1. The Organic Research Centre © The Organic Research Centre Welsh GM Co-existence proposals. June 2009

2. The Organic Research Centre © The Organic Research Centre EU GM Coexistence Issue of subsidiarity for the EU commission. EU Directive 2001/18/EC;  calls for member states to take appropriate national measures on coexistence (“living side by side in mutual toleration”) in order to avoid unintended presence of Genetically Modified Organisms (GMOs) in other products. Measures should be;  Proportionate  Avoid unnecessary burdens to farmers etc

3. The Organic Research Centre © The Organic Research Centre EU GM Coexistence EU Commission provided the framework for member states to build their own regimes.  The Christmas Tree.

4. The Organic Research Centre © The Organic Research Centre EU GM Coexistence Member states to provide the detail.  Decorations.

5. The Organic Research Centre © The Organic Research Centre EU GM Coexistence EU Commission provides the limited box of decorations to choose from.

6. The Organic Research Centre © The Organic Research Centre Welsh GM Co-existence proposals. June 2009

7. The Organic Research Centre © The Organic Research Centre Key Points A Statutory National Register of where GM Crops to be grown.  Public.  3 months in advance of planting. Statutory Training and Certification. A Statutory Duty to Inform  Neighbours  Landowners, contractors, purchasers of land and public (via register).

8. The Organic Research Centre © The Organic Research Centre Key Points Statutory Record Keeping.  Name, address of grower,  Name, address of landowner,  location of field,  type and variety of crop,  amount of seed…… Statutory Enforcement and Monitoring  WAG responsible.

9. The Organic Research Centre © The Organic Research Centre Key Points In the Field.  Statutory Isolation Distances.  Statutory Buffer Zones, Pollen Barriers/Traps  Statutory Cultivation Intervals Voluntary Code of Practice to include;  Field Margins  Production Planning – different flowering times etc  Seed Handling  Cultivation and Tillage  Control of Volunteers

10. The Organic Research Centre © The Organic Research Centre Key Points No specific organic coexistence requirements as overall measures take into account organic concerns. GM Crop Production Free Zones.  Voluntary Civil Liability, Economic Loss and Compensation  GM sector should have statutory liability for economic losses caused by the use of GM crops.  new statutory tort, a voluntary industry led compensation scheme or a statutory industry funded redress mechanism

11. The Organic Research Centre © The Organic Research Centre Issues – weasel words The proposal is clear that it is about the need to minimise unwanted mixing of GM and non-GM material. EU law requires “Member States may take appropriate measures to avoid the unintended presence of GMOs in other products”. Concerns about the ability of the Voluntary Code of Practice to deliver.

12. The Organic Research Centre © The Organic Research Centre Issues – “adventitious” WAG = the presence of technically unavoidable amounts of GM material in non-GM crops. Chambers 21 st Century Dictionary = Happening by chance; accidental. OED shows a similar definition.

13. The Organic Research Centre © The Organic Research Centre Issues Dealing with an introduction scenario. Very limited range of crops. Not future proofing.

14. The Organic Research Centre © The Organic Research Centre Issues – separation distances etc CropSeparation Distance MBuffer strip m Maize2004 Beet504 Potatoes204 Oilseed rapeNo recommendations made as too difficult to coexist.

15. The Organic Research Centre © The Organic Research Centre Issues - Seed Using 0.9% adventitious level as a target not a threshold. Proposed seed levels of between 0.1 and 0.5% Result in an extremely limited margin for error to meet a 0.9% final level in product. What happens during processing? Seed levels must be set as undetectable to allow product to leave a farm gate with as low as feasibly possible GM presence.

16. The Organic Research Centre © The Organic Research Centre Issues - honey No specific measures to protect Welsh honey from contamination with GM pollen from nearby crops (para 2.6). EU Commission advised that any GM pollen in honey can be regarded as adventitious and unavoidable; but Recently a Bavaria court ruled that honey containing GM maize pollen could not be sold.

17. The Organic Research Centre © The Organic Research Centre Issues – other Co-existence appears to be aimed at commercial holdings.  No specific mention of gardeners and allotment holders  Although it does say neighbours. Cross boarder  Consultation has preference to agree a mutually acceptable arrangement.  clear difference between the proposed England and Wales regimes.

18. The Organic Research Centre © The Organic Research Centre Consultation Process WAG have asked a series of questions (34) to be addressed plus any other pointes you think should be in the included for consideration. Evidence to support your views. 12 week consultation period. Response to WAG before or on 22 nd September 2009. Further consultation on any draft regulations that might come out of this consultation.