Dr. Barbara Doyle Prestwich:

I thank the committee for the invitation to speak on CRISPR-Cas9 gene editing in plants.

As Dr. McLoughlin outlined in his opening remarks, we face enormous challenges in producing sufficient food to feed a growing population, estimated to be 10 billion by 2050. It cannot be business as usual in terms of crop food production. The most recent IPCC report paints a damning picture of our collective inaction in terms of greenhouse gas emissions. Ireland is currently ranked first in the world in terms of global food security in the Global Food Security Index, but the index is dynamic and we cannot afford to become complacent. Unexpected external shocks can have a huge impact on a nation’s food security as evidenced by the ongoing situation in eastern Europe. In addition, under the European green deal and to meet the United Nations sustainable development goals, we in Ireland must make changes in how we produce and manage our crops.

My colleague Dr. Raghuram Badmi will focus more closely on the actual technology. For my part, I will focus on the international scene and why I believe we cannot afford to ignore CRISPR technology in Ireland, and more broadly across the European Union.

The constraints we face in terms of sustainable food production include, but are not limited to, land use, water availability, drought, heatwaves, flooding, disease control and soil health, coupled with an ever-diminishing list of available agri-chemicals. Some might argue that Ireland is not quite at the coalface in terms of impacts of climate change on food production, but it would be a grave mistake to ignore the writing on the wall. At present, we have a toolkit that includes new genomic techniques, also known as new breeding techniques, NBTs, which Dr. McLoughlin referred to and which are continually being rolled out in many countries around the world. These techniques offer precision genetic engineering capabilities that can introduce discrete changes in a plant’s DNA in order to make improvements such as disease resistance and drought tolerance, as well as many others.

What is the international experience of this technology, including CRISPR? As Dr. McLoughlin pointed out, this is a relatively new technology, but already we are seeing its adoption in many countries to great effect. Argentina has been a leader in the regulation of these NBTs since 2015. Data gathered there offers us some insight into the potential of this technology and its impact, not just on crop production but on technological innovation and its democratisation. What I mean by democratisation is that SMEs and the public sector have an opportunity to participate in product development and commercialisation. According to Whelan in 2020, "As a source of codified knowledge, regulations have a direct impact on technology diffusion because they affect the generation of new technologies, as well as decisions on their adoption by potential users". This is very important for both Ireland and the EU.

Over the past 30 years, one of the main criticisms levelled at the plant biotech industry globally has been that the production of biotech crops is in the hands of approximately four multinationals, leading to issues connected with food sovereignty. To a large degree this has been due to the huge cost and time involved in the regulatory and commercialisation process, with no guarantee of subsequent product approval. Due to delays caused by over-regulation, some biotech industries have left Europe - BASF in 2012 is a case in point. Compare this with the development of crops via NBTs over the past three years. I have included a table in my report, Table 1, taken from Eriksson in 2018, where already we are seeing a diverse range of traits being produced. Some have been produced from within the public sector. One can see in the table crops such as soybean, maize, mushrooms and potatoes and the traits vary from drought and salt tolerance to oil content, anti-browning and so forth. Among the players in that table are places such as the Donald Danforth Plant Science Center in the United States and Pennsylvania State University, among others.

Safety and regulation must be top of any country’s list when it comes to the introduction of new technologies. A regulatory process needs to be effective and efficient, and enabling of technological innovation, which should be a major consideration of policy makers. Again, if we look to Argentina, its regulations do not include a list of named techniques per se. As a consequence, they can be agile and are able to respond quickly to small incremental steps in technological innovation. This has led to more innovation. At least seven countries, so far, exempt genome edited products from genetically modified organisms, GMO, regulation where there is no additional DNA incorporated into the plant. Those countries are Argentina, Australia, Brazil, Chile, Colombia, Japan and the USA.

What are the challenges for Ireland? The European Commission’s farm to fork strategy is recognised as a cornerstone of the European green deal. This green deal has committed to no net emissions of greenhouse gases by 2050, a decoupling of economic growth from resource use and no person or country being left behind. However, in realising these ambitions, Ireland will face some serious challenges in terms of crop food production. Under the farm to fork strategy, there is an ambition to halve chemical pesticide use by 2030 under the sustainable use of pesticides directive. However, what are the alternatives on offer with this diminishing use of agri-chemicals? I refer to the technological toolkit, the NBTs that I mentioned earlier, which we cannot afford to ignore. In fact, last month the recently elected chair of the EU Parliament’s agriculture committee, Norbert Lins, called for progress on NBTs.

In conclusion, we in Ireland and Europe cannot afford to ignore the technological advances that CRISPR has to offer in terms of addressing our commitments under the European green deal, specifically climate, biodiversity and food systems. We must also be cognisant of how different national regulatory standards will impact international trade. The EU imports over 32.5 million tons of soybean and soybean meal from South and North America and approximately 5 million tons of rapeseed and rapeseed oil from Ukraine, Canada and Australia. I am not mentioning wheat in that figure. Finally, it was originally thought that the EU Court of Justice ruling that limited access to this technology would also have a large impact on Africa. However, it is now accepted that China, whose five- year plan prioritises new breeding techniques, could fill the gap if the EU fails to engage with the technology. For consumers, food producers and European economies, this would be a grave mistake. I thank the members for listening.