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EU Seed Law Consultation

I posted about this before.  They changed to an online submission form, and below are the answers as I submitted them.

Please, no matter where in the world you live, consider filling out the online form and giving your opinion about EU seeds laws.

You don’t have very much time.  Submissions have to be made this weekend to be on time.
1. INTRODUCTION

1.1 What is the name of your organisation?
Bifurcated Carrots
1.2 What stakeholder group does your organisation belong to? (multiple answers possible) Breeder of S&PM
Supplier of S&PM
User of S&PM
Consumer
International organisation
1.3 Please write down the address (postal, e-mail, telephone, fax and web page if available) of your organisation
weblogbb@patnsteph.net http://bifurcatedcarrots.eu/
2. PROBLEM IDENTIFICATION
2.1 Are the problems defined correctly in the context of S&PM marketing? No
2.2 Have certain problems been overlooked? Yes
2.2.1 Please state which one(s):
The loss of biodiversity as a result of the limited nature of DUS and VCU rules. The inability of small breeders and suppliers to make good use of the listings. The limited availability of high quality food to consumers, as a result of the limited nature of the listings. The unnecessary expense to small farmers as a result of being required to purchase seeds from a limited number of suppliers.
2.3 Are certain problems underestimated or overly emphasized? Overestimated
2.3.1 Please indicate the problems that have not been estimated rightly:
The emphasis should be on food-soveringty and not food-security.
2.4 Other suggestions or remarks:
The EU legislation is unfair to everyone except large multinational companies.
3. OBJECTIVES OF THE REVIEW
3.1 Are the objectives defined correctly in the context of S&PM marketing? No
3.2 Have certain objectives been overlooked? Yes
3.2.1 Please state which one(s):
The accessibility to heritage varieties, unstable varieties (for example F3) for use in creating locally adapted varieties and newly bred varieties created by small or independent plant breeders.
3.3 Are certain objectives inappropriate? No
3.4 Is it possible to have a regime whereby a variety is considered as being automatically registered in an EU catalogue as soon as a variety protection title is granted by CPVO? No opinion
3.5 If there is a need to prioritise the objectives, which should be the most important ones? (Please rank 1 to 5, 1 being first priority)
Ensure availability of healthy high quality seed and propagating material 3
Secure the functioning of the internal market for seed and propagating material 4
Empower users by informing them about seed and propagating material 5
Contribute to improve biodiversity, sustainability and favour innovation 1
Promote plant health and support agriculture, horticulture and forestry 2
3.6 Other suggestions and remarks:
Adequate biodiversity cannot be maintained in marketing listings as long as DUS remains a requirement.
4. OPTIONS FOR CHANGE
4.1 Are the scenarios defined correctly in the context of S&PM marketing? No
4.2 Have certain scenarios been overlooked? Yes
4.2.1 Please state which one(s):
Elimination of marketing lists for non novel foods.
4.3 Are certain scenarios unrealistic? Yes
4.3.1 Please state which one(s) and why:
1. This would be unfair for smaller businesses and limit choices for consumers. 2. Same as 1 3. Same as 1 and 2 above, in particular smaller companies would not have the capacity to perform these tests by themselves. 4. Any registration system would favor larger commercial organizations and limit consumer choice. 5. Same as 1, 2 and 3 above.
4.4 Do you agree with the reasoning leading to the discard of the “no-changes” and the “abolishment” scenarios? No
4.5 Other suggestions and remarks:
It is not fair to push registration costs back to companies making the registrations. This means unreasonable costs for smaller companies.
5. ASSESSMENT OF OPTIONS
5.1 Are the impacts correctly analysed in the context of S&PM marketing? No
5.2 Have certain impacts been overlooked? Yes
5.2.1 Please state which one(s):
You are ignoring the fact that wile jobs relating to variety registration would be lost, many more jobs would be created in the independent plant breeding and small farming sectors, in the event of liberalization of EU marketing rules.
5.3 Are certain impacts underestimated or overly emphasized? Overestimated
5.3.1 Please provide evidence or data to support your assessment:
Your assessment on job losses is flawed.
5.4 How do you rate the proportionality of a generalised traceability/labelling and fit-for-purpose requirement (as set out in scenario 4)? 5 = not proportional at all
5.5 How do you assess the possible impact of the various scenarios on your organisation or on the stakeholders that your organisation represents?
Scenario 1 Very negative
Scenario 2 Very negative
Scenario 3 Very negative
Scenario 4 Very negative
Scenario 5 Very negative
5.5.1 Please state your reasons for your answers above, where possible providing evidence or data to support your assessment:
You are ignoring very strong public opposition to current EU seed laws, and proposed changes thereof.
6. ASSESSMENT OF SCENARIOS
6.1 Which scenario or combination of scenarios would best meet the objectives of the review of the legislation? Scenario with new features
6.1.1 Please explain the new scenario in terms of key features:
Complete liberalization of market in terms of traditionally bred varieties. Genuine safety testing for novel foods, no patents or IPRs. Prohibition of GMOs pending environmental impact assessment, establishment of genuine need and true value and consumer demand. True responsiveness to consumer wises from the EU commission.
6.2 Do you agree with the comparison of the scenarios in the light of the potential to achieve the objectives? No opinion
7. OTHER COMMENTS
7.1 Further written comments on the seeds and propagating material review:
I am opposed to patents or other IPRs. I am opposed to marketing lists, except when they are an expression of consumer demand. The amount of GMOs allowed in food should be lowered to 0%. The EU should emphasize food soverignty as opposed to food security. The EU seed laws are a violation to human rights all over the world.
7.2 Please make reference here to any available data/documents that support your answer, or indicate sources where such data/documents can be found:
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Local Superweed — Horsetail

