Comment on the MBAA team's blogs (incl. continuative thoughts)

Regulation
	Alexia	Daniel	Sebastian	Tatjana
Two consequences for agriculture in Europe	Ban by the EU of the import of commodity crops	Opportunity to improve productivity and sustainability in agriculture would be constrained	GE plants would be sold like naturally modified (?) plants	Severe hindrance of the use of new breeding processes
	Farmers in the EU would be stretched to their limit (results in competition)	Crop productivity would be improved	Organic food wouldn’t be distinguishable from GE plants	GM (?) food would get more expensive that traditionally bred food; Europe would hold on traditionally bred food
Two consequences for research in Europe	All researched around plant breeding would be disabled Research for commercialisation may be restricted to   large biotech multinationals	Huge potential for biotechnological research (i.e. resistance against diseases) would be neglected	GE as regulated form of GM would stifle innovation in applied research and plant breeding programs	Research of GM (?) food will lose his attraction because too expensive Some promising approaches would never be implemented
	Regionally significant but low-profit crops would be ignored due to the limitation of breeding programs	Could weaken a European nutrition improvement because in GE, there’s much potential	Advantage for farmers because their fields wouldn’t   be contaminated by GM (?) plants	Other breeding methods would be fostered such as radiation breeding
Continuative thoughts (initiated by Petra’s blog comment) What are the consequences of not doing something in terms of regulation?
If GE plants weren’t regulated, a significant opportunity for research would be enabled what could result in further great NPBT. In addition, it could be a precedence case for further juristic/governmental decisions concerning NPBT. On the other hand, the GE technology would likely compete against the GM technology, what would find both supporters and opposers.

Precautionary principle (PP)
	Alexia	Daniel	Sebastian	Tatjana
PP applicable on the breeding process?	Possible and necessary, but difficult in general	Yes (due to the “Principle 15” of the UN)	Yes (due to “Directive 2001/18/EC” of the EU)	Possible for products, different for the production process
Continuative thoughts (initiated by Petra’s blog comment) What are the consequences of not applying the PP on the breeding process?
If PP wasn’t applied in the breeding process, there would exist a non-transparent scope of action for research what could finally result in a local to pandemic catastrophe for both the environment (plants, animals) and human beings. As mentioned by somebody in the movie Jurassic Park (can’t remember which episode and by whom exactly), DNA represents the mightiest power on biologically alive Earth. Cynically said, DNA isn’t a children’s birthday party – treating with DNA needs, from my point of view, precautionary behaviour.

Organic agriculture
	Alexia	Daniel	Sebastian	Tatjana
Regulation for organic agriculture	Tests would be held to analyse what effects monocultures had on the environment	Larger subject for the governments as it is now, what resulted in more regulations for supervision and quality management	The question of the problem needs another formulation…	Testing of the products, the cultivation, fertilizing…
Outlook on organic agriculture	No monocultures; no pesticides; no over-fertilizing…	More regulations which would make organic agriculture sensibly more costly (unprofitable or luxury prone)		Lower food diversity due to many provisions; organic agriculture wouldn’t finally be lucrative
Continuative thoughts (initiated by Petra’s blog comment)       1.     What are the consequences of not regulating organic agriculture?       2.     When thinking about applying the PP to organic agriculture: what could be difficult parts of this agriculture?       3.     Would these 'risky' practices have been prevented and would this not have been worse, making organic agriculture a no-go?       4.   What consequences would this have had for the environment?
1. Organic agriculture, per se, is characterised as GM-free and free of synthetic pesticides and mineral / chemical fertiliser. If there were no regulations at all for organic agriculture, it would be (below the line) less cost-intensive and still GM-free, what made it more lucrative. That, however, could result in more agriculture in general as well as in a competition between agriculture and nature protection. 2.,3.,4. To answer these questions, I would like to pick up Petra’s two examples: Synthetic pesticide applications and using Harmonia axyridis as biological pest control in agriculture. By using the PP in organic agriculture, synthetic pesticides would be substituted by natural pesticide applications, like it has been done with Harmonia axyridis. However, this animal is invasive and causes problems in local food chain. If an animal, such as Harmonia axyridis, was associated with a term like “organic agriculture”, there would be a constant damage to its image.

