ACRE was asked to comment on this application by Defra for the import, processing and use in food and feed as any other maize, including cultivation in the EU of GA21 maize, including molecular characterisation of the event, the environmental risk assessment (ERA) (including effects on non-target organisms (NTOs), potential impacts of associated herbicide regimes on biodiversity) and whether there was sufficient detail in the post market monitoring plan (PMM).
ACRE concurred with the applicant that there were no indications that GA21 maize presented a greater risk to the environment than other maize cultivars. However ACRE considered that there were potential impacts on biodiversity associated with cultivation, management and harvesting techniques of this GM maize.
ACRE discussed proposed herbicide regimes used in association with this GMO and the potential impact on farmland biodiversity. ACRE commented that the application would be strengthened by additional more comprehensive assessment of this risk taking into account the fact the wide range of different sites across the EU where this could be grown and that herbicide regimes and cultivation practices are different in each member state and are constantly evolving. Additionally, ACRE was not sufficiently convinced that the herbicide regimes proposed by the applicant would be the regimes used in practice.
ACRE noted that the argument for general surveillance over case specific monitoring was not convincing. A key part of the post-market monitoring plan is the gathering of data from farmers who grow GA21 maize so that the effect on the environment of growing the crop can be assessed. ACRE commented that the farmer questionnaire and PMM overall was reasonably good, there were areas where improvements could be made. ACRE commented that the farmer questionnaire should request comparisons between crops grown in the same year and in comparison with conventional crops. ACRE noted that it would be useful to have a separate discussion on what is required from general surveillance and considered including this as an agenda item at a future meeting. ACRE questioned why the applicant proposed to limit the number of farmers surveyed to 250 per year rather than to all farmers growing GA21 maize. It was ACRE’s view that the appropriate authorities be notified immediately upon observation of an unexpected occurrence. ACRE recognised that the indirect effects of cultivation and management of GMHT maize are likely to be small and slow to develop, but nonetheless must be monitored for in sufficiently in PMM. ACRE felt that additional information should be supplied on general surveillance networks present in each MS where it was likely to be grown.