An open letter to George Eustice, Secretary of State for Environment, Food and Rural Affairs
16th March 2021
Dear Secretary of State,
Public consultation on the regulation of genetic technologies
The ‘public consultation on the regulation of genetic technologies’ has potentially profound consequences for the future of food and farming.
I am writing to do two things. Firstly, to express concerns about the consultation process itself. Secondly, to propose two tests that we would urge Defra to apply before moving forward with any decision about weakening regulations on gene-edited GMOs, as we believe the consultation fails to address some critically important questions. Note – we will publish this as an open letter on our website.
I am Executive Director of the Food Ethics Council, a registered charity whose mission is to accelerate the shift to fair food systems that respect people, animals and the planet. I hope that we share a vision of a world where everyone eats well and global hunger is a distant memory; where farmers and food producers make a decent living, animals are treated humanely, and the biosphere is nurtured in all our actions.
Concerns about the consultation process and framing
While we welcome the principle of open consultation, we are keen the UK government learns lessons from previous consultations on genetically modified organisms. GMOs including gene-edited GMOs, are highly contested areas, with contested science and different, often competing, views. We want meaningful, constructive engagement and a whole food systems approach, from ‘field to fork’.
The consultation is presented in a one-sided way, which is not desirable or appropriate, as it feels to lots of civil society organisations like a fait accompli. This is likely to lead to further polarisation. It also excludes a number of important aspects of the technology, as well as moral perspectives. Much of the consultation document uses technical language that is not appropriate for a non-specialist audience. For these reasons, many are likely to be put off taking part in the consultation. We want to encourage active participation of as many people as possible (in their role as food citizens) in government consultations of this kind, as I’m sure you do.
Defra’s consultation document states that “GE has the potential to make producing abundant, healthy food part of reducing the environmental impact of a growing global population. It could fine tune and speed up the natural breeding process targeted towards environmental gains in England and help us reach climate and biodiversity goals. It could also help us produce pest and disease resistant crops and disease resistant or resilient livestock to help us adapt to the changing climate. And in many cases, the potential to reduce inputs into agricultural production will also indirectly reduce carbon emissions.”
This begs questions, both about supporting evidence for the claims of potential benefits and about potential concerns or risks, including concentration of corporate power and ownership over food production, contamination and ‘off-target effects’, which do not appear to have been appropriately considered or presented in the consultation document. The absence of information about existing technologies and processes (e.g. biodiverse agroecology) that already achieve, if not excel in realising, similar outcomes confirms the apparent bias. If the consultation is (as we hope) genuine and Defra is truly undecided about whether to weaken regulations, then surely it should not be presented only with claimed benefits.
Two tests the ‘regulation of genetic technologies’ consultation needs to pass
In our view, there are (at least) two critical tests the consultation will need to pass in order for the exercise to have been meaningful. We do not believe the consultation currently looks set to pass these tests. However, in the spirit of wanting constructive engagement, we set these out below, together with selected key questions that we believe it is important to address. Our two tests are:
Will the (potential) benefits and harms relating to food and farming as a whole have been properly accounted for?
Will the ethical case be clear and robust?
For a full copy of the letter, click the ‘download pdf’ button. See also our separate submission to the consultation, which is available here.