Genome Editing (GE)
	Alexia	Daniel	Sebastian	Tatjana
Regulation for GE/GM plants	GM (?): bigger benefit (for human beings) than damage (for the environment) – PP is justifiable Importance in terms of climate change and population growth must not be neglected	GE and GM plants should be regulated with an appropriate controlling period (but differently prioritised; GM higher than GE)	GE plants (without foreign DNA) should be treated differently than GM plants (with foreign DNA)	Observation of only the GE products is sufficient GE is not primarily a danger but a chance
Regulation for  radiation breeding programs	Radiation bred plants shouldn’t be classified as GMO	Radiation bred plants should be regulated, like supposed for GE and GM, with an appropriate controlling period (due to unpredictable mutations)	Radiation breeding is the proof for its harmlessness (because of having no foreign DNA?)	For all breeding processes, the same specifications have to be considered For GE the same regulations as for radiation breeding
Continuative thoughts (initiated by Petra’s blog comment)       1.     What are the consequences of not regulating radiation breeding programs?       2.    Does not realizing the potential of GE plants also have huge benefits for the environment?
1. A lack of regulation in terms of radiation breeding, that is recognized as “random and unpredictable” (because no mutation can be controlled), could be critical, especially if "super mutations" occured during that procedure (as mentioned in my blog). These could be i.e. genetic mutations which could cause excessive tolerance in terms of environmental conditions what resulted in a suppression of surrounding plants. 2. First of all, it is important to specify the term “environment”; here, I will use “recent biodiversity”. I could well imagine that GE plants could, in their agricultural dominance, suppress some recent species (i.e. apple trees, the stealthy disappearance of the species-rich high-tribe fruit trees (“Hochstammobstbäume” in German). Therefore, not realizing the potential of GE plants had benefits for the environment indeed.

Effect of PP on the regulation of technical innovations (Blog 3)

Consequences of the regulation based on the breeding process:

The regulation of breeding process in Europe would severely hamper the use of new breeding processes because the procedure genetically modified plants must pass is costly and time-consuming (Hartung et al. (2013)). As a consequence, food from genetic modified plants gets more expensive than food produced in a conventional procedure. Another point is that agriculture in Europe will rely more on conventional breeding and so it is not possible to produce new plant varieties (Hartung et al. (2013)).

The research on genetically modified food will lose his attraction because it is too expensive and some promising approaches never will get implemented because the approval procedure is too complex. So the scientists will focus more on other methods like radiation breeding.

PP for regulation based on the breeding process:

The Precautionary approach was originally created with the aim of protecting the environment, later the European Commission renamed the approach as a precautionary principle and extended it to cover policies to safeguard consumers and human, animal and plant health (Tagliabue (2016)). Since the PP was not particular developed for the regulation of breeding processes the principle is not an optimal method to use for the regulation. The PP places additional regulatory burden on GMO utilization, in consequence it reduces returns from innovation, limits utilisation of GMOs worldwide and provides misplace incentives for research (Ingeborg-Myhr (2007). It is possible to use the PP when just the product has to be considered but when it also is important to assess the way how something was produced the PP achieves his limits.

PP and organic agriculture:

If the organic agriculture had not been invented until today it maybe would be regulated by the precautionary principle. In this case it had to be proven that the hole organic agriculture is harmless for humans and the environment before the products can be sold on the market. Not only the products would have to be tested but also the hole process of growing which includes watering, fertilization and many other things. The development of organic agriculture would progress very slowly because all this steps are very time-consuming and expensive. In the end the diversity of food would not be as big as it is now because there are too many provisions that takes account and the development of organic agriculture would not be lucrative.

Genome editing:

In my opinion it is very important to observe the development on genome editing critical and precise. But I also think that it would be enough just to check the products and not the overall production. In the end the human population especially comes in contact with the end product and it is important not to forget that genome editing is not primarily a danger but a chance. In my opinion it is important that for all breeding processes the same specifications have to be considered. Therefore, I think when plant production with genome editing has to be regulated it is also important to regulate radiation breeding.

Literature:

F. Hartung, J. Schiemann. 2013. Precise plant breeding using new genome editing techniques: opportunities, safety and regulation in the EU. The Plant Journal.

G. Tagliabue. 2016. The Precautionary principle: its misunderstandings and misuses in relation to “GMOs”. New Biotechnology.

A. Ingeborg-Myhr. 2007. The Precautionary Principle in GMO regulations. Norwegian Institute Of Gene Ecology.