Dear Dr O Reilly

14/12/04

Dear Dr O’Reilly,

Further to you recent letter dated18 October 2004 regarding Co-existence of GM crops with conventional and organic farming I enclose for your information the report from the Agricultural Science Association compiled by our sub Committee on Policy. As president of the Association I would like to thank the Department of Agriculture and Food for giving us the opportunity to make a submission on this topic. We feel that the Professional Agricultural Science graduate has a key role to play in the development and implementation of these co-existence guidelines.

Yours Sincerely,

David Rath President, Agricultural Science Association. Co-Existence of Genetically Modified crops with conventional and organic farming

The Agricultural Science Association is the representative body for professional Agricultural Science graduates in Ireland. Firstly, we would like to thank the Department of Agriculture and Food for giving us the opportunity to participate in the discussion on co-existence of GM crops with other established cropping systems. Given our role as a representative body for professionals our comments are restricted to the areas where we see the professional status of our members being of critical importance to the operation of effective coexistence guidelines.

At the outset it is important to point out that the ASA recognises the potential of modern biotechnology and also welcomes the recently implemented Regulations on GM Food and Feed and Traceability and Labelling which will ultimately provide both protection and reassurance to the consumer, but also enable judgments based on thorough scientific evaluations.

The ASA have examined the detail of Commission Recommendation 2003/556/EC on the guidelines for the development of national strategies and best practices to ensure the coexistence of genetically modified crops with conventional and organic farming. The legislation developed to date provides for assurances of the safety of the GMO, it does not however, address the potential economic loss where admixture of GM and non-GM crops occurs, nor does it address the appropriate measures that can be taken to minimise admixture.

From our point of view our particular interest focuses on the following aspects: The impact of this technology has potential widespread consequences for a range of scientific fields including soil biology, plant pathology, plant physiology, environmental biology, ecosystems, animal physiology, animal health and welfare etc. We would therefore, point out that expertise in such fields is a prerequisite to the full understanding of GM technology. These are all disciplines in which our members have professional qualifications. In addition, if proper scientific advice is not provided to all parts of the chain the area of liability could become an unwelcomed feature of GM production with consequences for the operator and also the advisor.

1. Training: Obviously, the ASA recognises the area of training as critical in the operation of several cropping systems. The ASA feels that our members who operate as Agricultural Consultant have a critical role to play in the practical operation of the guidelines and we would ask the Department of Agriculture and Food to consult with them on the development of guidelines through the ACA. It is our submission that such training be mandatory for advisors, extension staff, farmers and operators such as contractors. As regards advisors and extension staff, we would be happy to engage in consultation with University College Dublin or another Higher Education Institute to provide appropriate training on Genetically Modified Organisms with particular emphasis on co-existence for the professional Agricultural graduates. We have already held similar discussions on various different subjects (e.g. Pesticides and Veterinary Medicines) where further learning would be appropriate. We would emphasise the importance of a suitable qualification for the advisors and extension workers as a minimum requirement for these staff for the reasons previously stated about the sensitivity of the GM debate. We would see Teagasc as the authority most equipped to provide farmer and operator training where the Teagasc professional staff could provide the training. In addition, it would be wise to include co-existence on the curriculum of both the Ag Science Degree and the Teagasc Green Cert such that young farmers are familiar with the requirements at an early stage. In order for production systems to coexist, operators must be fully understanding of the requirements to ensure that GM crops are cultivated in a manner unlikely to adversely effect other producers in the locality.

2. Review System: A facility should be provided to enable regular reviews of the guidelines to take account of increasing knowledge in the area of pollen transfer and new GM crop releases. The ASA would favour the establishment of a management committee to oversee the evolution of the guidelines using the expertise of the most qualified persons in each field. We would envisage that such a committee would draw on the expertise of professionals in UCD, Teagasc and the Department of Agriculture and Food.

