, 2003


AGBIOVIEW SPECIAL: UK Crop Trials - Can Birds, Weeds and Crops Coexist?; Med


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

* Can Birds, Weeds and Sugarbeets Coexist?
* Media Pounce on GM Data
* Chain Reactions
* GM Trial Results Reverberate
* Evaluating the Farm-scale Trials
* Select Submissions of Public Comments to ACRE
* ... Aesthetically Beautiful but Practically Useless?


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;

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

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

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

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

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


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

'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

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

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

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,

European NGO-Network on Genetic Engineering http://www.genet-info.org/
UK Farm Scale Evaluations
Agricultural Biotechnology Council http://www.abcinformation.org/


Evaluating the Farm-scale Trials

- Conrad Lichtenstein, Spiked Online, Nov. 13, 2003

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

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

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.


Select Submissions of Public Comments to ACRE

See all at

The UK FSEs: Aesthetically Beautiful but Practically Useless??
We would like to make five points with regard to the recently published

We applaud the rigor and apparent objectivity with which the science was
designed and executed. Our comments should not be construed as a
criticism of the science, the investigators, or the committee that oversaw
the research project from inception to publication. Taken collectively,
the papers provide considerable new detail about numerical changes in
populations of a few selected species in a highly specialized habitat in
response to farm management strategies. These could reasonably be called
aesthetically beautiful studies of farm micro-ecology.

We submit, however, that the studies are essentially useless for the
purposes of advancing the public policy discussion on the suitability of
either GM or HT crops for UK agriculture or for the advisability of their
approval for commercial cultivation on a large scale for the following

1. The studies were unnecessary. Environmental safety assessments must
assess risks for worst-case scenarios. In this case, if perfect weed
control were assumed, it could have been concluded a priori that certain
weeds, weed seeds and insects would decrease in number. The researchable
question would then have been: what is the impact on bird populations?

2. Bird populations were not measured. The research would have been better
suited to assessing the suitability of HT crops if it had looked directly
at the impact of management strategies on biodiversity.

3. Yields were not measured. An evaluation of the suitability of HT crops
in the UK will ultimately depend on a balance between benefits and costs.

4. Biodiversity is not measured. Measuring a few species in isolated
plots of farmed land does not provide a valid estimate of biodiversity.
Counting some but not all of the species on what can amount in any given
year to no more than 15% of the farmed land leaves open the possibility
that significant changes have occurred in uncounted species. Failing to
measure the impact of weed control strategies on biodiversity in
surrounding fields with alternative crops as well as on unfarmed areas
further distorts the picture of biodiversity. No assessment is made on
the more important indicators of biodiversity: species and genetic

5. The research is not about GM crops. These studies compare weed
management strategies and not the GM nature of the crop itself.

While we appreciate that the skylark has adapted to life in agricultural
fields, farmland is hardly a very rich habitat for most wild species nor
does it support robust and biodiverse communities. Natural and unmanaged
lands are capable of supporting far superior biodiversity. Maximizing the
efficiency with which land is farmed could allow additional land to be set
aside for the establishment of nature preserves. Whether to foster high
numbers of sky larches in farmland or rich biodiversity in preserves is a
social policy decision. If poor weed control and more sky larches are the
choice, however, then it would be better to regulate which crops farmers
may plant since it clear from the FSEs that some crops (oilseed rape)
supported more weeds and insects whether conventional or HT.

The experience with HT crops in the US and elsewhere has established that
yields are enhanced by this technology. These increased yields observed
for HT crops have been accompanied by a rapid adoption of no-till
practices that can broadly be described as beneficial for the environment
and biodiversity . A move towards no-till agriculture leads to decreased
energy inputs, lower soil erosion and much healthier soils with respect to
structure , microbes , invertebrate species ,and soil organic matter. As
a consequence of these changes, conclude Fawcett and Towery, "the habitat
for birds and mammals improves." Crop management strategies also influence
aspects of environmental impact beyond weed and insect numbers in the
field. For example, the impact of pesticide residues on and off the farm
field could easily be evaluated and compared, for example, by using
Cornell's Environmental Impact Quotient

We conclude that the FSEs will be of little practical value in making the
important UK agricultural policy decisions that lie ahead with respect to
HT crops. Based on the years of effective performance and environmental
gains observed elsewhere with these crops, perhaps the most appropriate
research that could have been done in lieu of the FSEs would have been to
have approved the crops and monitored the results.

