Hi all,

The email that Jane sent interested me very much, but it was so garbled
on my machine that I couldn't read it so I spent a few hours fixing it
(See below).  Jane, I couldn't figure out how to set up Tables A and B.
Could you help me?

I live completely away from any other farm and everybody who lives up
here on our hill is organic anyway.  I only sell herbs, but grow our
food.  What must it be like to live in Iowa and try to be organic?  I
found the considerations in this study relevant.  If no organic farmer
could maintain uncontaminated seed, then we couldn't have certified
organic produce and food products.

What think you?

Merla


*  *  *  *  *


The Executive Summary of this Suppressed Study is at the Bottom of this
message!

Greenpeace International: EU suppresses GE study:
GE crops add high costs, threaten organic

BRUSSELS, BELGIUM, 16 May 2002 - A secret European Union (EU) study
leaked
to Greenpeace states that all farmers would face high additional, in
some
cases unsustainable costs of production if genetically engineered (GE)
crops
were commercially grown in a large scale in Europe. The study predicts
that
the situation would become particularly critical for organic farming of
oilseed rape as well as for intensive production of conventional maize.
The study was ordered in May 2000 by the EU Commission, to examine the
co-existence of GE and non-GE crops. It was carried out by the Institute
for
Prospective Technological Studies of the EU Joint Research Centre.

When the study was delivered to the EU Commission in January 2002, it
came
with the recommendation that it not be made public.

Lorenzo Consoli, EU policy advisor for Greenpeace says that, "The
European
Commission has tried to keep this study secret because it was afraid of
its
Political implications."

"The question is, if the introduction of GE crops on a commercial scale
in
Europe increases costs of production for all farmers, makes them more
dependent on the big seed companies, and require complicated and costly
measures to avoid contamination, why should we accept GE cultivation in
the
first place?" asked Consoli.

The EU study states that in oilseed rape production the co-existence of
GE
and non-GE crops in a same region, even when "technically possible",
would
be "economically difficult." This is because of the additional costs and

complexity of changes required in farming practices in order to avoid
genetic contamination.

Both organic and conventional farmers "would probably be forced to stop
saving seed and instead buy certified seed", because of the increased
risk
of GE impurity for seeds that have been exposed to field contamination.
The
study predicts that smaller farms would face relatively higher costs
compared to larger entities, and that cultivation of GE and non-GE crops
in
the same farm "might be an unrealistic scenario, even for larger farms."




EXECUTIVE SUMMARY

Background, objectives and scope

1. If genetically modified (GM) crops eventually increase their share in
EU
agriculture, adventitious presence of GM varieties in non-GM seeds and
crops might become an issue.  Therefore there is a need to find
appropriate measures at the farm
level to minimise adventitious presence of GM crops.

2. The objectives of this study, covering three model crops, are to
� identify sources and estimate levels of adventitious presence of GM
crops
in non-GM crops at farm level,

� identify and assess changes of farming practices that could reduce
adventitious
presence of GM crops in non-GM crops below policy-relevant thresholds,

� estimate costs of relevant changes in farming practices, costs of
monitoring systems
and costs  of potential insurance systems to cover possible financial
losses due to
adventitious presence of GM crops in non-GM crops.

3. The study covers three arable crops, with several farm types for each

crop in representative production areas of the EU:

� winter oilseed rape (OSR) for seed production (certified and
farm-saved
seed) (France, Germany)

� grain maize for feed production (Italy, France)

� potato for direct consumption and food processing (UK, Germany)

4. The three model crops have been studied on different conventional and

organic farm types, representing the average farm context for each of
the different production in the selected geographical areas (certified
and farm-saved OSR seed,
intensive and nonintensive maize cultivation, early and regular
potatoes). For a better comparison similar farm and plot sizes have been
assumed for conventional and
organic farms. Additionally smaller organic farm types have been studied
to reflect the actual situation in some Member States.

