For each question, answers should be broken down:- by the purpose of the genetic modification if this affects the content of the responses,- between ex ante and ex post considerations.1. - Economic and social implicationsUpstream1.1. FarmersFor each question, answers can be broken down by the range of relevant agriculturalstakeholders farmers- farmers cultivating GM crops;- and/or conventional crops;- and/or organic crops;- beekeepers;- seed producers producing GM seeds;- seed producers producing conventional seeds;- seed producers producing organic seeds;…Has GMO cultivation an impact regarding the following topics? If so, which one?- farmers' revenues (output prices and agricultural yields);Comments fromGreenpeaceFarmers cultivating GM cropsThere is no commercial GMO-cultivation in Denmark. Looking at experience from USA it isclear that yield from GMO-crops is not higher. Even the USDA states that“Currentlyavailable GE crops do not increase the yield potential of a hybrid variety. In fact, yield mayeven decrease if the varieties used to carry the herbicide-tolerant or insect-resistant genes arenot the highest yielding cultivars”(The First Decade of Genetically Engineered Crops in theUnited States/EIB-11 Economic Research Service/USDA, p 9).Similar results are reported from Sth America. Speaking about soy cultivation in the state ofMato Grosso, Brazil one grower comments:"We're seeing less and less planting of GMO soy around here. It doesn't give consistentperformance," said Jeferson Bif, who grows soy and corn on a large 1,800 hectare farm inIpiranga do Norte, near the key Mato Grosso soy town of Sorriso.He said he obtained average yields of 58 bags (60 kg) per hectare with conventional soy lastseason while fields planted with GMO soy in the same year yielded 10 bags less.Inae Riveras, Reuters “Biggest Brazil soy state loses taste for GMO seed”, Fri Mar 13, 2009 3http://www.reuters.com/article/internal_ReutersNewsRoom_BehindTheScenes_MOLT/idUSTRE52C5AB200903133

UN panel on agriculture, IAASTD, assess that cultivation in USA of GMO soy and Maize hasnot resulted in improved yields. Rather yields are slightly reduced (IAASTD synthesis reportp 60).-Farmers cultivating organic or conventional crops;The non-GMO supply chain is suffering many extra costs to prevent GMO-contamination.Thereby the application of the polluter pays principle is reversed, meaning that GMO imposesegregation costs on GMO-free producers thereby creating an unfair price advantage forGMO-feed. In a fair system the cost of protecting GMO-free products from GMO-pollutionthroughout the entire food chain should be borne by the polluter.-farmers' production costs;

Comments fromDanish Seed CouncilAPVD (Association of Plant Variety Owners in Denmark)If a GM-variety is accepted for growing the seed producers should be free to grow it inaccordance with the co-existence rules. Seed producers may see not improvements ineconomic output but might realize lower input.- labour flexibility;- quality of the harvest (e.g.mycotoxines);- cost of alternative pest and/or weed control programmes;- price discrimination between GM and non-GM harvest;- availability of seeds and seed prices;Comments fromDanish Seed CouncilAPVD (Association of Plant Variety Owners in Denmark)The farmer must maintain his/her access to seeds etc. from several suppliers/companies andnot be forced to use only one.- dependence on the seed industry;- farmers' privilege (as established by Article 14 of Regulation (EC) No 2100/94 onCommunity plant variety rights) to use farm-saved seeds;Comments fromDanish Seed CouncilAPVD (Association of Plant Variety Owners in Denmark)Farmers and companies in Denmark support the use of certified seed but acknowledge theright to use farm saved seeds when royalties are being paid for those crops where farm savedseed is allowed by derogation from the seed legislation in the EU.Comments fromGreenpeaceCultivation of GMO results in contamination risk. The contamination risk means e.g. that,although farmers privilege (to use farm saved seeds) is protected by legislation, farmers are infact forced to use certified seeds, in order to reduce risk of a contaminated harvest. In many

similar ways even a very small amount of GMO-cultivation will impose lost rights and extracosts on all other farmers.- the use of agriculture inputs: plant protection products, fertilisers, water and energyresources;- health of labour (possible changes in the use of plant protection products);- farming practices, such as coexistence measures and clustering of GMO and/or non-GMO production;- cost of coexistence measures;Comments fromGreenpeaceDetail on DK COEX measures favouring GMO-growers. While the risk is born by the GMO-free farmer. This is worsened because the Danish GMO-liability regime does not ensure thatthe polluter pays, but ensure that GMO-free farmers don’t get compensated.- conflicts between neighbouring farmers or between farmers and other neighbours- labour allocation- insurance obligations;- opportunities to sell the harvest due to labelling;- communication or organisation between the farmers;- farmer training;- beekeeping industry.Comments from:Danish Agriculture and food councilWe have not yet been growing GM crops in Denmark – the main reason is the lack of GM-crops with events that makes sense to grow in Denmark as the only European approved GMcrop is resistant to a pest that do not occur in Denmark.It is, however, the general opinion that in the years to come GM crops will be marketed thatwill have significant importance for Danish farmers. This may be in relation to revenues(output prices on agricultural products) but rather in relation to reduced costs, increasedflexibility in relation to crop protection etcetera – and primarily in relation to cope with thechallenges that follows from climate change such as tolerance in relation to abiotic stress(draught or heavy rain) and biotic stress (increased occurrence of pests and diseases) – solvingthese challenges we will probably need making use of all measures that are availableincluding traditional and modern plant breeding methods.Dependence on seed industry and restrictions in relation to the use of farm saved seeds willprobably be of minor importance in Denmark as most farmers is buying certified seeds and ispaying a license even for farm saved seeds.A prerequisite for growing GM crops in Denmark is, however, that the freedom of choice isguaranteed for all farmers (GM-growers, organic and conventional). In Denmark this isachieved by the legislation on co-existence which protects both the grower of GM crops andother farmers in the neighbourhood growing conventional or organic crops. The way theDanish co-existence legislation is organised should prevent conflicts between GM growersand other farmers as it is based on a dialogue – and protect all parties economically as a lossof income for conventional or organic farmers due to presence of GM material will becovered without any bureaucracy by the compensation scheme that is funded by a minor5