3. Role of DAF: Role of professional within Department of Agriculture and Food – Our association recognises the contribution of the agricultural professionals to the Department of Agriculture and Food (both in terms of the professional inspectorate grade, but also the administrative side). In order for there to be faith in the approval process and the policing of co-existence measures we would insist on the role of the inspectorate in policing this matter. GMOs are a particularly emotive issue with considerable focus from both sides of the debate. In order to operate effective measures for co-existence they must be designed and operated by qualified people within the Department i.e. the Agricultural Inspectorate. Failure to do so would cast considerable suspicion on the reasoning behind the measures and confusion amongst operators.

4. EU Review: If at such a time the EU decides to develop guidelines for the community, we would strongly urge the Department to bear our submissions in mind in future EU negotiations, and to stress during such negotiations the particular circumstances that pertain to Irish agriculture.

The ASA would be happy to assist the Department of Agriculture with any of the areas outlined above, or any other areas which you feel may be appropriate for our association.

APHA Views on Co-Existence 4th August 2004 1. Practical Experience of Co-Existence

Co-existence is not a new concept to the agricultural community. Waxy and non-waxy maize, white and yellow maize, hot and sweet peppers, high and zero erucic acid oilseed rape, to mention but a few, have been grown successfully in co-existence. Effectively, co-existence is not a problem provided technical and procedural guidelines are followed.

2. Co-Existence in the Context of Genetically Modified (GM) Crops Co-existence must be considered in the context of GM, conventional and organic crops, In 2003, conventional agriculture represented 94.5% of all arable land worldwide with GM and organic crops making up 4.7% and 0.8% of the arable area respectively.

In terms of the adventitious presence of material from one crop in another, the levels should be the same across conventional, GM and organic crops.

Given the legislative reality in Europe, food, feed or products intended for direct processing produced from crops grown from non-GM seed should have a GM content not exceeding 0.9%. It should be remembered that the relevant figures in Brazil and Japan are 4% and 5% respectively. 3. Practical Experience from Spain

In Spain, GM maize is its 6th year of cultivation with 7% of the crop area (32,000 hectares) being sown to GM varieties.

Practical experience to date has not resulted in any difficulties between GM, conventional and organic crops. However, this is in the context where most of the GM varieties are grown in Catalunya in response to the presence of the relevant pest in this area whereas non-GM varieties predominate in other areas of Spain.

If GM crops become the norm in Spain, it is anticipated that the use of separation distances and buffer crops will allow co-existence.

4. Experiences from North America In 2003, GM crops accounted for 80%, 41% and 70% respectively of the soya bean, corn and canola plantings in the USA and Canada combined.

The small number of instances where GM material has been found in non-GM crops have been largely attributed to problems in storage and/or transport The only question over co-existence relates to canola in Canada. However, a lack of information in relation to any alleged problems makes it difficult to reach any conclusion. Appropriate co-existence rules may be quite effective.

5. Awareness of Farmers of GM Crops It is necessary that a farmer intending to grow a GM crop would indicate this intention to neighbouring farmers. This would allow appropriate management techniques to be put in place.

The history of making the names of farmers who intend to grow GM crops publicly available has been difficult. In many cases, trial crops have been vandalised.

In order to provide information to neighbouring farmers but to avoid the possibility of damage to GM crops, it appears appropriate to require the grower of GM crops to notify neighbouring farmers of his of her intention to grow GM crops.

Consideration should be given to this mechanism of communication as opposed to a public register due to the security concerns referred to. 6. Liability Issues In the case where a non-GM crop becomes contaminated with GM material to the detriment of the non-GM crop producer, existing civil liability legislation covers losses resulting from negligent practice.

It may be best to let the Courts sort out liability issues.

The Association appreciates the opportunity to comment on the development of co-existence guidelines by the Department. We look forward to maintaining contact with you in relation to the development of the guidelines, c:\documents and settings\nicola jolley\data\reports & position papers & association documents\reports\apha views on coexistence. doc

An Taisce – The National Trust for Ireland Tailor’s Hall, Back Lane, Dublin 8

Barry O’ Reilly, Department of Agriculture and Food, Backweston, Leixlip, Co. Kildare.