- Bruce Chassy, Chris Preston, Wayne Parrott, Steve Strauss, Alan
McHughen, Martina McGloughlin


1. The FSE results demonstrate that differences in the choice of weed
management approach can lead to differences in weed survival and in the
wildlife populations dependent on weed growth and development

2. The differences in weed and invertebrate densities reported in the FSEs
are not an inherent property of the GM crops, but instead are due to the
particular weed management practices examined in the various crops.

3. At least another variable should have been included into these trials:
cultivating GM varieties with the same weed control management as in the
field sectors planted with the corresponding conventional crops. No
differences between GM and conventional varieties as to weed flora and
invertebrate densities would have been found.

4. A further variable could have been useful: mechanical weed control or
weed control by hand, where the weeds should have been eradicated very
strictly in intervals of 2 or 3 weeks at least until the particular crops
had reached an advanced growth stage when they covered the ground
completely. The impact on wildlife would have been very similar to those
variables with the better herbicidal efficacy.

These considerations may emphasize that the type of crop variety (GM or
not-GM) is of no impact on wildlife and that the type of weed management
is the main factor.

- Sincerely yours, Peter Langelüddeke, Hofheim, Germany


'A 35% decline in farmland bird populations between 1973 and 1998
obviously flashes a warning signal that current agricultural practices are
not sustainable' said Baroness Young of Old Scone, English Nature's
Chairman. 'The gradual erosion of the traditional relationship between
farmers and wildlife, through the intensification and specialisation of
farming methods, has drastically reduced the biodiversity of England's
farmland.' English Nature press release. (10 December 1999).

It should be remembered that the Farm-scale Evaluation (FSE) trials were
initiated at a time when modern farming techniques were being much
maligned by conservation organisations for having a negative impact on
farmland bird populations.

Four years on, with the conclusion of the trials, L.G. Firbank et al argue
in their commentary on the FSEs that the possibility of reduced
populations of arable weeds 'exacerbating declines in birds that feed on
weed seeds … needs to be taken into account when assessing the impacts of
growing these crops'.

If we are to have a fair assessment of the management practices associated
with the three GM crops studied in the FSEs then we need to discuss and
debate more critically the prevailing preoccupation with farmland
biodiversity, and in particular the headline-grabbing discussion about
farmland birds, as these inevitably set the tone for any such assessment.

All too often 'farmland biodiversity' is referred to as a self-evident
good, and its decline as a self-evident bad, without any proper
explanation of what mix of organisms we are concerned about and why. To
the extent that a specific argument is made for the importance of farmland
biodiversity, it is often done in relation to human enjoyment of the
British countryside and with particular reference to the British public's
love of birds.

However, the contemporary debate about farming and bird populations is
heavily coloured by a tendency to overemphasise the destructive nature of
human activity. An examination of this debate provides a useful case study
in the cultural framing of questions about farming and wildlife, and how
this is usually done in a one-sidedly negative way.

The population levels of different bird species within the UK, in general
and on farmland in particular, have always been subject to change in
response to changes in human activity. Changing bird populations are
neither new, surprising or worrying. There is a danger that for cultural
and political reasons we are becoming overly sensitive to having any
impact on other species. Consider the following points:

An authoritative review of historical ornithological literature conducted
in 1944 found that '132 out of 189 breeding species, or 70 per cent, have
changed markedly in status during the course of the nineteenth and
twentieth centuries'. The authors noted that widespread species 'could
probably double or halve its numbers without the fact being noticed'.
(Alexander and Lack. 1944). Today a 25% recorded decline in a bird species
prompts a Biodiversity Action Plan being put into place – it seems that
today the government is unwilling to allow bird populations to fall as
well as increase, though this has always been the way of things.

The number of species breeding in the UK is thought to be around 20%
greater today than in 1800, despite the intensification of agriculture on
the 75% of the UK's land surface that is farmed. 'The number of breeding
species in the UK is increasing, with nearly 40 more species breeding at
the end of the 20th century than at the beginning of the 19th. ... In the
last 30 years there has been a net increase of four species per decade.'
(The State of the UK's Birds 1999, Gregory et al., RSPB, 2000)

But is there a particular problem with Britain's farmland birds? The
answer to this depends on what you count as a farmland bird. If you count
birds found on farmland and are prepared to accept that some bird
populations will fall whilst others rise, it is hard to justify the way in
which modern farming has been branded as producing a sterile countryside
devoid of birds. To date, the data provided in this debate has been highly
selective. Alarming statistics about the decline of farmland birds is
dependent on a more specific definition of what a farmland bird is.
Consider the following points:

The 35% decline in farmland bird populations between 1973 and 1998
statistic referred to in the English Nature press release quoted above
refers to the DETR's 'farmland bird' index (part of its quality of life
series of indices). This is a composite index of the recorded population
changes of 20 birds found breeding on farmland and deemed to be 'farmland
specialists'. However, a similar composite index that included all of the
42 bird species for which Siriwardena et al (Journal of Applied Ecology
1998, 35:24-43) calculated a farmland index would show either no overall
change or a slight increase. In other words, if we counted all the bird
species found on farmland, as opposed to those singled out as being
specialists on farmland rather than generalists, we would not get the
dramatic '35% decline' statistic. Of the 42 species found on farmland 18
have declined by more than 20% over the last 30 years and 17 have
increased by more than 20% over the same period.