”insurance”-payment of 100 DKK per hectare grown with GM crops. It is essential to notethat the GM groves are also protected economically as they can not be held responsible tocover the loss if they have fulfilled the obligation according to the co-ex law. It might becomprehensive to have a consultation to be sure that the legislation also takes care of theinterests of the beekeepers.The question of costs and benefits from growing GM crops should not be treated isolated butshould be seen in connection with the very large import of feed produced from GM crops andother costs in the production chain in relation European Union legislation on hygiene etcetera.Comments fromThe Danish Beekeepers´ AssociationBeekeepers fear that widespread production of GM-crops will lead tofurther decrease in biodiversity, do to increase in monocultures. Wefear that some GM-crops will have negative impact on the vitality ofhoneybee colonies and demand extensive testing of new GM-crops towardsall stages of bees.The protection of beekeeping and honey production in the "co-existence"legislation is not adequate as the producer of GM-crops is not liable topay compensation in case of any damage.There is no protection for the beekeeper against non intentionallypollution of products from beekeeping from GM-crops. (pollen in honey)Any other impacts you would like to mention:Comments fromCooperation of biodynamic consumersandCooperation of biodynamic agriculturalistsGrowing more GM crops in Denmark and the rest of Europe will put a pressure on third worldcountries, who cultivate few or no GM crops, and/or third world countries where the farmers,the public and the scientists are divided over the cultivation of GM crops. If introducing GMcrops, many such countries have very weak public institutions that are unlikely to be able tosecurely measure and control the use and impacts of the cultivation of GM crops. This is notonly a moral issue, it might even affect European countries directly by creating even morerefugees caused by i.e. GM crop failures or other unintended consequences of the introductionof GM crops. And so, it might have serious socioeconomic consequences.Certified organic agriculture as we know it will probably become completely eradicated, sinceover time the GM traits will spread by natural selection to all non-GM crops. This hasapparently already happened in Canada. The EU should consider the agricultural policyrecommendations for decision makers in North America and Europe as they appear in theregional report of The International Assessment of Agricultural Knowledge, Science andTechnology for Development (IAASTD), issued by a UN-led scientific, agricultural panel inapril 2008, in co-operation with the World Bank. The IAASTD report asks decisions makersto consider the multifunctionality of agriculture. Agro-ecology, including many organicpractices, is encouraged.

It will strengthen competitiveness of European Seed Industry, new developed GM-productssecure the future of the European Seed Industry and exchange of optimized germplasm willhelp to secure the development of new plant varieties necessary to combat the future climaticand population challenges. The development of new products to place on the world market isa necessity to increase or even secure employment, turn over and profits in the long term.On the downside we predict increasing costs for the breeding companies in the developmentof GM crops caused by insurance issues (legal risks), increased development cost caused byfield trials of GM varieties and costly risk assessments and the need to achieve deregulationfor newly developed products.GM-growing is characterized by growing varieties containing many patented traits. Accessto further plant breeding also with varieties containing patented traits must be secured to keepprogress in breeding in the future. Respecting breeder’s exemption based on existing UPOVrules.The unpredictability and uncertainty regarding possibilities for full authorization of GM-cropsare at the moment the main reason for EU seed companies not to engage in the developmentof GM technologies in crops with high out-crossing potential and crops naturally existing inEU (grasses etc.).Comments from:Danish Agriculture and food councilIt will strengthen the competitiveness of the European seed industry as new developed GM-products may be competitive with and be as efficient as seeds from seed producers in other7

parts of the world in relation to meeting the challenges we are facing with increasing globalpopulation and climate change. This is both in relation to selling Danish produced seeds onthe global market and to get access to and exchange of optimized germplasm with seedproducers in other parts of the world. The future competitiveness of European and Danishseed producers is dependent on the ability to develop and place seeds on the global market.The development of new products to place on the world market necessary to increase or evensecure employment, turn over and profits in the long term.On the downside we predict increasing costs for the breeding companies in the developmentof GM crops caused by insurance issues (legal risks), increased development cost caused byfield trials of GM varieties and costly risk assessments and the need to achieve deregulationfor newly developed products.The unpredictability and uncertainty regarding possibilities for full authorization of GM-cropsare at the moment the main reason for EU seed companies not to engage in the developmentof GM technologies in crops with high out-crossing potential and crops naturally existing inEU (grasses etc.).-the production of seeds (easiness/difficulty to findeasiness/difficulty to find areas to produce these seeds…);seedproducers,

Comments fromDanish Seed CouncilAPVD (Association of Plant Variety Owners in Denmark)The production of GM-seeds depends on the crop (out-crosser, natural varieties in productionarea etc.). To find dedicated GM-seed producers is not seen as a problem, however to identifyseed production areas with the least impact on production of conventional varieties can be anissue.The seed companies have to establish breeding and production procedures which allowproduction of GM-, conventional- as well as organic-seed and have to establish certificationprocedures to prove purity as asked for in conventional plant breeding.Seed production in general, this holds true for conventional seed production as well as forGM-seed production, with zero tolerance for adventitious presence isimpossibleand will bea show-stopper for any GM production in the EU.In order to allow coexistence of GM- and conventional seed production practical coexistencemeasures and liability rules must be established for the EU Member States.Comments from:Danish Agriculture and food councilThe production of GM-seeds depends on the crop (out-crosser, natural varieties in productionarea etc.). To find dedicated GM-seed producers is not seen as a problem, however to identifyseed production areas with the least impact on production of conventional varieties can be anissue.The seed companies have to establish breeding and production procedures which allowproduction of GM-, conventional- as well as organic-seed and have to establish certificationprocedures to prove purity as asked for in conventional plant breeding.