5th May 2005

RE: National Strategy for Best practice of co-existence of GM crops with conventional and organic farming

Dear Mr. O’Reilly,

Upon speaking recently with John Downey of your department and outlining the situation here at An Taisce, he has suggested that efforts would be made to incorporate any comments submitted by ourselves into the ‘National Strategy for Best practice of co-existence of GM crops with conventional and organic farming’, whether as an appendix or otherwise. The cause of our delay has been that An Taisce was without a Natural Environment Officer for some months. I have only recently taken up the position.

I am aware that oral submissions were made by Shirley Clerkin the former Natural Environment Officer and Eanna Ni Lamhna, President of An Taisce during the consultation process. I have not had enough time to formulate An Taisce’s position on this complicated issue and therefore to contribute to the consultation procedure by way of submitting a full report, I do hope that you will accept and incorporate the following comments in relation to the Drafting of the National Strategy, submitted to you in good faith.

I would like to take this opportunity to wish you every success in compiling a comprehensive and precautionary Strategy on this complex issue.

Yours Sincerely,

Anja Murray, Natural Environment Officer, An Taisce – The National Trust for Ireland.

Telephone: 01 707769 e-mail: [email protected] Comments relating to the development of a National Strategy for Best practice of co-existence of GM crops with conventional and organic farming.

On the issue of ‘co-existence’ An Taisce is concerned about the ability of a ‘National Strategy for Best Practice’, or indeed any legislative or other protective measures, to prevent the introduction of GM crops from interfering with the development of organic and conventional agriculture in Ireland by way of cross pollination and contamination, or from negatively impacting the wild flora contained in Irelands network of conservation sites (including the legally protected European Natura 2000 network).

As GM technologies are still in the early stages of development, the effects and implications of genetically modified crop plant species on the genetics of other organisms in the environment have not yet been adequately or conclusively researched for all crop, farm, or landscape types, and are as yet unpredictable in the full range of Irish conditions.

Evidence that has come to our attention on this issue includes research commissioned by the Joint Research Centre of the European Commission entitled “ Scenarios for Co-existence of genetically modified, conventional and organic crops in European agriculture”. The report states that co-existence threshold limits of 0.1% contamination as required by organic standards “will be virtually impossible” for any of the scenarios considered in the study “even with significant changes in farming practices”.

Ireland’s landscape is of a mosaic structure, with our many hedgerows acting as corridors for the movement and dispersal of wild plants and animals. It would be impossible to control the movement of pollinating insects and the dispersal of transgenic seeds by birds and other mammals in such traditional and widespread Irish landscapes. An assessment of transportation vectors in agricultural landscapes is presented in ‘Concepts for co-existence’, a report commissioned by the Austrian Ministry of Health and Women, 2003. Until the potential and actual gene flow between all potential crop types is fully researched in all Irish landscape types, incorporating investigation of the full range of contamination vectors (including wind, water, and pollinators), parameters for co-existence in Ireland can not be set with any scientific validity.

In line with Directive 2001 /18, a thorough assessment of the risk posed to organic and conventional farming and to the natural environment from the deliberate release of GMO’s must be undertaken in order to validate any Best Practice Strategy for Ireland. Such an assessment must be subject to full and transparent stakeholder and public consultation.

The additional costs presented by co-existence to conventional and organic farmers and to the exchequer are also of huge concern. An Taisce find it impossible to justify the imposition of these costs on Irish farmers and tax payers for the benefit of a few farmers and companies who may chose to grow GM crops. The costs are likely to be so high as to put organic farmers out of business. Endangering jobs in Ireland’s organic farming and GM-free sector for the benefit of a few GMO producers does not make economic sense. Any strategy drawn up on co-existence must ensure that these costs become the responsibility of the GM grower, and the full liability of any contamination also be borne by the same. Legal structures must reflect the same responsibility.

The impacts of unintentional and uncontrolled contamination of other crops and of wild plant species is a very real and dangerous risk. The potential threat is recognised in the National Biodiversity Plan (2001) and should be recognised as a major and significant risk to the potential of the" Green and Safe" image of Irish agricultural produce in Europe. An Taisce is strongly opposed to any allowance of these risks to be taken before the issue of cross contamination can be fully and independently researched and dealt with safely and effectively, and the economics of the various options fully explored. Until this time, it is of the utmost importance that Ireland's agricultural sector and our natural environment is not subjected to such a potentially ruinous experiment.