General Findings

5. Sources of adventitious presence of GM crops in non-GM crops at farm
level are seed impurities, spread of pollen and seeds from field to
field by wind,
insects and machines, overwintering of plants and plants growing from
spread
seeds as well as mixing of crops after harvest.

6. The percentage of GMOs grown in the region represents an important
factor, already a level of 10% GM varieties in the region causes
significant
increase of GMO content in non-GM crops. Two scenarios of 10 % or 50 %
share of GM crops in the region were analysed. A share of 50 % mimics
the
current situation in countries which adopted GM crops readily (e.g. in
2000, GM
soybeans represented about 54 % of the American soybean acreage, GM rape

seed represented about 50 % of the Canadian rape seed acreage) and is
the principal scenario examined in the study, while a share of 10 % GMOs
illustrates an
introduction phase of GM crops in EU agriculture.

7. Farming practises such as the treatment of soil, sowing dates,
rotation
systems and the infrastructure of the farm, as well as farm and plot
size may influence
levels of adventitious presence of GM crops in non-GM crops.

8. Threshold levels that have been studied here are 1 % (for maize and
potato crops), 0,3 % (for OSR seed production) and 0,1 % (for all three
model crops).
The two first are thresholds that have been integrated in European
legislation or are being discussed in this context.  The latter (0,1 %)
reflects the quantification limit of current analytical methods and
mimics the condition of zero GMO content. The 1 % and 0,3 % threshold
can be met in both scenarios studied but with changes in farming
practices needed for any farm types. In certain cases studied, farming
practices, which involve a co-operation between neighbouring farms, are
the most effective ones. To estimate onfarm levels of adventitious
presence of GM crops in non-GM crops and to compare the effects of
changing farming practices a combination of expert scientific opinion
and computer models was used. The latter provide levels of adventitious
presence of GM crops with a
relative value (i.e. they are useful for comparisons of farming
practices). Their absolute values (e.g. when considering if a particular
threshold can be respected) have to be taken with care, since the are
not yet fully validated.

9. The possibilities to meet a very low threshold (0,1 %) were analysed
for
all three model crops. The results show that compliance with this
threshold would be difficult in and of the two scenarios considered,
even with significant changes in farming practices. Thus, if applying
the very low de facto threshold currently required in organic production
(detection limit), organic production of GMO-free crops would not be
feasible in a region with GM crop production.

10. Compliance with the 1 % threshold would result in additional costs
(changing farming practices, monitoring system, insurance) of 1 % - 9 %
of current product price for maize and potato. For OSR seed production,
the equivalent costs would be 10 % - 41 % of current price. These costs
include all identified costs, also those affecting the GM crop
production. This reflects the present situation regarding legal
obligations for commercial GM crop production.

Specific Findings

Winter oilseed rape for seed production

11. For production of certified or farm-saved seed four organic and
conventional farm
types are studied. Certified seed producers are assumed to grow OSR
according to
certified seed production standards (e.g. for hybrid seed an isolation
distance of
300 m and a 6 year rotation, careful postharvest segregation). The farms
using farm-saved seed are assumed to be larger (about three times) with
larger plots. The conventional farm applies a short 3 year rotation,
exchanges seed and shares machinery with its neighbours or uses
contractors (for example for harvesting). It has no dedicated machinery
for GM crops and no dedicated storage facilities. A summary of farm
characteristics, predicted levels of adventitious presence of GM OSR in
non-GM OSR, recommended changes in farming practices and related costs
is shown in Table A of the Annex to this Summary.

12. For the estimation of in-field levels of adventitious presence of GM
crops in non-GM crops the computer model GENESYS has been used. It ranks
cropping systems according to their probability for gene flow from
herbicide tolerant OSR to rape volunteers,
both in time (via seeds) and in space (via pollen and seeds). It is
suitable for seed as well as for crop production. Expert opinion was
used for estimations of post-harvest levels of adventitious presence of
GM OSR.