Seed production in general, this holds true for conventional seed production as well as forGM-seed production, with zero tolerance for adventitious presence isimpossibleand will bea show-stopper for any GM production in the EU.In order to allow coexistence of GM- and conventional seed production practical coexistencemeasure and liability rules must be implemented in all EU countries making it possible tocontinue organic plant breeding and production of seeds, which is necessary to make a fullchoice of freedom achievable.- marketing of seeds;- the protection of plant breeders rights; - the protection of plant genetic resources.Does the marketing of GM seeds have an impact on the seed industry and its structure in theEU (size of companies, business concentration, competition policy)? Please specify persector.- for plant breeders;Comments fromDanish Seed CouncilAPVD (Association of Plant Variety Owners in Denmark)

The production of GM-seeds depends on the crop (out-crosser, natural varieties in productionarea etc.). To find dedicated GM-seed producers is not seen as a problem, however to identifyseed production areas with the least impact on production of conventional varieties can be anissue.The seed companies have to establish breeding and production procedures which allowproduction of GM-, conventional- as well as organic-seed and have to establish certificationprocedures to prove purity as asked for in conventional plant breeding.Seed production in general, this holds true for conventional seed production as well as forGM-seed production, with zero tolerance for adventitious presence isimpossibleand will bea show-stopper for any GM production in the EU.In order to allow coexistence of GM- and conventional seed production practical coexistencemeasures and liability rules must be established for the EU Member States.Comments from:Danish Agricultur and food councilOnly plant breeders organized in a bigger breeding organization or Seed Companies will havethe ability and financial strengths to engage in GM-crop development. Deregulation and riskassessment costs are too high for small breeding companies, and only a limited number ofproduct leads with a big market potential will be economically viable.On the other hand, the production of organic seed or seed of specific conventional varietiesopens certain niches for smaller breeding companies. Coexistence measures have to guaranteethe existence of both types of breeding industries.- for seed multiplication;9

Any other impact you would like to mention:Downstream1.3. ConsumersHas GMO cultivation any impact regarding the following topics? If so, which one?- consumer choice (regarding quality and diversity of products);- the price of the goods;- consumer information and protection;Comments fromDanish Seed CouncilAPVD (Association of Plant Variety Owners in Denmark)The consumers should have adequate information to make their choices. Production of GMO-crops should be market-driven.Comments fromCooperation of biodynamic consumersandCooperation of biodynamic agriculturalistsCertified organic agriculture as we know it will probably become completely eradicated, sinceover time the GM traits will spread by natural selection to all non-GM crops. This hasapparently already happened in Canada. The EU should consider the agricultural policyrecommendations for decision makers in North America and Europe as they appear in theregional report of The International Assessment of Agricultural Knowledge, Science andTechnology for Development (IAASTD), issued by a UN-led scientific, agricultural panel inapril 2008, in co-operation with the World Bank. The IAASTD report asks decisions makersto consider the multifunctionality of agriculture. Agro-ecology, including many organicpractices, is encouraged.

Comments fromGreenpeaceThe European food industry avoids using GMO as direct ingredient, so in direct food useconsumer choice is largely unaffected. Exception is as in the current GMO-linseed scandal (orthe GMO-rice scandal), where GMO-cultivation result in GMO-contamination of foods.Impact on consumers is firstly that they are exposed to untested GMOs; secondly thatproducts are recalled and therefore not available; and thirdly that the cost of the clean-up inthe end must be borne by the consumers. The current GMO-contamination of linseeds alsoillustrates very well that the costs are much higher than cost of replacing the linseeds. Thecontaminated linseeds have been used in a variety of products (breads, muesli etc) which hasa value much higher than the costs of replacing the linseeds. This is the costs of GMO-contamination that must be quantified for the food chain. In addition to quantifying the cost ofmarket closure and clean-up costs for the GMO-free farmers who unwittingly had theirharvest contaminated with GMO.99% of the GMO used in the EU is used as animal feed. Here consumers are both mislead;consumers demanding GMO-free animal products will have to cover the extra segregationcosts resulting from the use of GMO.Informed consumer choice is hindered as there is no labelling of animal products of animalsfed with GM-feed. A survey from the independent Danish consumer council found that nearlyhalf of the consumers in Denmark wrongly believe that EU law requires that animal productsare labeled if the animals have been fed with GMOs. So, the current labelling scheme ismisleading. It is well established that consumer/citizen concern with GMOs goes beyondimmediate impact on own health and includes concerns for environment, food security,sustainability, corporate control and irreversibility when GMOs are released in theenvironment. Therefore it is making a mockery of consumers interests when GMO labellingonly covers the miniscule use of GMO in food, while exempting the animal productsproduced from millions of tons of GMO feed (99% of the GMO used in EU) unlabelled.A direct result of the misleading labelling law is distortion of the market in favour ofproducers who use GMO-feed. Producers who are responsive to consumer demands andtherefore use GMO-free feeds are not rewarded by the market place for their GMO-freestatus. This creates a market distortion favouring the producers who use GMO-feed.Any other impact you would like to mention:1.4. Cooperatives and grain handling companiesHas GMO cultivation any impact regarding the following topics? If so, which one?- work organisation;- handling and storage;- transport;- administrative requirements on business or administrative complexity.Comments from:Danish Agriculture and food councilThe grain handling companies are already handling large quantities of GM products in theform of imported feed. The growing of GM cultivars in Europe will therefore primarily makeit necessary to handle GM and non GM seeds including making sure the legislation on co-existence is fulfilled. This also include the obligation to making sure that GM seeds are only11

