1. WALES MOVING TOWARDS A CONTINUING BAN ON GM CROP CULTIVATION WALES Cymru THE LAND OF MY FATHERS Hen Wlad Fy Nhadau

2. WELSH AGRICULTURE 1.6 million hectares (around 77% of Wales' total land area) is used for agricultural production and an estimated 57,500 people are directly employed in the sector. The average farm size is 30-40 hectares, small by UK standards, and dominated by family-run enterprises. (1) The question the people of Wales have had to answer is: Are we willing to risk our rich family-based agricultural history and also the hopes of a sustainable future, on a technology that has so many un-answered questions surrounding it regarding both health and environmental safety as well as likely negative economic impacts? The answer is simply - no.

3. REBECCA EVANS, DEPUTY MINISTER FOR FARMING AND FOOD IN THE WELSH GOVERNMENT RECENTLY STATED (2) Following the “European Union (EU) decision that has allowed Member States and Regions to make decisions on whether they wish to ban or cultivate genetically modified (GM) crops in their territories, the Welsh Government will demand that the GM applicant limits the geographic scope of an EU GM crop authorization to exclude Wales. “Should this demand not be met then we can adopt further measures to restrict or prohibit the GM crop cultivation. These further measures may include such things as environmental or agriculture policy, socio-economic impacts, public policy or the avoidance of GM contamination to other products. We have campaigned for several years to have socio-economic issues included as important factors in the consideration of GM crop approvals and I am pleased that these are now formally recognized.”

4. The current approach of the welsh government and welsh NGOs is to work towards a continuing ban on GM cultivation based on compelling grounds within the new EU regulation FIVE POSSIBLE TARGETS ARE Environmental policies Land-usePublic policy Agricultural policy objectives Socio-economic reasons

5. ENVIRONMENTAL PROTECTION Wales will investigate possibilities regarding regional or local issues that have not been fully taken into account as part of the risk assessment process for the approval of GMOs (EFSA assessment). This investigation will be ongoing and will react to new EU approvals if/when they happen. Many parts of Wales are protected areas, according to a number of designations. They include three national parks, and five Areas of Outstanding Natural Beauty (12). From a practical point of view using buffer zones around these protected areas and trying to organize coexistence measures in the event that GMOs are allowed in Wales would be an administrative nightmare.

6. LAND-USE Wales is currently investigating some scope in the context of land-use requirements where a GM cultivation opt-out is based on nature conservation. Wales has made large investments in the organic sector and wants to safeguard the agricultural land in Wales that is managed under voluntary agri-environment schemes. Organic farming is an important part of the Welsh landscape. There are over 1000 organic farms in Wales, ranging from smallholdings to large estates, and 8% of the total land area is managed organically. (3)(4) AGRICULTURAL POLICY OBJECTIVES

7. SOCIO-ECONOMIC IMPACTS Socio-economic effects must refer to legitimate public interests that would need to be defined and must have evidence to support them. Wide-ranging opinion polls as well as more in-depth research into the economic impacts and health/environmental safety of GM crops by the Welsh government, can lead to socio-economic reasons being the main tool used to continue the ban on GM crop cultivation in the country. Welsh NGOs are particularly interested in the following reasons for maintaining the ban on GM cultivation

8. A) EFFECTS ON THE HEALTH, SAFETY OF FARM FAMILIES AND LABOURERS Over 80% of GM crops worldwide are engineered to be grown with glyphosate-based herbicides (5). Massive increase of glyphosate use with GM Crops - USGS (6). MARCH 2015: WORLD HEALTH ORGANISATION’S CANCER AGENCY IARC DECLARED THAT GLYPHOSATE IS A PROBABLE HUMAN CARCINOGEN. (7) IARC: Glyphosate has been detected in the blood and urine of agricultural workers, indicating absorption and that there were increases in blood markers of chromosomal damage (micronuclei) in residents of several communities after spraying of glyphosate formulations. Need to protect farm families and laborers in Wales from probable increased levels of harm, caused by the inevitable increase in use of glyphosate-based herbicides with the commercial cultivation of glyphosate-tolerant GM crops.

9. B) SUSTAINABILITY ISSUES Massive increases in the use of glyphosate and other agrochemicals in two of the main GM crop cultivating countries (Brazil and U.S.A) is of great concern to Wales. Data on GM crop related increases in pesticide use from the U.S. Geological Survey (6) and last week from Brazil’s National Cancer Institute must be studied in detail (8). Brazil’s National Cancer Institute: The report says that national consumption of agrochemicals is equivalent to 5.2 litres of agrochemicals per year for each inhabitant. Agrochemical sales increased from USD 2 billion in 2001 to 8.5 billion in 2011 (mainly due to introduction of GM crops). The sustainability of Welsh agriculture and our ‘clean and green’ market position can thus clearly be shown to be under threat from GM crop cultivation if the above data is taken into account.