13. Applying current practices, levels of adventitious presence of GM
crops
are estimated to range from 0,42 % to 1,05 % for the considered farm
types in the presence of 50 % GMOs (see Table A). Organic farm types
(with current practices) are predicted to have higher levels of
adventitious presence of GM OSR mainly because of their lower efficiency
in volunteer control compared with conventional farms (see Table A,
current practices). All farm types, organic as well as conventional,
could achieve a hypothetical
0,3 % threshold for GMO content in seed production by changing farming
practices.

14. Theoretically, levels of adventitious presence of GM crops could be
reduced to very low levels (< 0,1 %) by changing farming practices. The
only exception would be conventional farms using farm-saved seed, where
achieving such low levels
seems not to be feasible without changing the post-harvest farming
strategy completely
(see Table A, best change of practices).

15. Levels of adventitious presence of GM crops depend on field sizes
(as
shown by studying an additional small farm scenario), isolation
distances, volunteer control and the farm structure regarding
post-harvest handling of the seed crop (possibility to segregate).  In
addition, for OSR the initial seed purity and the selected crop variety
(varietal associations and hybrids with reduced male fertility or - for
seed production - with male sterile parent lines are very prone to
crosspollination) play an important role.

16. The model predicted as effective measures:

Avoiding at any time throughout the rotation cycle cultivation of rape
seed within a radius of 300 m surrounding the seed production field
(costs difficult to estimate due the need for farreaching changes of
crops and rotations).

Changing set-aside management by sowing the field in spring in order to
minimise survival of rape volunteers (estimated to 194 ?/ha additional
costs).

Longer rotations with an additional (non-rape) spring crop to control
volunteers (no additional costs assumed).

Sowing GM OSR one month before non-GM OSR in order to have a difference
in
Flowering time.

This farming practice is very effective but not reliable enough
because of its dependency on favourable weather conditions.  The
selection of measures depends on the type of farm, but in general
changing set-aside management and
establishing OSR-free zones of 300 m around the plot are the most
efficient
practices, though they are rather costly or require co-operation between

farmers. The EC Scientific Committee on Plants (SCP), in its opinion
from
13 March 2001, recommends an isolation distance of at least 600 m for
hybrid seed
in the year of seed production to avoid cross-pollination.

Maize for grain production

17. For grain maize production seven farm types were studied
(conventional
and organic, intensive and non-intensive cultivation, large and small
organic farms).
Main features of intensive maize cultivation are the high percentage of
maize grown
(50 % to 80 % of the agricultural area) and varying but generally small
isolation
distances between different plots. In contrast, farms cultivating maize
in non-intensive cultivation regions (maize representing 20 % of the
agricultural area) are assumed
to have larger plots and isolation distances of about 500 m. A summary
of
farm characteristics, levels of adventitious presence of GM crops in
non-GM
crops, recommended changes in farming practices and related costs is
shown in
Table B of the Annex to this Summary.

18. The computer model MAPOD was used to estimate the effects of
changing
farming practices on the level of in-field adventitious presence of GM
maize in non-GM maize via cross-pollination.

Post-harvest levels were estimated by an expert panel.

19. Applying current practices, levels of adventitious presence of GM
crops
in non-GM crops are estimated to range from 0,16 % to 2,25 % for the
considered
farm types in the 50 % scenario (see Table B).

20. Cross-pollination from GM plants is the main source of in-field
adventitious presence of GM maize. The impact depends on relative plot
size of the
GM source and the non-GM recipient as well as on isolation distances.
Small
farms or farms with smaller fields would be more affected. Volunteers in
maize
are not a significant source of adventitious presence of GM crops.

21. Impurities in the certified seeds used for sowing would also be an
important source of adventitious presence of GM crops. According to OECD

schemes a varietal purity for conventional certified maize seed of 99,0
% is required.
In the study, adventitious presence of GM seed in conventional maize
seeds is
assumed to be 0 - 0,3 %. For organic seed lower seed impurities could be
expected,
reflected in the assumed level of 0,05 % in this study.

22. For conventional farms the post-harvest handling of the grains
represents another principal source for adventitious presence of GM
crops as
maize is often cleaned, dried and stored in central facilities, where
adventitious
admixture could occur.

