I would like to comment specifically on pages 74 to 80 of the report concerning the use of GMOs in agro-ecological production methods.
For the moment the section provides a random undigested collection of claims about GMOs referring to a few scattered reports, while failing to critically assess the validity of those claims and - importantly - failing to evaluate the larger impact of GMOs, within the political, economic, social, ecological, technological and institutional context in which they have been introduced and promoted. The problem apart from ideological differences among the experts who co-wrote the text, is that they don't seem to be well informed about agricultural biotechnology. Already the first sentence in this section shows that they have an old definition of GMO that does not include the New Agricultural Biotechnologies. They talk about "selective gene transfer from one organism to another and between species (Bawa and Anilakumar, 2013)". New agro-biotechnologies do not practice gene transfer any more but induce mutations, 'edit genes' etc.. The immediate menace for agro-ecosystems is the new potential of very rapidely gene editing techniques that transform living organisms that are released in the environment.
The litterature quoted in this section seems 'undigested', unquestioned — sentences that follow one-another draw oppostie conclusions etc. Also important studies such as Benbrook 2016 on the explosion of glyphosate use since the introduction of GM glyphosate resistant crops in 1996 are omitted.
More detailed comments:
p. 76 line 37 Outdated definition of GMO— obviously the New Biotechnologies of gene editing do much more than that.
line 39 "Genetically modified organisms (GMOs) were discovered in 1946 (Clive, 2011)" this sentence is nonsense as GMO were not discovered at a particular moment in time but engineered over a long period of time
p. 78 line/box 16 "An examination of relevant social and agro-ecological factors improves assessments" My comment: Systemic impacts such as herbicide resistance, pest resistance, explosion of secondary pests, only show in the medium and long term. Longterm trials are needed… The nutritional deficiencies of plants produced in the GM complex (genetic modification plus assorted herbicide use) could be examined immediately in the short term.
line 15 "The net economic gains have been due to improved yield and production gains (72 percent) and cost savings (28 percent) (Brookes and Barfoot, 2017)." My comment: How are these gains calculated? Gain per farmer, per farm, per hectare, per ton of grain produced? Ratio of input / output in 1996 and 2015?
Box 17 "Meta-analysis (of peer-reviewed literature, 1996–2016) suggests yields were increased (5.6–24.5 percent) and GM maize had lower levels of toxins (Pellegrino et al., 2018)." My comment: http://advances.sciencemag.org/content/2/8/e1600850
Recent studies in the US showed that herbicide use increased in GT Maize and soy. BT crops that produce their own pesticide for the time being seem to need less external pesticide applications
p. 79 line 3-6 "In May 2018, the US FDA provided a positive food safety and nutritional evaluation of Golden rice, although they noted that it did not have high levels of Vitamin A. An economic analysis of costs and benefits suggested that the delay in the approval for use of GM Vitamin enriched rice (Golden rice) resulted in ~1.4 million life years lost in India over a decade (Wesseler and Zilberman, 2014)." My comment: this sentence is inconsistent with the preceding one, stating that golden rice does not have significantly increased levels of vitamin A
line 19 "engineered varieties resistant to papaya ring spot virus" My comment: What makes them resistant? the plant produces a pesticide? what is the health impact for humans?
p. 81 line 1 "proponents of GM technology assert [...] it can contribute to the realisation of some agroecological principles provided that the social, economic, safety and health aspects of GM technology are appropriately regulated" My comment: What about ecosystem impacts? GM technology needs to be evaluated and monitored.. for instance the longterm consequences of the introduction of Roundup Ready technology for the entire ecosystem... as required in the European Directive 2001/18.
Dear HLPE project team,
I would like to comment specifically on pages 74 to 80 of the report concerning the use of GMOs in agro-ecological production methods.
For the moment the section provides a random undigested collection of claims about GMOs referring to a few scattered reports, while failing to critically assess the validity of those claims and - importantly - failing to evaluate the larger impact of GMOs, within the political, economic, social, ecological, technological and institutional context in which they have been introduced and promoted. The problem apart from ideological differences among the experts who co-wrote the text, is that they don't seem to be well informed about agricultural biotechnology. Already the first sentence in this section shows that they have an old definition of GMO that does not include the New Agricultural Biotechnologies. They talk about "selective gene transfer from one organism to another and between species (Bawa and Anilakumar, 2013)". New agro-biotechnologies do not practice gene transfer any more but induce mutations, 'edit genes' etc.. The immediate menace for agro-ecosystems is the new potential of very rapidely gene editing techniques that transform living organisms that are released in the environment.
The litterature quoted in this section seems 'undigested', unquestioned — sentences that follow one-another draw oppostie conclusions etc. Also important studies such as Benbrook 2016 on the explosion of glyphosate use since the introduction of GM glyphosate resistant crops in 1996 are omitted.
More detailed comments:
p. 76 line 37 Outdated definition of GMO— obviously the New Biotechnologies of gene editing do much more than that.
line 39 "Genetically modified organisms (GMOs) were discovered in 1946 (Clive, 2011)" this sentence is nonsense as GMO were not discovered at a particular moment in time but engineered over a long period of time
p. 78 line/box 16 "An examination of relevant social and agro-ecological factors improves assessments" My comment: Systemic impacts such as herbicide resistance, pest resistance, explosion of secondary pests, only show in the medium and long term. Longterm trials are needed… The nutritional deficiencies of plants produced in the GM complex (genetic modification plus assorted herbicide use) could be examined immediately in the short term.
line 15 "The net economic gains have been due to improved yield and production gains (72 percent) and cost savings (28 percent) (Brookes and Barfoot, 2017)." My comment: How are these gains calculated? Gain per farmer, per farm, per hectare, per ton of grain produced? Ratio of input / output in 1996 and 2015?
Box 17 "Meta-analysis (of peer-reviewed literature, 1996–2016) suggests yields were increased (5.6–24.5 percent) and GM maize had lower levels of toxins (Pellegrino et al., 2018)." My comment: http://advances.sciencemag.org/content/2/8/e1600850
Recent studies in the US showed that herbicide use increased in GT Maize and soy. BT crops that produce their own pesticide for the time being seem to need less external pesticide applications
p. 79 line 3-6 "In May 2018, the US FDA provided a positive food safety and nutritional evaluation of Golden rice, although they noted that it did not have high levels of Vitamin A. An economic analysis of costs and benefits suggested that the delay in the approval for use of GM Vitamin enriched rice (Golden rice) resulted in ~1.4 million life years lost in India over a decade (Wesseler and Zilberman, 2014)." My comment: this sentence is inconsistent with the preceding one, stating that golden rice does not have significantly increased levels of vitamin A
line 19 "engineered varieties resistant to papaya ring spot virus" My comment: What makes them resistant? the plant produces a pesticide? what is the health impact for humans?
p. 81 line 1 "proponents of GM technology assert [...] it can contribute to the realisation of some agroecological principles provided that the social, economic, safety and health aspects of GM technology are appropriately regulated" My comment: What about ecosystem impacts? GM technology needs to be evaluated and monitored.. for instance the longterm consequences of the introduction of Roundup Ready technology for the entire ecosystem... as required in the European Directive 2001/18.