sold to farmers that are allowed to grow GM crops according to the Danish law on co-existence which means they have to be licensed. This will give the companies increasedadministrative costs which eventually will be passed on to the farmers.Any other impact you would like to mention:1.5. Food and feed industryHas GMO cultivation any impact regarding the following topics? If so, which one?- range of products on offer;- employment, turn over, profits;- work organisation;- crop handling (drying, storage, transport, processing, etc...);- administrative requirements on business or administrative complexity;Comments from:Danish Agricultur and food councilThe primary need of the food and feed industry is the free and non-bureaucratic access to acton the global market. Asynchronous approval of GM in Europe combined with the currentzero-tolerance towards not fully approved GM-events despite the risk assessment has statedthey do not impose any risk to human or animal health or to nature is one of the most severeeconomic problems for European food and feed industry. This applies to the production whereGM is part such as feed for conventional livestock due to increased costs and economic riskassociated with the uncertainty that despite non-approved GM events have not been detectedbefore shipment there is always the risk that a very small fraction could be found in Europeancontrol. It does, however also - and perhaps even more severely - apply to those producersavoiding GM such as organic producers that has to comply with a zero tolerance in stead ofthe 0.9 per cent threshold for adventitious and technically non-avoidable presence of approvedGM events.Any other impact you would like to mention:Comments fromGreenpeaceLack of GMO-labelling of animal products distorts the feed market. The application of thepolluter pays principle is reversed, meaning that GMO impose segregation costs on GMO-freeproducers thereby creating an unfair price advantage for GMO-feed. In a fair system the costof protecting GMO-free products from GMO-pollution throughout the entire food chainshould be borne by the polluter.A survey from the independent Danish consumer council found that nearly half of theconsumers in Denmark wrongly believe that EU law requires that animal products are labeledif the animals have been fed with GMOs. So, the current labelling scheme is misleading. It iswell established that consumer/citizen concern with GMOs goes beyond immediate impact onown health and includes concerns for environment, food security, sustainability, corporatecontrol and irreversibility when GMOs are released in the environment. Therefore it ismaking a mockery of consumers interests when GMO labelling only covers the miniscule useof GMO in food, while exempting the animal products produced from millions of tons ofGMO feed (99% of the GMO used in EU) unlabelled.12

A direct result of the misleading labelling law is distortion of the market in favour ofproducers who use GMO-feed. Producers who are responsive to consumer demands andtherefore use GMO-free feeds are not rewarded by the market place for their GMO-freestatus. This creates a market distortion favouring the producers who use GMO-feed.If GMO-labelling of animal products was introduced it would enable consumers to reward theproducers who are responsive to consumer demands. This means that GMO-free producerswould be able to recover any extra costs for GMO-free feed. But fair labelling would alsoentice many more producers to be GMO-free. When more GMO-free feed is demanded theextra costs per feed unit would also be drastically reduced: firstly when scale increase to allowdedicated GMO-free feed plants, secondly when scale increase so much that GMO-free feedcan be ordered as full ships of GMO-free feed (30-50,000 tons) as opposed to ordering onlyGMO-free feed by the hull (3-8000 tons).Introducing GMO-labelling of animal products would be fairly cost-free, provided theindustry is given approximately 6-12 month to adjust, so the producers who want to be GMO-free have reasonable time to secure GMO-free feed supplies. It is assumed that brandedproducts would be first to shift to non-GMO feed. This would be enough to reach economiesof scale and thus result in lowering the GMO-free premium, enticing even more producers tobe GMO-free. If a significant share of EU producers gives signals to be willing to go GMO-free, growers in Brazil and Argentina will immediately increase the availability of GMO-freesoy.1.6. Transport companiesHas GMO cultivation any impact regarding carriers (insurance, cleaning, separate lines...)? Ifso, which one?Comments from:Danish Agricultureand food councilCultivation of GM crops will have the impact that transport companies must fulfil theobligations to prevent spreading of GM and especially to fulfil the requirements of the co-existence legislation. Transport companies are, however, currently also handling importedproducts containing GM or products from GM.1.7. Insurance companiesDoes the GMO cultivation have any impact regarding insurance companies (e.g. in terms ofdeveloping new products)? If so, which one?1.8. LaboratoriesHas GMO cultivation any impact regarding the following topics? If so, which one?- employment, turn over, profits;- feasibility of analyses;- time necessary to provide the results;- prices of the analyses.Any other impact you would like to mention:13

1.9. Innovation and researchDo GMO cultivation and the technology spill over have an impact on the following topics? Ifso, which one?- investment in plant research, number of patents held by European organisations(public or private bodies);- investment in research in minor crops;- employment in the R&D centres in the EU;- use of non-GM modern breeding techniques (e.g. identification of molecularmarkers);- access to genetic resources;- access to new knowledge (molecular markers, use of new varieties in breedingprogrammes, etc.).Recently, the number of different transgenes and traits in new GMO plants applied formarketing has increased significantly and this tendency is expected to continue.Consequently, there will be an increasing need for information and trials concerning thepotential environmental effects of genetic interactions and synergy on target and non-targetorganisms. This issue has already been included in EFSA’s guidelines, but the way ofimplementation still needs to be defined and optimized.Comments from:Danish Agriculture and food councilThe current reluctance regarding GM crops has an impact on European research institutionsand eventually on the number of patents held by European organisations compared toorganisations from other parts of the world and also the future access to genetic resources andtools to include in the other modern breeding technologies including molecular markers.1.10. Public administrationHas GMO cultivation any impact regarding the actions of the national public administrationsand the necessary budget (national and local level) for example policing and enforcementcostsGMO crops are not cultivated in Denmark yet, but Denmark is prepared as legislation oncoexistence between GMO crops and conventional and organic crops has been introduced. Inaddition, a control scheme in order to control compliance with the coexistence rules isintroduced.Any other impact you would like to mention:Economic context1.11. Internal marketDoes the placing on the market of GMO seeds have an impact on the functioning of the EUinternal market on seeds? If so, which one?