23. Conventional intensive maize producers may need to change farming
practices to comply with a threshold of 1 % (in both scenarios of 10 %
or 50 %,
and considering an adventitious presence of GM seeds in the seeds used
of about
0,3 %). Lowering seed impurity would have a big impact but might be
difficult
to achieve (opinion of the SCP from 13 March 2001).  Increasing
isolation
distances to 100 m - 200 m, the introduction of varieties for GM and
non-GM
maize with different flowering times and improving post-harvest
management
(storage, cleaning and drying facilities dedicated to non-GM maize)
would be
possible alternatives. The costs of increasing isolation distances and
changing
post-harvest management have not been determined because of their very
complex nature. For a difference in flowering time to be effective, the
GM
variety has to flower earlier than the non-GM variety. Because of
generally lower
yields for earlier varieties, this would lead to additional costs of
about 45 ?/ha
(for GMO producers) (see Table B, best change of practices, additional
costs).

24. In less intensive maize growing regions, for conventional farms it
may
be sufficient to change the post-harvest management to meet a threshold
of 1 % (an adventitious presence of GM seed in non-GM maize seed of 0,3
% has been
assumed) (see Table B, best change of practices).

25. Organic farms (not growing GM maize on their farms) using organic
seed
with high purity and having a post-harvest management separated from
conventional production, could meet a threshold of 1 % without changing
current farming practices.

26. A threshold of 0,1 % seems to be extremely difficult to achieve for
any
of the farm scenarios.

Potato for fresh consumption and processing

27. Potato has very different characteristics compared to oilseed rape
and
maize, as the harvested potato is not the result of a fertilisation
event. Therefore it has
far less problems regarding pollen flow as a source for adventitious
presence of
GM crops. In four farm types studied (conventional and organic
production of early potatoes and potatoes for direct consumption and
processing), the main problems are caused by groundkeepers and
post-harvest handling of the crop.

28. Expert opinion alone was used to estimate in-field and post-harvest
levels of adventitious presence of GM crops in potatoes. Applying
current farming
practices including a careful segregation of varieties, the estimated
levels of
adventitious presence of GM crops in non-GM crops range from 0,1 % to
0,54 % (see Table C in the Annex to this Summary).

29. All considered farm types would be able to meet a 1 % threshold
without
changing farming practices. Organic farms face levels of adventitious
presence of GM crops of less than half of those of the conventional
farms. However, even with changes
in farming practices, a threshold of 0,1 % would probably not be
achievable for any
farm type. The farm characteristics and results for potato are presented
in Table C.


Applicability of existing segregation systems

30. Segregation systems in place (such as those for waxy maize of high
erucic acid oilseed rape) are not suitable for the purpose of minimising
adventitious presence of GM crops in non-GM crops, without some
significant changes. In
general the thresholds assured by these systems are less stringent than
those being established for GM crops. Also, some of these systems are
backed by cheap, fast
and easy detection methods (iodine staining for waxy maize) while
current
methods for detecting and differentiating GM varieties do not yet have
these
characteristics.


Monitoring adventitious presence of GM crops in non-GM crops on the farm

31. Monitoring systems could be developed adapting the Hazard Analysis
and
Critical Control. Point methodology (HACCP), to define crucial steps in
the
production process to be controlled.

Different degrees of control intensity, adjusted to thresholds and
probability of adventitious GMO presence, could be achieved by varying
the
production steps to be included.  At each stage of the cultivation
process, steps to
assure segregation have to be documented. The scheme would be supported
by
detection methods (qualitative and quantitative GMO Polymerase Chain
Reaction
(PCR) analysis).

32. Detection and quantification of GMO content is usually done by
analysing
the transgenic DNA by PCR or the protein content by immunoassays
(Enzyme-linked ImmunoSorbent Assay, ELISA).

These tests are rather time-consuming and need laboratory equipment as
well
as skilled personal.