10. C) RURAL ECONOMY AND CONSUMER ACCEPTANCE Farming and food processing industries remain the cornerstone of the Welsh rural economy. The Welsh emphasis is on competing on quality, strong branding and adding value through local processing. We, therefore, need to preserve consumer confidence and maintain our focus on a clean, green, natural environment. BY HAVING THE ABILITY TO CONTROL WHAT IS GROWN IN WALES WE CAN HAVE CONFIDENCE IN PRESERVING THESE VALUES.

11. D) SAFETY OF GM CROPS AND SOCIAL ACCEPTANCE Currently there is no scientific consensus on the safety of GM crops and their associated pesticides (9). EFSA, in the eyes of Welsh observers, has failed properly to apply the Precautionary Principle in this area. The currently planned EU KBBE (10) rat feeding trial on GM Maize NK 603 is not comprehensive enough to answer the many safety questions that have been asked by EU consumer, farming and environmental groups regarding GM crops. The EU study will only be for carcinogenicity and will not include a multigenerational or focused toxicity component.

12. D) SAFETY OF GM CROPS AND SOCIAL ACCEPTANCE Without a comprehensive study on the safety of GM crops and their associated pesticides the Welsh public will remain very cautious about GM foods and GM crops, thus cultivation of GM crops would damage consumer trust in Welsh farming and food. We applaud the currently planned independent study ‘Factor GMO’ (11) which according to initial reports will meet the requirements for a comprehensive study. In our opinion governments from the EU should turn their attention to the ‘Factor GMO’ study, which will enable them to receive answers that allow them to make the correct decisions on regulating GM crop cultivation and their associated pesticides.

13. OTHER SOCIO-ECONOMIC POINTS THAT SHOULD BE INVESTIGATED ARE a) Effects on food, feed and commodity prices, b) Risks of the extinction of traditional varieties, biological diversity, c) effects on income and employment d) effects on farms and farming communities, including size and protection of the farm family and labourers; e) requirements for education, information and continuing training, f) operating costs (inputs, labour, economics of scale etc.) and g) impact on investment and access to finance.

14. DIFFICULTIES FACED c) Wales also faces its own country specific problems including establishing cross- border arrangements with England to ensure that Welsh farmers are protected from any possible contamination should GM crops be grown across the border. a) Would national ban be legal in the context of the WTO? b) Already permitted Coexistence Measures under existing law. Could these take priority over a complete prohibition on cultivation in terms of proportionality?

15. THANK YOU DIOLCH YN FAWR

16. REFERENCES (1) http://gov.wales/topics/environmentcountryside/farmingandcountryside/cap/ruraldevelopment/ruraldevelopmentplan4wales2007/?lang=enhttp://gov.wales/topics/environmentcountryside/farmingandcountryside/cap/ruraldevelopment/ruraldevelopmentplan4wales2007/?lang=en(2) http://gov.wales/about/cabinet/cabinetstatements/2015/gmcrops/?lang=enhttp://gov.wales/about/cabinet/cabinetstatements/2015/gmcrops/?lang=en(3) http://www.organiccentrewales.org.uk/schools-wales.phphttp://www.organiccentrewales.org.uk/schools-wales.php(4) http://www.abc.net.au/news/2015-04-08/monsanto-contributed-to-michael-baxters-legal-costs/6377526http://www.abc.net.au/news/2015-04-08/monsanto-contributed-to-michael-baxters-legal-costs/6377526(5) http://www.agbioforum.org/v12n34/v12n34a10-duke.htmhttp://www.agbioforum.org/v12n34/v12n34a10-duke.htm(6) http://water.usgs.gov/nawqa/pnsp/usage/maps/show_map.php?year=2012&map=GLYPHOSATE&hilo=Lhttp://water.usgs.gov/nawqa/pnsp/usage/maps/show_map.php?year=2012&map=GLYPHOSATE&hilo=L(7) http://www.thelancet.com/journals/lanonc/article/PIIS1470-2045%2815%2970134-8/abstracthttp://www.thelancet.com/journals/lanonc/article/PIIS1470-2045%2815%2970134-8/abstract(8) http://www1.inca.gov.br/inca/Arquivos/comunicacao/posicionamento_do_inca_sobre_os_agrotoxicos_06_abr_15.pdfhttp://www1.inca.gov.br/inca/Arquivos/comunicacao/posicionamento_do_inca_sobre_os_agrotoxicos_06_abr_15.pdf(9) http://www.ensser.org/media/0115/http://www.ensser.org/media/0115/(10) http://ec.europa.eu/research/participants/portal/desktop/en/opportunities/fp7/calls/fp7-kbbe-2013-feedtrials.htmlhttp://ec.europa.eu/research/participants/portal/desktop/en/opportunities/fp7/calls/fp7-kbbe-2013-feedtrials.html(11) http://factorgmo.com/en/http://factorgmo.com/en/(12) http://en.wikipedia.org/wiki/Protected_areas_of_Waleshttp://en.wikipedia.org/wiki/Protected_areas_of_Wales