The only GMO seed currently allowed for cultivation in the EU is seed from the insectresistant maize MON810. As this maize is not cultivated in Denmark, no experience on thefunctioning of the EU internal market on seeds is available.On the other hand the question on the setting of thresholds for accidental presence of GMOseed in conventional seed (to import) which do not have to be labeled is still not resolved. Soin practice the individual member states are setting their own thresholds. This situationactually harms the trade of seed between member states. The seed industry has been frustratedfor years because of this unsolved problem.Does it have an impact on the internal markets for services (if so which impact and whichservices), for agriculture products and on workers' mobility? If so, which one?Does GMO cultivation have(emergence/disappearance)?animpactonmonopolies?Ifso,whichones

The lengthy approval process for GMO crops in the EU makes it difficult for small and semilarge companies to participate in the development of GMO crops. Recently, the last Danishbreeding company developing GMO crops stopped the development of a GMO ryegrass withan improved nutrient content because of the long prospects of having returns of theinvestments (because of the long prospects of getting a permission to market the seed in theEU). This situation contributes to the development of monopolies as only the big biotechcompanies have the financial volume to tackle this situation. Furthermore, as these companiesare multinational, they get quicker returns of their investments because of the more rapidapproval process in third countries compared to the EU.Does it provoke cross-border investment flows (including relocation of economic activity)?Any other impact you would like to mention:1.12. Specific regions and sectorsAnswers can be broken down on the purpose of the level (national, regional, local) andaccording to region.Has GMO cultivation any regional and local impact in those regions regarding the followingtopics. If so, which one?- agriculture incomes;- farms' size;- the farm production practices (e.g. increase or decrease of monoculture);- the reputation regarding other commercial activities of the region/localities.As there is no experience with commercial cultivation of GMO crops in Denmark, it isdifficult to answer these questions in a Danish context. It is however expected that changes incultivation practises will follow from the cultivation of GMO crops, e.g. with the cultivationof herbicide resistant GMO crops. As an example it is worth mentioning research by theNational Environmental Research Institute which has shown that it is possible to change thecurrent practise of spraying with four herbicides at fixed times to a more flexible sprayingpattern.

The monitoring- and research data in applications for marketing under Directive 2001/18 andRegulation (EC) No 1829/2003 are in most cases primarily based on field trials and data fromoutside the EU. It would strengthen the conclusions of the assessment process if more relevanttrials were made under different environmental conditions in different regions of the EU.Comments from:Danish Agriculture and food councilThe legislation on co-existence should handle these challenges. The structure of farms,differences in which crops that are grown etcetera may be different in different regions andcountries – therefore it is reasonable to have locally adjusted legislation on co-existencewithin the overall EU framework as published on July 23 2003.Comments fromGreenpeaceWHERE ARE IMPACTS IN TERMS OF THIRD COUNTRY TRADE? EU’s GMO-legislation, allow the import of massive quantities of GM products unsustainably produced inmonoculture systems in Latin America has clearly a huge responsibility in causing the serioushealth, ecological social and economic problems these countries are facing. Thousands offamilies have been displaced from their lands in countries like Argentina and now live inslums beside cities, chemical pollution has increased massively (due to weed resistance toherbicides), biodiversity have been lost as well as agriculture diversity, with directconsequences for these countries food security.Any other impact you would like to mention:2. - Agronomic sustainability2.1 Agricultural inputsDoes the cultivation of EU approved GMOs for cultivation have an impact regarding the useof pesticides against target insect pests (i.e. corn borer)?As there are no cultivation experiments with insect resistant GMO crops in Denmark it isdifficult to answer this question. However, experience from Spain on the cultivation ofMON810 maize – which is resistant towards attacks from the European Corn Borer – seemsto indicate that the cultivation of this maize can result in a decrease in the use of insecticides.The potential for reduced insecticide use is obvious, but at present not considered relevant inDenmark because the relevant pest insects constitutes no agricultural problem at present. Incase they will become a problem in the future, the potential effects on non-target speciesshould be considered both in the risk assessment and in the demands for monitoring activities.The possible increase in other pests and control strategies should also be addressed.

Comments from:Danish Agriculture and food councilAs we don’t have these pests in Denmark there has not been any cultivation of these GMcrops. When other crops with effective resistance to native pests in the future will bemarketed it is the clear expectation that it will lead to a reduction in the use of pesticides.Does the placing on the market of GMOs have an impact, and if so which ones, regarding theuse of pesticides or/and on the patterns of use of chemical herbicides?Results from experimental cultivation of GMO feed beets in Denmark indicates that it ispossible to replace the current practise of spraying with four different herbicides at fixedtimes to spraying with a single herbicide at more flexible times.Comments from:Danish Agriculture and food councilA large scale demonstration project in 1999 conducted as a joint venture between seedcompanies, agriculture and the authorities showed that farmers growing GM fodder beet wasvery keen on utilising the properties of the GM beet experimenting both with reduced dosageand delayed spraying with herbicides leading to very high biodiversity in the herbicideresistant GM fodder beet fields – both regarding weeds, insects and birds2.2. Biodiversity, flora, fauna and landscapes (other impacts than the ones considered inthe environmental risk assessment carried out under Directive 2001/18 and Regulation(EC) No 1829/2003)The evaluation of possible effects on biodiversity, flora, fauna and landscape in Denmark hasin numerous cases raised attention to the need for knowledge on environmental effects of thegrowing of herbicide tolerant crops (HT) and insect resistant crops (Bt). At present theseissues are not always addressed properly by the environmental risk assessment carried out bythe companies applying for marketing and mostly only formally included in the associatedmonitoring programs.These knowledge gaps include:Field edge effects– HT-crops alter the seasonal timing and the pesticides that areapplied. The effects of these changes on biodiversity, flora and fauna are largelyunknown and at least poorly quantified.Long term effects– present days’ effects assessment mainly include short or mediumterm effects. The changed herbicide use in HT growing systems may both lead toenvironmental positive and negative effects in the long term. In order to give the bestguidance to the administrations, industries and agriculture, long term investigations ofeffects of different cultivation strategies on biodiversity, flora and fauna should belaunched.Landscape effects– When new crops are grown on a larger scale they can influence thefunction of the landscape. In Denmark the conventional maize area has beenexpanding over the last 20 years. This has already lead to concern for many wildspecies in the agricultural landscape such as lapwings and partridge. Cultivation of17

genetically modified crops will probably enhance landscape effects, but there is verylittle knowledge available on these effects and the associated losses of nature values.Non-target effects– Bt-crops having direct effects on harmful species have a number ofadvantages relative to conventional crops needing to be sprayed with insecticides.Here can be mentioned that it is mainly insects that prey on the crop that are harmedand they often include refuges to prevent build up of resistance in target pests whereunsprayed conventional crops are grown. Such refuges serve as areas for wild speciesin the cultivated landscape. However, Bt-crops also have the potential to affect non-target species. Knowledge on Bt-sensitive non-target species (e.g. different butterflies)is inadequate in Denmark and Europe at present and therefore it will be impossible toassess possible future losses of biodiversity.Monitoring programsable to catch up the abovementioned effects does not exist, or aremost often not applied properly in the post market monitoring. Furthermore, thefeedback from monitoring to risk assessment needs to be improved for attaining moreenvironmentally relevant results. Results from long-term monitoring programmes andother experiences from areas outside the EU could also be used.