To enable control of GMO content on the farm level, accurate, cheap,
quick
and easy to use testing methods based on PCR and ELISA need to be
developed.
Currently, test prices are in the region of 320 ? for a quantitative PCR
analysis
of a single sample or 150 ? for a semi-quantitative analysis of a single
sample
by ELISA. Prices might decrease when larger numbers of samples are
tested.

33. Several national and international organisations are involved in
developing harmonised guidelines and standards for sampling strategies
and
GMO detection methods. Validation of testing methods, especially PCR, is

undertaken by performing ring trials with different laboratories. The
major
initiative in this field in the EU is the European Network of GMO
Laboratories, organised by the Joint Research Centre / Institute for
Health
and Consumer Protection (JRC /IHCP). Certified reference materials for
PCR
and ELISA tests of specific GMOs have been developed by Joint Research
Centre / Institute for Reference Materials and Measurements (JRC /IRMM).



Insurance systems

34. If adventitious presence of GM crops in non-GM crops occurs above a
set
threshold a reduction of income could be expected. Organic farmers would
also
lose possible organic price premia and subsidies, so their short-term
losses would
be higher. Indicative insurance costs have been calculated on the basis
of short-term
losses and an assumed frequency of exceeding the threshold of 3 %. In
the medium
and long-term additional costs for crop management to control GM
volunteers, for
GMO testing and control might arise. For organic farms, to regain the
organic
status might take time and imply a further loss of income.


Cost impacts

35. Costs presented below are those needed to meet thresholds of 0,3 %
for
OSR seed and 1 % for maize and potato crops, in the 50 % scenario.

36. Changing farming practices, where necessary, leads to very different

economical burdens for farmers according to crop and farm scenario.
Costs of
monitoring systems have a high impact on all farms. Monitoring costs
include a
large part that is fixed per farm unit, therefore total costs would be
negatively
correlated to farm size. Indicative insurance costs have a large impact
on
most organic farms due to high price premia, and negligible effects on
conventional farms.  Differences in yields and prices between crops lead
to
dramatic differences in economic impact, although the costs per ha may
be of
similar magnitude. This is illustrated in Figure A of the Annex, which
presents
total costs as percentage of product price.

37. For OSR, farms producing conventional certified seeds would have
additional costs representing10 % of the price, the largest part of the
costs being
monitoring costs. For the corresponding organic farm, costs would
represent
more than 20 % of the price, the difference being due to higher costs of
changing agricultural practices. For seed saving farms, the costs would
represent
17 % (conventional) or 41 % (organic) of the price, the organic farm
having
to apply a more expensive additional farming practice. These farms would
probably
be forced to stop saving seed and instead buy certified seed.

38. For maize additional costs for intensive conventional production
would
correspond to 9 % of the price, with almost half the costs originating
from yield
losses due to change of flowering time.  However, costs of necessary
changes of
the post-harvest management for conventional farms have not been
estimated in
this study. For an organic farm located in the same area, costs would
represent
6 % of the price, mainly monitoring costs and indicative insurance
costs. In
nonintensive maize production (organic or conventional) costs would
represent
4 % - 5 % of the price.  In the organic farm, high product prices reduce
the
economic effect on the total costs, despite rather high indicative
insurance costs.

39. Potato is the less affected model crop. There is no need to change
agricultural practices for any of the farms and a very high yield as
compared
to oilseed rape and maize further decreases the costs per tonne.
Monitoring
and indicative insurance costs would amount to 1 % - 3 % of the farm
gate
price.

40. In general organic farms have higher costs per hectare and per tonne

compared to conventional farms. This is caused by slightly higher
monitoring
costs and higher indicative insurance costs as well as, in some cases,
higher
costs for changing farming practices.  However, when relating costs to
product
prices, the price premia for organic crops reduces this difference
considerably.


Future research needs

41. Some of the recommended farming practices could also be employed by
farmers growing GM crops. Further studies will be needed to identify and

evaluate the effectiveness of practices that these farmers could
specifically
use to minimise probability of adventitious presence of GM crops in
non-GM
crops. This could include also specific biological characteristics of GM
crops for
containment of transgenes.