I always find I have nothing in common with the management of our community garden complex.  They are as far from organic minded as you can get, and they have no sympathy for organic gardeners either.  At the same time, they think I have an interesting garden, and recognize me as an experienced gardener, so they always seem to have lots of questions for me that I just can’t answer or mostly just really don’t care.

At the moment everyone’s attention is focused on Horsetail.  It’s really everywhere right now.  Everyone’s garden is full of it, as well as all the untended open space around the gardens.  It’s everywhere that is, except in my garden.  I don’t have a sign of it anywhere.  Every once in a while it pops up somewhere in my garden, but then goes away on it’s own.

The cause of horsetail is pretty clear.  Anywhere you spray with Roundup, you get a serious infestation.  Everywhere else the surrounding plants out compete it, and it goes away.  Horsetail likes very poor soil, which is how most fellow gardeners do their gardens, with as poor soil as possible, then added fertilizer and other chemicals as needed.  Fertile soil promotes weeds, don’t ya know…

So now it’s this urgent problem!  Everyone wants to know why I don’t have the problem, and what they can do to solve the problem so they can keep using Roundup.  The more serious gardeners have switched to more expensive and toxic weed killers, but other gardeners are too thrifty for this and don’t want to spend the extra money.

The other urgent issue is whenever I have canola/rape weeds in my garden, because I guess those all have the Roundup ready gene by now in our area, and they want to make sure I pull them out as soon as possible before they go to seed!  What they don’t know is these are really mustard weeds…

Anyone have any ideas for explaining to my fellow gardeners that I just don’t care what kinds of special weed problems they have after using Roundup?

Anyone with an established organic garden have problems with horsetail?  Anyone with an organic garden have problems with other Roundup ‘superweeds’?

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Brussels Action 17-18 April 2011 — The Message

With our tractor in the lead, on Monday the 18th we marched!

In addition to the demonstration on Monday, there were workshops on Sunday with equally compelling messages.

Olivier de Schutter, the United Nations Special Rapporteur on the Right to Food, gave his message in a video. His position is clear. The European seed laws are a violation of human rights.

Representatives of Turkey and India spoke about the problems they have in their countries because of European seed laws.  However bad it might be for us here in Europe, it can be far worse for people living in other countries.

Please, no matter where in the world you live, make your voice heard on the new EU seed laws!

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Brussels Action 17-18 April 2011 — Food, Wine and Song

One of the fantastic things about getting a group of people like this together, was all the great food!

The evening before, when most people coming from out of town were arriving, they held a potluck dinner.  Can you imagine, seed savers coming from all over Europe, bringing with them things from their own gardens or local markets?  Since people were arriving over the course of the evening, dishes kept getting added to the buffet, so it was possible to go back every hour or so for more…  Many people brought local breads and cheeses.  A number of farmers were present, and some meats were on offer that looked very home made.

The day of the seed swap vegetarian meals were provided by „popular kitchen” of the „collectif du 123”.  It was really nice!

When the seed swap and workshops were over, day turned to evening and the music started.  The organic drinks came out, and the celebration began.  This band played salsa and world music:

On the day of the demonstration itself, great sandwiches were served for lunch and during the march we had a little impromptu music…