Reacción a "The Council of the EU will vote tomorrow on a proposed regulation governing the marketing of genetically modified microorganisms"

A major problem with the proposed relaxation of Directive 2001/18/EC for the release of genetically modified microorganisms (GMM) is, that it has been inspired by little scientific evidence, and with no consultation of ecology researchers. Considering that ecologists are the experts in the study of the interactions of organisms with the environment, this oversight compromises the scientific credibility of the proposal. Namely, many statements in the proposal about both benefits and risks of GMM release are based on belief instead of sound scientific evidence.

Additionally, postulated benefits for e.g., agriculture, are not weighed against the backdrop of myriads of studies suggesting highly effective solutions to adverse environmental effects of intensive agriculture, such as diversification. Instead, from a scientific point of view, the proposal may yield many potential environmental risks.

Due to the manifold biological interactions in natural systems, the release of novel organisms is, as shown in myriads of ecological studies, a gamble with a completely uncertain outcome. Even the behaviour of novel plants, which can be better monitored, and for which most species have been described, is largely impossible to predict. Vice-versa, less than 1% of the microbial diversity is currently known, and their ecological role is speculative. GMM taxa span across the entire tree of life, such as fungi, bacteria, archaea, protists, or microalgae, whose lumping into a common category contradicts the most basic scientific knowledge.

The European Commission has recently repeated that deregulation of e.g. New Genomic Techniques should not apply to microorganisms and animals, due to our insufficient knowledge about them. It appears almost cynical that even before a deregulation for NGT plants is confirmed, the Commission proposes a ‘low risk’ category of GMM, for which risk assessment and monitoring would be waived. Moreover, the proposed criteria for such GMMs are vague, partly circular, and at odds with scientific evidence. For example, there is no such thing as a gene of ‘low concern’, given that we do not even know what GMMs will do in the environment. We also know that biotic interactions, such as competition, predation, or facilitation, with the unknown microbial diversity in the wild cannot be derived from lab studies, explaining both observed failures of ‘desired’ GMM effects, as well as potential risks. Furthermore, microorganisms can transfer genetic material across species, and while highly detrimental consequences of this are well-known (e.g. spread of antibiotic resistances), such horizontal gene transfer is an active area of research.

Where the existing directive takes full account of the dearly needed precautionary principle, the proposed changes may create major environmental risks. These include the alterations of the microbiome of other organisms, including humans, changes of complex biotic interaction networks of the rhizosphere, displacement of native microbes, endangerment of local microbial diversity before it is even described, reduced resistance and resilience to future environmental change, and cascading effects to higher trophic levels.

GMMs will evolve fast, interact with a multitude of other organisms, will be difficult to trace, and cannot be called back. With billions of microbes in soils and microbiomes of ‘higher’ taxa, GMM release also affects plants, animals, humans, and non-target microbes which, under the proposed changes, may not even be monitored. This makes GMMs a moving target for environmental assessments, suggesting much more strict regulation of GMM release than for all other organisms.

Overall, GMM should not be released into the environment without scientifically sound, case-by-case risk assessment. They must be traceable, release should be strictly time-limited, and effects re-evaluated regularly. Ecologists must be involved in both developing, as well as conducting scientifically sound and reliable approaches for GMM risk and benefit assessments.