42. More information on actual levels of seed impurities in the lots
marketed in the EU (which is becoming available from some Member States
laboratories) is essential for simulations like the ones presented here.
Also, a
study similar to the one described here for OSR seed could be useful
for maize seed, to better understand how co-existence will impact on
seed
production and to provide information for an adaptation of seed
production
standards.

43. An exhaustive laboratory survey of the actual presence of traces of
GM
crops in non-GM crops (in countries where GM crops are widespread) is
lacking.

44. For a more comprehensive analysis of economical impacts of
co-existence
a deeper analysis concentrating on the complete economic environment of
a farm
could be envisaged.


Annex to Summary

Table A: Levels of adventitious presence of GM OSR in non-GM oilseed
rape
seed production in conventional and organic agriculture with current and
with
recommended farming practices (50% GMOs in the region, medium-term
evaluation)*

Certified hybrid seed production Farm-saved seed production

Farm type Conventional

Organic Conventional



(50% GMOs also

grown on the farm)



Organic

Farm characteristics



Farm area

Plot size

Number of (seed) plots

131 ha

6 ha

1-2

131 ha

6 ha

1-2

351 ha

11 ha

6-7

351 ha

11 ha

6-7



Current practices



Total rate of adventitious

presence expected

0.42% 0.61% 0.59% 1.05%



Best change of practices

To meet threshold 0.3%



Total rate of adventitious

presence expected

To introduce a

spring crop in the

rotation

0.19%

Spring sown

set-aside***

0.04%

Dedicated

machinery,

cleaning machinery

0.23%

Spring sown

set-aside

0.11%



Additional Costs (? / ha) ~0** 194.3 93.2 194.3



Best change of practices

To meet threshold 0.1%



Total rate of adventitious

presence expected

Spring sown

set-aside

0,03%

Spring sown

set-aside

0,04%

Not achievable Combination of

pratices****

0.07%



Additional Costs (? / ha) 194.3 194.3 198.6

* The seed bank is assumed to be pure at the beginning of the
simulations

** No additional costs compared to current practices

*** Advancing GM OSR sowing date is also an effective measure, but
depends
on favourable weather conditions and

thus is not reliable enough.

**** Combination of practices includes difference in sowing time, chisel

before other crops than rape, spring sown setaside

and region-wide border management



Co-existence in European Agriculture Summary



Table B: Levels of adventitious presence of GM maize in non-GM grain
maize
production in conventional

and organic agriculture with current and with recommended farming
practices
(50% GMOs in the

region)



Intensive maize cultivation area Non-intensive maize cultivation area

Farm type Conventional

France



(50% of GMOs

in and outside

the farm)



Organic

large

Organic

small

Conventional

Italy



(50% of GMOs

in and outside

the farm)



Conventional



(50% of GMOs

in and outside

the farm)



Organic

large

Organic

small

Farm

Characteristics



Farm area

Plot size

Number of plots

60 ha

3-4 ha

14

60 ha

3-4 ha

14

10 ha

1 ha

1

50 ha

8 ha

3

100 ha

20 ha

1

100 ha

20 ha

1

15 ha

3 ha

1



Current practices



Total rate of

adventitious

presence expected

2.25 %

(+/-0.6%)

0.16 %

(+/-0.07%)

0.58 %

(+/-0.04%)

1.75 %

(+/-0.2%)

0.8 %

(+/-0.5%)

0.17 %

(+/-0.09%)

0.32 %

(+/-0.04%)



Best change of

practices to

meet threshold

1%



Total rate of

adventitious

presence expected

50 days

difference in

flowering time

+

post-harvest

management

0.66 %

(+/-0.3%)*

Current

practices

Current

practices

Minimum

distance 200m

+

post-harvest

management

0.69 %

(+/-0.3%)*

Post-harvest

management

0.51 %

(+/-0.3%)*

Current

practices

Current

practices



Additional costs

(? / ha)