Research at the National Environmental Research Institute has shown that the changedcultivation practise that follows from replacing the currently used four different herbicideswith Roundup makes it possible to increase the biodiversity in the GMO feed beet fields if thespraying of Roundup is delayed until later in the growing season.Comments fromGreenpeaceThe environmental risk assessment currently performed in the EU is totally inappropriate, asit is not capable to assess the risks of GM plants. long term environmental risk assessment isnot conducted for GMOs, especially not for GMOs meant for import only (i.e not forcultivation within the EU) and because the EFSA GMO-panel consist of biotechnology andfood safety experts and lacks the scientific expertise and the budget capacity to conduct oranalyse environmental risk assessments.In the past years,new peer reviewed scientific studies have demonstrated that the effectsof Bt maize varieties are far from predictable and their potential to cause negativeeffects is even greater than previously thought.In February 2008, 37 scientists from 11 countries wrote an open letter to EnvironmentCommissioner Stavros Dimas supporting his proposal to reject the authorisation forcultivation of two GM Bt maize varieties (1507 and Bt11). They highlighted the “lack

of

scientific consensus on the safety assessment of GM crops”,

stressed that “data

quality on

available studies is highly variable”

and argued for a “temporary

suspension of cultivation

until a more rigorous risk assessment has been done”.

iTarget insects develop resistance to the pesticidesproduced by the Bt GM crops.iiFarmerswill then be forced to apply both greater quantities and additional varieties of insecticide tofight these resistant pests, to the benefit of pesticides manufacturers, which are often the samecompanies that make GMOs.The European Commission, in its submission to the WTO case, criticised the EUenvironmental risk assessment on GMOs, and on Bt crops in particular, by stating that “the

current state of Bt environmental risk assessment in Europe shows that there were and still

are considerable grounds for concern about the toxin Bt, especially non-target effects,...”

iiiBt maize results in swapping one pest for another.Catangui et al. (2006)ivshowed that in theUS new insects (Western bean cutworm) fill the niche of the pest organism killed by Bt maize(European corn borer).Bt maize (including Bt11 and MON810) is unexpectedly susceptible to aphid infestation.Faria et al. (2007)vdetected differences in amino acid concentrations not described in any ofthe applications for marketing of Bt maize. This demonstrates that Bt maize is subject tounexpected and unpredictable effects and that plant-insect interactions are too complex to beassessed by the current EU risk assessment.The Bt toxin from GM Bt maize may affect headwater stream ecosystems.Rosi-Marshallet al. (2007)videmonstrated that GM crops producing Bt toxins can affect ecosystems viaunexpected pathways, because interactions in the natural environment are complex and notfully understood. Thus, the current risk assessment does not consider all toxicity pathways andtherefore all risks of GM plants.The level of Bt toxin produced by MON810 varies.Nguyen, H. T. & J. A. Jehle (2007)viishowed that the level of Bt toxin produced by MON810 varies strongly between differentlocations and even between plants on the same field. The reasons for these differences are notknown. This raises serious questions about the current capacity to assess the impact of Bttoxins on the environment.Bt toxin affects behaviour of monarch butterfly larvae.Prasifka et al. (2007)viiishowed thatmonarch butterfly’s larvae exposed to Bt maize anthers (the part of the flower that carries thepollen) behave in a surprisingly different way, compared to other larvae exposed to non-Btcrops.Environmental testing invalidated by unknown toxin.Rosati et al. (2008)ixshowed that theBt toxin actually produced by MON810 is likely to be different from the Bt toxin used in thecrop's environmental testing. This invalidates most, if not all, MON810 environmental ‘safety’tests.Leaves or grain from Bt maize could be toxic to aquatic life in streams.Bøhn et al. (2008)xshowed that GM Bt maize could be toxic to aquatic life (insects). This underlines theconclusions of Rosi-Marshall et al. (2007, above) that this unexpected pathway is importantand has not been considered in the risk assessment of Bt crops.Herbicide-tolerant GMOsThe introduction of GM crops tolerant to herbicides such as glyphosate (the active ingredientof Monsanto’s ‘Roundup’) have caused an increase in weed resistance. This lead tosignificant changes in agricultural practices, namelyincreased quantities of more toxicherbicides being sprayed on the crops.The use of Glyphosate dramatically increased with the introduction of Roundup-Ready GMcrops, since their introduction a decade agoxi, xii.Now, glyphosate-resistant weeds areoccurring in direct association with Roundup-Ready GM crop cultivation in many parts of theUS. 34 cases of glyphosate resistance in nine species have been documented in the US since2000.xiii, xiv, xv, xviIn Argentina, new weeds, thought to be resistant to glyphosate, are replacing the usual weedsfound in the fields as a result of cultivating GM herbicide tolerant soya.xvii Now farmers are19