What's special about the specialists? For some of the so called 'farmland
specialists' - skylark, starling, tree sparrow, greenfinch, goldfinch,
linnet, and reed bunting, research has estimated that between 35% and 65%
of their populations breed on non-farmland habitats. (R. Gregory 1999,
Vogelwelt 120: 47-57 and Gregory and Baille , Journal of Applied Ecology
1998, 35:785-799)

Modern farming has been blamed for the downfall of some 'farmland
specialists' without any specific evidence that this is the case. Take the
plight of the tree sparrow, which has featured prominently in many
conservation organisation press releases and newspaper headlines as a
victim of intensified farming because of its startling 87% decline over
the last 30 years or so. Even English Nature's own Biodiversity Action
Plan, published in 1998, states that 'The tree sparrow appears to undergo
irregular fluctuations in numbers. In Britain there was a high population
from the 1880s to the 1930s, but numbers then decreased to a low point
around 1950 ... Numbers then increased again from 1960 to 1978, possibly
due to an influx of birds from mainland Europe. ... Little is known about
the factors affecting numbers of tree sparrows.'

If we are going to have an intelligent discussion about the implications
of the FSEs for the introduction of commercially grown GM crops to the UK,
we need to discuss what aspects of farmland biodiversity are important and
why, rather than assume that farmland biodiversity in general is a good
thing. No one would argue that we should encourage the greatest diversity
of species on farmland as possible as this would negate the whole purpose
of farming – to improve upon the lot of the hunter and gatherer who was
dependent on what nature had to offer in an unadulterated form. Obviously
a large part of the current discussion, and the motivation behind the
FSEs, is about whether there is too little biodiversity on farmland in the
UK. But what is the benchmark, what should we be trying to achieve? Which
species, other than the crops being grown and those that are important to
their growth, merit our attention and why?

Certainly in relation to bird populations, which do provide an
eye-catching backdrop to this discussion, the debate to date has been
alarmist and one-sided. As Lord Derek Barber, Chair of the RSPB from
1976-81 and Chair of the Countryside Commission from 1980-90, told me back
in 1999: 'In terms of a balance sheet type approach, conservation is
gaining something every day. What people ignore is the fact that we are
getting better rather than worse. Everything as far as the RSPB are
concerned is always in grave danger. Bodies like the RSPB and WWF cry wolf
at every opportunity. They tend to go for exaggerating all the time and
they tend in due course to believe their own exaggeration' (Interview with
the author, 1999)

- Tony Gilland, Science and Society Director, Institute of Ideas


From the farm scale evaluations, I do not draw the conclusion that
agricultural biotechnology harms the environment or biodiversity. The
conclusion I draw from the farm scale evaluations is that agricultural
biotechnology allows for better weed control. I believe it is crucial to
maintain the distinction between the impact of agricultural biotechnology
on the environment and the impact of agricultural biotechnology on weed

The farm scale evaluations did not establish any damage to the environment
or biodiversity from agricultural biotechnology. The farm scale
evaluations did establish that fewer weeds and weed mass, depending upon
the crop and the comparison being made, survive in fields growing some
transgenic crops. However, other technologies (for example
herbicide-resistant crops from conventional breeding programs) are equally
likely to result in fewer weeds. Hence, if transgenic crops are not
permitted due to weed reduction, then equally new non-transgenic crops
should likewise be prohibited because of weed reduction. The issue is
weed reduction, not the technology. Hence, there is no scientific basis
for discriminating against transgenic crops.

As weed reduction is the finding of the farm scale evaluations, one should
also consider the benefits of agricultural biotechnology for the
environment. Transgenic crops may well use less toxic pesticides and
herbicides. Transgenic crops facilitate farmers adopting the agronomic
practices of low-till or no-till fields. Transgenic crops protect against
the risk of weed competition and insect damage thereby increasing yield
per acre which may permit habitat-restoration as farmland is removed from
cultivation. These advantages of transgenic crops may well result in
better biodiversity and an increase in weeds as available food for

Agricultural biotechnology also offers other environmental benefits such
as the potential for reduced nitrogen and phosphorous fertilizer usage.
The farm scale evaluations were not designed to consider these other
environmental benefits. But if the farm scale evaluations (in their
limited scope of measuring weed management) were to result in transgenic
crops being banned, these other, unmeasured benefits of transgenic crops
would be equally lost.