45.4 + n. d. 0 0 n. d. n. d. 0 0



Threshold 0.1% Not achievable

* It is assumed that the percentage of seed impurities is 0-0.3%. For
homozygous GM maize varieties, the

effect of seed impurities in the produced crop is doubled. Therefore it
is
assumed that the effect of the seed

impurity is in the interval of 0 - 0.6%, here expressed as 0.3 +/- 0.3%.

n.d. not determined



Co-existence in European Agriculture Summary



Table C: Levels of adventitious presence of GM potatoes in non-GM potato

production in conventional

and organic agriculture with current farming practices (25 to 50 GMOs in
the
region)



Potatoes for direct consumption and

processing

Early potatoes

Farm type Conventional



(25 to 50% of GMOs

also grown on

the farm)



Organic Conventional



(25 to 50% of GMOs

also grown on

the farm)



Organic

Farm

Characteristics



Farm area

Plot size

Number of plots

150 ha

10 ha

3

150 ha

10 ha

3

75 ha

3 ha

5

75 ha

3 ha

5



Current practices



Total rate of

adventitious

pesence expected



0.36 %

(+/-0.15%)

0.1 %

(+/-0.02%)

0.54 %

(+/-0.21%)

0.16 %

(+/-0.05%)



Best change of

practices to

meet threshold 1%



Current practices Current practices Current practices Current practices



Additional costs

(? / ha)



0 0 0 0



Threshold 0.1% Not achievable



Figure A: Total costs of achieving thresholds for adventitious presence
of
GM crops in non-GM crops as

percentage of farm gate price (targeted threshold 0.3% for oilseed rape,
and
1% for maize and potatoes)



* For conventional maize, costs for changes in the post-harvest
management
are not included.



Co-existence in European Agriculture Conclusion



CONCLUSIONS



Consumers, food/feed industry and retailers demand a reasonable degree
of
choice between GMO- and non-GMO-derived products. But different modes of

agricultural production are not naturally compartmentalised. If GM crops
increase
their share in EU agriculture (which is now minimal) questions arise
concerning their possible co-existence with non-GM crops (conventional
and organic)
at farm level or regional level. Some of these questions are of
agronomic
and economic nature, and these are addressed in this report:

* What will be the levels of adventitious presence of GM crops in
organic or
conventional crops, with current farming practices if the share of GM
crops increases
to 10% or 50%?

The study was done for three crops for which GM varieties are available
(oilseed rape for seed production, maize for feed production and
potatoes for
consumption), and for several farm types (both organic and conventional)
that
were defined to cover the variability present in EU farming
infrastructure. For
all crop-farm combinations, a hypothetical share of GM crops of 10 % or
50 % in
the region was considered. A share of 50 % mimics the situation in
countries
that adopted GM crops readily (for example the share of GM oilseed rape
in Canada
is currently 54%), while the 10 % figure represents a scenario of slow
adoption of
GM crops in the EU.

In these scenarios, an estimation of the expected levels of adventitious

presence of GM crops in non-GM crops was done with a combination of
computer modelling and expert opinion. The estimations have a strong
relative value (i.e. they
are useful in predicting the effect of a change in farming practices)
but the absolute
figures obtained have to be taken with care since the models are not yet
fully adjusted
with field data.

The estimated levels of adventitious presence of GM crops do not change
dramatically between the two scenarios of GM crop share (10 % or 50 %).
A practical consequence is that measures to prevent adventitious
presence of GM crops (see below) may have to be implemented in the early
stages of adoption.

On the other hand, the estimated levels of adventitious presence of GM
crops in
non-GM crops - assuming current farming practices vary significantly
depending on
the crop and farm type (for example, as much as 2,2 % for a conventional
intensive
maize farm or as low as 0,1 % for an organic potato farm). In general
there is a trend to expect lower levels of adventitious presence of GM
crops on organic farms, because of segregation systems already in place,
but there are notable exceptions.  For example
in seed production of rape, organic farms will face higher probability
of adventitious presence of GM crops due to problems in controlling
volunteers with Organic practices.

