Complaint to DEFRA about new GM seed consultation
See also the Press Release.
To Steve Reed, Daniel Zeichner, and the DEFRA Plant Varieties and Seeds division,
I am writing to lodge a formal complaint regarding the current consultation on the Plant Varieties and Seeds Framework for Precision Bred Plant Varieties.
The consultation supporting documents strongly imply that it is for the public, and respondents can select the category ‘individual’ to describe themselves. However, with one exception, the questions exclusively asses business impacts, and are heavily weighted towards the financial implications for those businesses that develop and supply seeds.
The concerns and opinions of those that buy seeds are not sought. The financial implications for those that wish to, or are legally obliged to, exclude genetically modified precision bred varieties are not adequately addressed.
Markets function properly when there is appropriate and sufficient information about products. The demand-side market will not be able to properly function if there is no information regarding precision bred status on seed packets. Supply will therefore not reflect demand, which will lead to market failure and an inappropriate and inefficient allocation of resources.
Furthermore, the huge number of people and organisations that buy seeds for non-commercial use, and their communities, are completely disregarded in the consultation. Members of the public have been dissuaded from completing the consultation. One such person told GM Freeze: “I’m unable to complete this survey. I can’t get past certain sections which I can’t respond to as I’m not a business.”
One section of the supporting document is entitled “The purpose of a public consultation”. Surely the primary purpose of a public consultation is to elicit the views of the public, not to disenfranchise them in such a way that they are unable to – or dissuaded from – providing meaningful input.
There are an estimated 330,000 allotments in the UK. These are managed by people that clearly care about the food they put in their mouth, does their opinion count for nothing? Around 44% of people with gardens were estimated to be growing food in 2022, is their opinion equally irrelevant?
A public consultation must be for the public. The exercise in question is an economic impact assessment of sorts. This is ironic given the damning report about the Genetic Technology (Precision Breeding) Regulations published by the Secondary Legislation Scrutiny Committee, which raised concerns about the lack of an impact assessment. It also drew attention to DEFRA’s unacceptable use of data in relation to its presentation of the opinions of the general public, which, it was noted, was used to “justify potentially contentious policy decisions.”
One GM Freeze supporter told us, “This public consultation is not including or addressed to the public,” Another asked, “why can we not respond to this consultation as non- commercial growers? This is really important for everyone.”
The consultation has been described to GM Freeze as “fake”. Another person called it a “disgusting exercise… (that) is only interested in those with a business, and the questions are very carefully angled to avoid my concerns.”
We are therefore lodging this complaint not just from GM Freeze, but on behalf of all of the frustrated and furious members of the public and non-commercial growers to whom this “public consultation” is not addressed.
We call on DEFRA to withdraw the consultation and repurpose it so that it genuinely seeks to ascertain the opinions of the public. It should also assess the full range of implications for all businesses – not solely the narrow administrative costs for those businesses that supply seeds. The consultation must be capable of assessing the potential costs to the organic and PBO-free sector, whose businesses may face ruin should seed labelling not be required.
If this consultation stands, and its findings justify a decision to not require on-packet labelling of GM PBO seeds, we can only conclude that it was designed for just this purpose.
Yours in good faith,
Leonie Nimmo
Executive Director
GM Freeze