I have written an article entitled "Agricultural Biotechnology:
Environmental Benefits for Identifiable Environmental Problems." I attach
a file containing the article. I also attach an article by Professor Alan
Goldstein, entitled "Potential For Agricultural Biotechnology To Develop
Sustainable P Fertilizer Systems." Both attached articles discuss the
broader environmental benefits. A ban on transgenic crops would forgo the
environmental benefits discussed in these two articles.

Sincerely yours, Drew L. Kershen , University of Oklahoma College of Law


I am grateful to ACRE for the opportunity to contribute to this review in
my capacity as a commercial farmer. I have had considerable personal
involvement in the GM issue as a member of the Agriculture and Environment
Biotechnology Commission, a former member and chair of the British Beet
Research Organisation and a member of the UK Non-Food Crops Forum.

I will restrict my comments to the relevance of the results of the Farm
Scale Evaluations to the production of sugar beet and start from the
premise, as reported in the scientific papers arising from these trials
that, the effects reported did not arise because the crops had been
genetically modified but from the management regimes employed.
Conventional farmers seek to grow their crop in as near to sterile
environment as possible, this is particularly so for sugar beet where the
establishment and early growth of the beet plant is particularly sensitive
to competition from weeds. The use of GMHT beet broadens the choice of
herbicide and crop management strategy available to the farmer and the
FSE's have clearly shown that the methodologies traditionally employed by
farmers need to be modified where GMHT beet is grown.

I am aware of studies at CSL that have indicated the importance to wild
life of a narrow strip of land left uncultivated and unsprayed through the
centre of a crop. Further work at Broom's Barn has demonstrated the
importance and effectiveness for both beet development and biodiversity of
modified crop management protocols. Potential for potential environmental
improvement either early or late season have been demonstrated in GMHT
beet either by leaving weeds between rows early to mid season, or by
leaving some weeds to develop late season to provide autumn bird food and
seed return. Both approaches give as good or better yields than
conventional beet. In addition, very recent work at Brooms Barn advocates
leaving small unsprayed strips as required to mitigate improved weed
control effects.

In 1998 the weed control programme on a particular field on this farm
involved five separate herbicide applications in each case involving a
different combination of chemicals. A total of nine different herbicides
was used, each of them more than once. This was neither economic nor
environmentally sensitive. The ability to use GMHT beet would provide a
clear solution to both of these problems. The weed control strategy could
then be both effective and economic through the use of appropriate
herbicide applications and unsprayed strips would be of significant
benefit to wild life.

While I recognise that ACRE intends to consider the results from the FSE's
what I am urging is that the wider implications of the FSE's are taken
into account. The implications of the investigations over the past four
years stretch far beyond GMHT crops to arable agriculture in general where
the same herbicide is used extensively for stubble cleaning operations. I
see this as a significant opportunity to establish herbicide management
regimes for both GMHT and conventional crops that would benefit both the
farmer and the environment alike.

David J Carmichael, Lincoln , 14 November 2003


I am a British biotechnologist who is now actively developing GMHT onion
crops in New Zealand . I was horrified by the reporting of the FSE results
and the lack of guidance given by research group with respect to the real
meaning of the results. The conclusion of this was once again bad
reporting of a very interesting study. I believe that the key messages are
that less AI was required for effective weed control in all three systems
studied and that in two of theses systems (rape and beet) weed control was
so efficient that biodiversity was compromised (not necessarily a bad
thing in a farm environment).

Therefore with a correct management strategy in these systems even further
reductions in AI use, at a level which could maintain current biodiversity
levels (if that is what is desired), could be achieved. Thus the GMHT has
enhanced farm management options and provided the opportunity to reduce AI
input. Correct management is the key to maintaining biodiversity and
probably to preventing the establishment of resistance problems. I hope
these comments help support the careful use of biotechnology in Britain.

Dr Colin Eady, New Zealand


I was a member of the AEBC when it prepared the report on the FSE
experiments entitled “Crops on Trial”. I also attended a presentation by
the FSE scientists at the Royal Institution on 16 October 2003 and at the
Royal Society on 23 October 2003 as a member of the GM Science Review. My
interest and background in the subject is indicated in the footnote1.

I first wish to congratulate the scientists involved for their outstanding
and innovative work.

