Managing the Footprint of Agriculture: Towards a Comparative Assessment of Risks and Benefits for Novel Agricultural Systems

This report has been drawn up by a subgroup of the Advisory Committee on Releases to the Environment (ACRE) in response to requests by the Secretary of State and the Agriculture and Environment Biotechnology Commission to assess the wider implications of the Farm-Scale Evaluations (FSEs) of genetically modified herbicide tolerant (GMHT) crops. ACRE's remit is currently limited to GMOs and the release of certain non-GM species of plants and animals that are not native to the UK. However, this report is based on the experience gained by ACRE in reviewing the findings of the FSEs, on the deliberations of the ACRE subgroup established to examine the wider implications of this study, and on evidence submitted by a variety of stakeholders to an open meeting held in October 2004. A draft version of this report was sent to a wide range of stakeholders for The report has now been revised to take into consideration the evidence submitted in consultation responses. A document published alongside this report 1 details the responses made during the consultation period and the revisions made to the report. In recent years, it has become apparent that there are inconsistencies in the regulatory assessment of the environmental impact of GM crops in comparison with other agricultural crops and practices. The EU Directive 2001/18, which covers the release of genetically modified organisms, requires an environmental risk assessment of possible immediate and/or delayed, direct and indirect environmental impacts of the specific cultivation, management and harvesting techniques used for the GM plant as part of a rigorous approval process. Non-GM crops and other changes to agricultural management do not require similar risk assessments. Quantitative field studies have shown that the environmental impact of changes in agricultural management can be at least as significant as those associated with GM crops. Examples include the change from spring to winter sowing in arable crops and the shift from hay cutting to silage production. There is, however, currently no equivalent regulatory requirement for assessment of the positive and negative effects of such changes in agricultural practice on the environment prior to their widespread adoption. This inconsistency is further illustrated by GM herbicide tolerant crops that require an extensive environmental risk assessment before approval for cultivation and marketing whilst herbicide tolerant crops produced by non-GM breeding methods can be grown without an equivalent assessment. The FSEs showed that differences in the impact on wild flora and …