Sources of adventitious presence of GM crops are well known, and can be
divided into
four main origins (seed impurities, cross-pollination, volunteers and
harvesting-storage practices). The relative importance of each source
for the final level depends on the crop
and farm type: volunteers are a key source of adventitious presence of
GM crops for
rape seed farms (especially organic) but are of low importance in maize
farms, where
seed impurities and cross-pollination account for most of the
adventitious presence of
GM maize.

* Can this adventitious presence of GM crops in organic or conventional
crops be reduced below certain policy-relevant thresholds with changed
farming
practices?

Once again the answer depends on the farm-crop combination. The
thresholds
used in the analysis are similar to those being discussed in various
regulations. These
are 0,3 % for seed production of allogamous species (rape) and 1 % for
maize and
potato crops (for food-feed uses). All farm types producing oilseed rape
seed or conventional maize will need significant changes to meet their
thresholds. In some
cases (dependent on farm type) changing farming practices at the
individual farm
level will be insufficient. In these cases changes may involve
co-operation
between neighbouring farms. Examples are the introduction of sowing date

differences between GM and non-GM varieties, or region-wide border
management.
In contrast, all potato farm types and some maize farm types (organic)
could meet
these thresholds with current farming practices (with all the
reservations already
mentioned for the value of absolute figures).


* Can adventitious presence of GM crops in organic or conventional crops
be
avoided?

The possibility of changing practices to meet very low thresholds for
all
crops, near the analytical limit of quantification (~ 0,1 %) is also
considered
in the report. This reflects the situation in organic farming where the
use of
GM varieties is not permitted (Council Regulation (EC) 1804/1999),
setting
a de facto threshold. The report concludes that a 0,1 % limit will be
extremely difficult to meet for any farm-crop combination in the
scenarios
considered (10 % and 50 % GMOs in the region), even with significant
changes in farming practices. Perhaps some farm types producing seed of
oilseed rape could approach such thresholds, but only with significant
changes
of farming practices.

* What is the cost of these changes?

Compliance with the 1 % and 0,3 % thresholds through changes in farming
practices and introduction of a monitoring system as well as likely
insurance
needs may result in additional costs of 1 % - 10 % of current product
price
for the farm-crop combinations studied (in the 50 % scenario).
Exceptions are
found in the production of seed of oilseed rape, where costs can be much

higher in particular farm types (up to 41 %). In all cases, monitoring
activities
account for a large part of the additional costs.

Cost reductions might be possible with segregation becoming an
integrated
part of agricultural practices and with decreasing costs of GMO tests.
Generally,
organic farms face higher costs (especially indicative insurance costs)
per hectare
and per tonne than conventional farms. However, when relating costs to
product
prices, the price premium for organic crops may reduce this difference
considerably.

* Can the different types of production co-exist in a region?

This question has to be examined case-by-case for each crop. However, it

seems clear that coexistence with thresholds in the region of 0,1 % is
virtually impossible in any of the scenarios considered. When
considering the
0,3 % (production of seed) and 1 % (food-feed production) thresholds,
co-existence of GM and non-GM crops in a region (with 10 % or 50
% GMO share) might technically be possible but economically difficult
because of the costs and complexities of changes associated. This is the
case
exemplified by seed production of rape. For potato the costs are much
lower and no significant change of practices is needed, so co-existence
could be a reality. The costs and types of adaptation of maize growers
put
this crop in an intermediate situation, but some types of conventional,
intensive
maize farms will have difficulties in a co-existence situation.

* Can the different types of production co-exist on the same farm?

Finally, cultivation of GM and conventional or organic crops on the same

farm might be an unrealistic scenario, even for larger farms. Due to the

importance of volunteers, oilseed rape seed producers will exclude
growing
GM crops on the same farm to avoid adventitious presence of GM seeds in
their non-GM seeds. Also for maize and potatoes it would make the
handling of the
crops rather difficult.


...............................................

Be the change
you want to see in the world.
-- Mahatma Gandhi

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