In addition, irrespective of the safety of growing GM crops, there will always be a market for GM free food in Europe. Several consumer surveys in the EU have found an overwhelming public preference for GM free foods, with Europe’s top 30 retailers and top 30 food and drink producers, amounting to more than 60% of the total European food and drink sales, are committed to remaining GM freeing order to meet consumer demand. (Reference: No market for GM labelled food in Europe, Greenpeace report, 2005). Ireland, in our somewhat isolated geographical position, has much to benefit from economically by remaining free from the great risks associated with the release of GM crops in our environment, at least until the scientific and economic research has been completed and the full extent of these risks can be assessed. Ireland should take this opportunity to remain as the ‘control’ site of this experiment, thus justifying our GM free stance to outside pressures.

We believe that G. M. Foods offer no long-term gain to the producer, the consumer, the developing world or the environment.

As this technology is not reversible and is of vital public interest, we call for an extension of the consultation period for a further year. We call for a fully informed public debate and a referendum before any further consideration of introducing these crops to Ireland. Looking forward to your response.

1 Sinne le meas,

Jim McNamara Organic Farmer, Knockaderry, Co. Limerick. Michael O'Loinsigh, Student, Springfield, Dromcollogher, Co. Limerick. Kieran English, Knockatanna, Caherconlish, Co. Limerick. Vincent Burke, Tobernea, Effin, Co. Limerick. Danielle Ryan, Milford, Co. Cork. Kevin O'Dea, Broadford, Co. Limerick. Kevin Fitzmaurice, Fort William, Milford, Co. Cork. Jitka Pechancova, Church St, Dromcollogher, Co. Limerick. Norma Courtney, Lacca, Ballyhahill, Co. Limerick. Dylan Keating, Fort William, Milford, Co. Cork. Oonagh 0 Dwyer Lahinch Co Clare Grower. Kevin Duffin, Fort William, Milford, Co.Cork Grainne McHugh, Fort William, Milford, Co. Cork. Jessica Swadosh, Fort William, Milford, Co. Cork Ron de Bruin, Gardenfield, Dromcollogher, Co. Limerick. – Grower Ted Cook, Kilbarry, Macroom, Co. Cork. - Tree Specialist. Con Cremin, Ardagh, Co. Limerick – Farmer Eileen Flynn O'Sullivan, Ardagh, Co. Limerick – Farmer John Harnett, Ashford, Co. Limerick. – Farmer Sinead Neiland Grower Knocktoosh Broadford Co Limerick. Roisin Ni Ghairbhith 3 Woodview Park Ennisthymon Co Clare. Grower. Thomas & Michael Keane Morgans Askeaton Co Limerick. Farmers. Grace Maher Neurney Co Carlow Grower. Tom Atkins 18 Newbridge Park Scibbereen CoCork. Tracy Ryan Bog Cross Liscarroll Co Cork Grower. Emer 0 Flaherty Springfield Broadford CoLimerick Farmer/grower. Ted Bradley Ballyhea Charleville CoCork Grower. Paul 0 Donoghue Ahane Co Limerick Grower Rossum McNamara Clonlara CoClare Grower. G. M. Crops-Points of Concern to Farmers, Growers & Consumers.

Organic Food is produced to internationally recognised standards, with care for the soil for animals, plants and human health as its core features. Summary.

This submission from An tlonad Glas- the Organic College, staff, students and producers is centred on the direct threat that Genetically Modified Food presents to our livelihood, to biodiversity to the soil and the environment. It calls for a further moratorium on G. M. Crops for at least a year, for an informed public debate followed by a referendum.

Outline of the issues.