My comments and analysis of the FSE experiments are as follows: 1. The
essential message is that, in general terms, more weeds result in more

2. It follows that if a farmer reduces the extent of weed control in
crops, more wildlife will be supported. This is true whether a farmer uses
herbicides, mechanical cultivation, hoeing or gas burners to control

3. The precise practice of using herbicides to control weeds in non-GM
crops has been refined over many decades. The spraying protocols used on
the GM crops were the best estimate for these novel crop-herbicide
combinations and are likely to be refined over time.

4. The GM crop-herbicide combinations give considerable flexibility in the
future to explore and refine weed control strategies that favour wildlife.
There is comparatively limited flexibility within the conventional
crop-herbicide combinations to vary and evolve weed control strategies.
The Broom's Barn experiments illustrate that new GM crop-herbicide regimes
can be usefully explored.

5. The impact on wildlife of the GM crops compared with the non-GM crops
was statistically significant but it appears of limited biological
significance compared with the other variables in agriculture, such as
crop, seasons, position in the field, sprayed out set-aside etc.

6. If the difference in impact between the GM and non-GM crops in the FSEs
is used to question commercialisation of the beet and oilseed rape, this
would in a sense place a mark on a yardstick of wildlife impact. Our
response can be essentially political by making a judgement against this
novel technology. Alternatively our response can be a scientific one where
we evaluate the magnitude of the biological impact of the GM crops against
the other variables in agriculture.

7. The logical scientific response to a decision against commercialisation
of GM beet and oilseed rape would be to question all practices
(conventional and novel) in agriculture that have a similar or greater
impact on wildlife compared with the GM beet or oilseed rape. This would
apply to all herbicide and pesticide registrations, certain set-aside
practices, the application of copper sulphate sprays, excessive
cultivation and so on.

8. It is the impact of the full farming system that is important, rather
the impact of one crop within it. Making judgements about one particular
crop character, whatever breeding method is used to produce it, could in
wildlife terms, be described as rearranging the implements at the farm
sale - it largely misses the point.

9. The FSEs have been pioneering experiments in developing methodologies
and interpreting data. It is important that we now make a considered
response in the context of the spectrum of biological impacts on wildlife
observed across all agricultural practice. A reflex reaction may ease the
immediate political pressures but will not do justice to the real
challenges before us.

10. The fundamental question is how much of the UK resources for plant
growth we wish to devote to supporting crops and supporting wildlife, and
how we wish to distribute the two.

I have deliberately kept these comments concise. If you wish me to expand
on any of them, I shall be happy to do so.

Yours sincerely, Professor Philip J Dale, John Innes Centre, Norwich


Summary of Indur Goklany Submission
Although the results of the farm scale evaluations (FSEs) provided a
bumper crop of information on the biological effects of different
herbicide management regimes associated with genetically modified
herbicide tolerant (GMHT) and conventional crops, they do not provide a
comprehensive assessment of the biodiversity and environmental
consequences of cultivating GMHT rather than conventional varieties
because they did not evaluate key arguments that underpin the
environmental rationale for GMHT crops .

In summary, despite the FSEs pioneering effort in ecological research,
their evaluation framework was too narrowly conceived to fully or fairly
evaluate the risk-risk trade-offs that underlie the environmental
rationale for adopting GMHT crops. The FSEs confirm what we already knew
or suspected — that weed-killers kill weeds, that delaying their use
allows weeds to grow larger, and that killing weeds disadvantages
weed-feeding invertebrates but favors detritivores. But they shed little
light on whether any negative impacts on biodiversity of more effective
weed control might be overcome by the positive impacts resulting from
higher yields (which would help reduce the amount of land diverted to
agriculture), increases in conservation tillage, and net reductions in the
amount, toxicity, or persistence of herbicides employed. Unless the
evaluation framework used by ACRE (and the precautionary approach) is
expanded to incorporate these considerations, there is a danger that the
resulting recommendations might, perversely, increase, rather than reduce,
environmental risks associated with canola, beet and maize farming.
Moreover, for both fairness and transparency, these considerations should
be conveyed to the public in the brief summaries of results (which the
general public is most likely to read), as well as in any advice proffered
to ministers.

I suspect that a proper evaluation of the countervailing risks of using
GMHT rather than conventional crops along the lines proposed above would
show that GMHT crops, while imperfect, nevertheless could, with
appropriate management, provide net gains to the U.K. environment
(compared to conventional crops)1,3. This would be consistent with the
U.S.18 and Canadian15 experience which suggests that if GMHT crops are
designed and managed judiciously, the net result could be a reduction in
pressures on biodiversity, accompanied by improvements in farm income,
water quality, conservation of carbon in the soil, and preservation of
farm productivity.