recommended to spray stronger formulas, mixtures and other more notorious of herbicides tocontrol glyphosate resistant weeds.xviii, xixDoes the cultivation of EU approved GMOs have an impact regarding the number of nonagriculture species/varieties?Does GMO cultivation have an impact on agriculture diversity (number of plant varietiesavailable, agriculture species, etc?)Does GMO cultivation have an impact, and if so which one, regarding:- protected or endangered species;- their habitats;- ecologically sensitive areas;Does GMO cultivation have an impact, and if so which one, regarding:- migration routes;- ecological corridors;- buffer zones.Does GMO cultivation have an impact, and if so which one, regarding:- biodiversity;- flora;- fauna;- landscapes.Comments from:Danish Agriculture and food councilIt is the general opinion that the current legislation in the EU ensures that GM crops that canbe marketed without risks to human and animal health and the environment can also be grownwithout any further restriction.Any other impacts you would like to mention:Comments fromCooperation of biodynamic consumersandCooperation of biodynamic agriculturalistsBy introducing more GM crops to Denmark and the EU, several already existing challengesregarding environment, climate and public health will further deteriorate. Allowing more GMcrops within the EU will very likely affect the current restrictions on feed crops grown outsidethe EU. By keeping GM crops out of Denmark and the EU, it is believed (as mentioned in EUpolicy papers and the recent danish government-sponsored GMO-synthesis) that over time thelivestock production within the EU will diminish considerably due to an expected lack ofGM-free fodder. This will have a large-scale positive impact on climate mitigation, waterpollution, water usage, biodiversity and global food resources. Livestock production is,according to the introduction to the FAO report "Livestock’s Long Shadow" (2006) one of thetwo or three main causes behind the most serious environmental challenges, at every levelfrom local to global. Both the Chairman of the UN Intergovernmental Panel on Climate20

Change (IPCC), Rajendra Pachauri, and economist Lord Nicholas Stern, have argued thatmeat consumption should be heavily reduced, the sooner the better. Introducing GM cropswill help to maintain and further aggravate these challenges, as it will allow the unsustainableoverproduction of livestock to continue as it is. This will cost Denmark and the EU possiblytrillions of Euros each year, for environmental, climate mitigation and health costs.2.3. Renewable or non-renewable resourcesDoes the placing on the market of GMOs have an impact, if so which ones, regarding the useof renewable resources (water, soil…)?Does the placing on the market of GMOs have an impact, if so which ones, regarding the useof non-renewable resources?Comments from:Danish Agricultur and food councilFarmers all over the world will be challenged by climate change – therefore resilient cropswith tolerance against draught etcetera will lead to a reduced impact on both freshwaterresources and soil as they may lead to more stable yields with less input of water.Any other impacts you would like to mention:2.4. ClimateDoes GMO cultivation have an impact regarding our ability to mitigate (other than bypossibly reducing CO2 emissions from fuel combustion – see next section) and adapt toclimate change? If so, which ones?Future GM-crops constitute a possible adaptive capacity to climate change. These new cropsare likely to be tolerant to different kinds of climatic stress, i.e. drought, temporary flooding,saline conditions etc. This will help to ensure future supply of agricultural products, but at thesame time pose a pressure on the biodiversity, flora, fauna, landscape and other environmentalvalues. Hence areas that today are unavailable for crop production will be included in arableland and consequently be lost for nature.

Comments fromGreenpeaceGMO-cultivation do not solve any problems but creates many more.In the context of changing climate, Climate change mitigation, food security, soil and waterrestoration, improved crop stress tolerance etc. The solution is multifunctional agriculture asoutlined by the UN panel on agriculture, IAASTD. Some of IAASTDs points summarisedbelow. For an EU context it is worth looking also at the reports from the EU-fundedPICCMAT Working group.-Reduce N2O: An important step in agriculture climate mitigation is to reduce use ofN-fertiliser, in order to reduce N2O (ca 300 times worse GHG than CO2). Beans andlegumes that capture nitrogen from the air need to replace the use of artificial21

fertilisers. In this regard it is a major concern that GMO-soy beans reportedly requireartificial N-fertilisation, as opposed to conventional soy-beans growing in healthysoils.-Increase SOC: Increasing soil organic carbo (SOC) serves many purposes ofimproving soils, improving water management, improving yields, improvingadaptability to erratic weather etc. Most importantly agricultural lands has thepotential to off-set the total direct GHG-emissions from agriculture. Also researchshows that in soils rich in SOC excess nitrogen tends to form N2, rather than N2O.Whereas N2O is a very serious GHG, N2 is not. In regard to SOC GMO has nothingto offer. Soil needs to be managed using organic methods in order to increase SOC,and feed crops should be perennial (grass) rather than single year monocultures (soyand maize).Low input farming. Soy and maize (the big feed crops = the big GMO crops) areprimarily grown in huge monocultures, highly dependent on fossil energy andpesticides. This is the type of farming that GMO-crops were developed for. The typeof agriculture that according to IAASTD will be needed to meet future food supply ismultifunctional farming methods that rely on IPM rather than chemical warfare. Incontrast to IPM, GMO, whether it is Bt or HT GMO-crops, both require more andmore toxins to combat pests. As pests (weeds and insects) develop resistance toroundup and Bt-toxin farmers apply higher and higher dosages roundup (and biotekindustry develop plants that express more and more Bt toxins)

Comments fromCooperation of biodynamic consumersandCooperation of biodynamic agriculturalistsBy introducing more GM crops to Denmark and the EU, several already existing challengesregarding environment, climate and public health will further deteriorate. Allowing more GMcrops within the EU will very likely affect the current restrictions on feed crops grown outsidethe EU. By keeping GM crops out of Denmark and the EU, it is believed (as mentioned in EUpolicy papers and the recent danish government-sponsored GMO-synthesis) that over time thelivestock production within the EU will diminish considerably due to an expected lack ofGM-free fodder. This will have a large-scale positive impact on climate mitigation, waterpollution, water usage, biodiversity and global food resources. Livestock production is,according to the introduction to the FAO report "Livestocks Long Shadow" (2006) one of thetwo or three main causes behind the most serious environmental challenges, at every levelfrom local to global. Both the Chairman of the UN Intergovernmental Panel on ClimateChange (IPCC), Rajendra Pachauri, and economist Lord Nicholas Stern, have argued thatmeat consumption should be heavily reduced, the sooner the better. Introducing GM cropswill help to maintain and further aggravate these challenges, as it will allow the unsustainableoverproduction of livestock to continue as it is. This will cost Denmark and the EU possiblytrillions of euros each year, for environmental, climate mitigation and health costs.