1. The technology is unsafe & consequences unknown. 2. The Precautionary Principle should be applied at present. 3. G.M. Technology is controlled by multinational corporations. 4. It reduces independence of family farms 5. It runs counter to Agro-ecological farming. 6. G.M. Crops will mean Bio-diversity loss and a Wild-life threat 7. It will increase our weed problems 8. The majority of farmers don't want it 9. Most consumers do not want it 10. Chefs do not want to use GM food in their restaurants 11. It is not sustainable and is fertiliser dependant 12. Its labelling is inadequate 13. No insurance company will cover it 14. It has negative tourism implications 15. Education & Public Consultation has been inadequate.

According to David Byrne (outgoing EU Health & Consumer Affairs) 'any member state may object to the marketing on their territory of any such GM variety if they consider there is a risk for human health, the environment or agronomic reasons.

Issues of Concern: 1. The technology is unsafe & consequences unknown, as there is the real possibility of unknown effects of some genes being expressed and of unstable horizontal gene transfer between species. The crucial significance of food and especially organic food for human health makes this technology of special concern. It must be noted that research on the health risks of these products has been conducted predominantly by the companies which promote it. 2. The Precautionary Principle in this regard means that a. Further study of the field and health consequences is needed before its acceptance in Ireland is considered. b. In this study there is a strong case for making the island of Ireland a G.M.free Zone as a control in the E.U. experiment with G.M. Food.

3. G.M. Technology is controlled by multinational corporations - it is well known that the beneficiaries of this technology are the biotechnology companies, who also make the pesticide sprays for the crops and have an agenda other than the public good.

4. It reduces independence of family farms a. There will be a loss of right to save & plant own seeds if G.M. patented. The possible introduction of a "terminator" gene further reduces the range of seed options. b. Organic licences & certification is threatened and may be lost. 5. It runs counter to Agro-ecological farming. a. G.M. Technology is a departure from traditional and time proven natural breeding & selection techniques. It carries the real possibility of contamination of organic and conventional crops. b. This may be permanent damage as we cannot recall GM genes that pass into the wild. 6. G.M. Crops will mean Bio-diversity loss and a Wild-life threat.

a. This loss is inevitable if the focus is on chemical farming with larger fields and contamination of the flora & fauna which will be irreversible. b. Loss of heritage seeds & plants is also a likely consequence.

7. It will increase our weed problems. Cross pollination of G.M. Crops with existing weed families can lead to super weeds. This is of major concern to us as organic producers who rely on non-chemical methods of weed control.

8. The majority of farmers don't want it. a. It will reduce the value of food exports. b. IFA vice-president, Irish Cattle & Sheep Farmers Assoc are amongst those opposed to release of GM seeds.

9. Most consumers do not want it a. Strong opposition in Europe - 80% consumers are demanding GM free food & meat b. What about consumer choice? - labelling is not satisfactory as there can be hidden GM ingredients below the threshold of mandatory labelling

10. Chefs do not want to use GM food in their restaurants - a large number of prominent chefs have opposed the introduction of GM crops through their own association and via the slow food movement.

11. It is not sustainable and is fertiliser dependant - As the world oil supply is limited and increasingly expensive, the focus on chemically dependant crops and agriculture is neither sustainable nor efficient. This is equally true in Ireland and in the developing world.

12. Its labelling is inadequate a. The onus must be on the G.M. promoters to label their crops not on us producers of G.M. free crops to label our. 13. No insurance company will cover it. a. We note there is a total refusal by insurance companies to cover disaster risks associated with this technology. We are asking if the Department of Agriculture can seek insurance cover for organic producers who may lose their symbol as a result of GM Crop introduction.

14. It has negative tourism implications Ireland's 'clean green image' has been a major factor in promoting our export of food and our grass-based livestock. This special status may be lost permanently.

15. Education & Public Consultation has been inadequate. a. There has been a lack of an awareness & educational campaign to show both sides of the argument. The Public has not been consulted - no referenda. b. It is for this reason that we call for a further moratorium of one year and a public referendum on the issue in advance of G.M. Crop acceptance.

Conclusion From our experience as organic producers, we know that pollen, seeds, animal and plant material can be dispersed over very large distances. We believe that G. M. Crop technology is still at best imprecise, experimental and potentially dangerous. As we, or our public agencies are not in a position to control the pace, or regulation of this technology, we believe it is not appropriate to release it at present in Ireland.