Does the cultivation of EU approved GMOs have an impact regarding energy and fuelneeds/consumption? If so, which ones?Life cycle analyses which compares the effect of cultivation of GMO sugar beet, oilseed rapeand maize with the cultivation of the conventional versions of these crops have showndecreased emissions of CO2 and ozone (e.g., as a result of reduced fuel use), decreasedecotoxicity, acidification and nitrification, reduced emissions of toxic particulates and areduction in carcinogenicity by the cultivation of GMO crops.Does the cultivation of EU approved GMOs have an impact regarding the demand fortransport in general terms? If so, which ones?Any other impacts you would like to mention:

3 - Other ImplicationsComments fromGreenpeaceSocio-economic impact is important in addition to proper risk assessment. Socio-economicimpacts should not be considered as an alternative of bringing the quality of the riskassessment up to the level agreed in Directive 2001/18. The Norwegian GMO-legislationprovides example of the proper way to include socio-economic and sustainability criteria.http://www.regjeringen.no/en/doc/Laws/Acts/Gene-Technology-Act.html?id=173031 see §10“...The deliberate release of genetically modified organisms may only be approved when thereis no risk of adverse effects on health or the environment. In deciding whether or not to grantan application, considerable weight shall also be given to whether the deliberate release willbe of benefit to society and is likely to promote sustainable development...”

The letter can be found on the internet at:http://www.vdw-ev.de/Scientists%20letter%20to%20Dimas.pdfTabashnik, B.E., Gassmann, A.J., CrowdeDr, .W. &C arrière, Y. 2008 . Insect resistance to Bt crops: evidence versus theory. NatureBiotechnology 26: 199-202.European Communities – Measures affecting the approval and marketing of biotech products (DS291, DS292, DS293). Comments bythe European Communities on the Scientific and Technical Advice to the WTO Panel, para 128Catangui M.A. et al. 2006.Western bean cutworm, Striacosta albicosta (Smith) (Lepidoptera : Noctuidae), as a potential pest oftransgenic Cry1Ab Bacillus thuringiensis corn hybrids in South Dakota Environmental Entomology 35 1439-1452.Faria, C.A., Wäckers, F.L., Pritchard, J., Barrett, D.A. & Turlings, T.C.J. 2007. High susceptibility of Bt maize to aphids enhances theperformance of parasitoids of lepidopteran pests. PLoS ONE 2: e600. doi:10.1371/journal.pone.0000600.Rosi-Marshall, E.J., Tank, J.L., Royer, T.V., Whiles, M.R., Evans-White, M., Chambers, C., Griffiths, N.A., Pokelsek, J. & Stephen,M.L. 2007. Toxins in transgenic crop byproducts may affect headwater stream ecosystems. Proceedings National Academy ofSciences of the USA 41: 16204–16208.Nguyen, H. T. & J. A. Jehle 2007.Quantitative analysis of the seasonal and tissue-specific expression of Cry1Ab in transgenic maizeMon810. Journal of Plant Diseases and Protection.Prasifka, P.L., Hellmich, R.L., Prasifka, J.R. & Lewis, L.C. 2007. Effects of Cry1Ab-expressing corn anthers on the movement ofmonarch butterfly larvae. Environmental Entomology 36:228-33Rosati, A., Bogani, P., Santarlasci, A. Buiatti, M. 2008. Characterisation of 3´ transgene insertion site and derived mRNAs in MON810YieldGard maize. Plant Molecular Biology DOI 10.1007/s11103-008-9315-7.Bøhn, T., Primicerio, R., Hessen, D.O. & Traavik, T. 2008. Reduced fitness of Daphnia magna fed a Bt-transgenic maize variety.Archives of Environmental Contamination and Toxicology DOI 10.1007/s00244-008-9150-5Benbrook, C.M. 2004. Impacts of Genetically Engineered Crops on Pesticide Use in the United States: the First Eight Years.

AgBioTech InfoNet Technical Paper Number 7http://www.biotech-info.net/Full_version_first_nine.pdfNandula, V.K., Reddy, K.N., Duke, S.O. & Poston, D.H. 2005. Glyphosate-resistant weeds: current status and future outlook. Outlookson Pest Management August 2005: 183-187.xiiiBaucom, R.S. & Mauricio, R. 2004. Fitness costs and benefits of novel herbicide tolerance in a noxious weed, Proceedings of theNational Academy 101: 13386–13390.xivvan Gessel, M.J. (2001) Glyphosate-resistant horseweed from Delaware. Weed Science, 49, 703-705.xvhttp://www.weedscience.org/Summary/Uspecies MOA.asp?lstMOAID=12&FmHRACGroup=GoxviZelaya, I.A., Owen, M.D.K. (2000). Differential response of common water hempAmaranthus rudisSauer) to glyphosate in Iowa.Proc. North Cent. Weed Sci. Soc., 55, 68. and Patzoldt, W.L., Tranel, P.J., & Hager, A.G. (2002) Variable herbicide responses amongIllinois waterhemp (AmaranthusrudisandA. tuberculatus)populations Crop Protection, 21, 707-712.http://www.weedscience.org/Case/Case.asp?ResistID=5269xviiVitta, J.I., Tuesca, D. & Puricelli, E. 2004. Widespread use of glyphosate tolerant soybean and weed community richness in Argentina.Agriculture, Ecosystems and Environment, 103, 621-624.xviiiSee, e.g. http://farmindustrynews.com/mag/farming_saving_ glyphosate/index.htmlxixBrooks, R.J. 2003. Saving glyphosate. Farming Industry News http://farmindustrynews.com/mag/farming_saving_glyphosate/index.html.Monsanto 2008b. Roundup PowerMAX™ is advertised as “proven on hard-to-control weeds”. http://www.monsanto.comxii