Center for Bio-diversitet

To the Commision  / Agriculture DG

att: Leo Maier & Adelmo Moreale

In view of the fact that genetic erosion is continuing on a broad front whereas action is being taken in respect of individual breeds [and] varieties we feel that it is important that the EUs new genetic resources regulation represents a full commitment to the obligations in the 1992 Rio Convention on Biological Diversity.
This can only happen on the following basis:
(1) By creating favourable conditions for the general publics use of domesticated biodiversity in their daily lives by rationalising the rules in all fields of EU legislation having an impact on how accessible and attractive that diversity is.
(2) By giving the people the right to that biodiversity on their own terms and acknowledging that biodiversity is a function of cultural diversity.
(3) By [acknowledging] that domesticated biodiversity means more than just threatened farm breeds and thus favouring all man-made animal breeds which do not belong to modern intensive farming breeds.
(4) By [acknowledging] that NGOs in this field are not the same as in many other fields because, unlike, for example, nature conservation associations, we tend our part of the biodiversity with feed, water and weeding every day. Which is why support to NGOs in this field needs to be more flexible.

(1) Rationalising EU legislation
The more difficulties and requirements there are imposed on animals and plants the smaller their populations become. That is why it is very important for the conservation of biodiversity in EU countries that those elements of the Convention which oblige the signatories to integrate respect for biodiversity into their legislation, to identify rules which suppress biodiversity and to introduce rules which favour biodiversity are implemented without delay.
Those elements of the Convention do not seem to figure at all in the discussion of the new EU genetic resources regulation.
The Convention states that signatories must, inter alia:
identify processes and categories of activities which have or are likely to have significant adverse impacts on the conservation and sustainable use of biological diversity, and monitor their effects through sampling and other techniques
(Convention, Article 7(c)),
develop or maintain necessary legislation and/or other regulatory provisions for the protection of threatened species and populations,
where a significant adverse effect on biological diversity has been determined pursuant to Article 7, regulate or manage the relevant processes and categories of activities
(Convention, Article 8(k) and (l)),
integrate consideration of the conservation and sustainable use of biological resources into national decision-making,
adopt measures relating to the use of biological resources to avoid or minimise adverse impacts on biological diversity
(Convention, Article 10(a) and (b)).
Where domesticated biodiversity is concerned, the EUs rules on livestock husbandry and veterinary conditions are actually a serious threat to biodiversity. Probably more important than national rules; in any event the Danish authorities reject all criticism from NGOs by referring to the fact that these are EU rules.
We therefore need to find new solutions for all those cases which do not involve diseases which are a serious threat to human health.
In Denmark the authorities meet any proposal in that direction with derision; but the likelihood is that there are already two veterinary standards for the same disease: one for wild animals and one for animals in captivity. With a little commonsense the border between the two standards could be shifted so that small livestock herds are excluded from the agriculture rules. Thus small herds which are not in contact with the major foodstuffs industry, for example, are vaccinated against foot and mouth, etc., in cases where there is a risk.
Conservation is supported by the commitment and desire of the general public to participate in breeding which is not motivated by profit, activities which create value for society but which cannot be expressed in financial terms. So it is not possible to preserve a broad biodiversity while at the same time continuing to impose more and more bureaucratic and veterinary requirements on breeders. That trend must not just stop, it must be reversed or else the traditional breeding culture, which has hitherto preserved much of the biological diversity, will disappear.
Rules the only purpose of which is to regulate the large-scale production of livestock and crops cannot be imposed on small-scale producers without crowding them out. A holding earning good money can survive almost unlimited bureaucratic difficulties provided it makes a net profit; but if the incentive is not financial potential new producers will drop out if the going gets too hard.
It is important to recognise that breeders not making a financial profit have a different relationship to their animals than modern large-scale producers, a relationship that is more akin to that which people have to their dogs or horses or which countryfolk had to their domestic animals in traditional farming culture. So there is no chance of success unless those breeders are exempted from the customary bureaucratic measures for the agriculture sector, just as the disease-related slaughter policy is unacceptable for animals kept for cultural and social purposes. Where animals are concerned, it is precisely bureaucracy and veterinary policy which are the two greatest barriers to realising the great potential for grass-roots participation which exists in the rich European countries.
The slaughter policy is a threat to biological diversity both because small populations genetic basis can be reduced to dangerously low levels under adverse circumstances and because the latent threat of the slaughter of a years unprofitable breeding work will keep interested people from getting involved in breeding.
An International Evaluation of Danish efforts to conserve domestic livestocks genetic resources actually recommends special dispensations at national and European level:

New rules to control the outbreak of diseases, or merely to increase standards in animal welfare, can have an adverse impact on keeping breeds in conservation plans.
RECOMMENDATION: Where safe and appropriate there should be exemptions from certain animal health provisions at both national and European level.
(Alderson, Mousing and Oldenbroeck, Copenhagen, May 2002)

Agriculture organisations have apparently from time immemorial believed that unregistered livestock on small holdings presents a disease risk, but the truth is that most outbreaks of disease originate on intensive farms where the animals immune system is working overtime, and it would greatly benefit both animal welfare on small holdings and genetic diversity if backdoor sales of industrial hybrids could be banned and instead traditional old-fashioned breeds and their farmyard crosses could be made more accessible to people who wish to rear a few animals for domestic needs.
In the same way, there is apparently a handed-down view that the exchange of small amounts of plant material (e.g. potatoes) between allotment owners is a greater threat than the import of vast quantities from other parts of the world.
Finally, we must recognise that consumers and tax-payers will scarcely keep on accepting an animal health policy based on the financial concerns of the sector. Consumers do not comprehend the slaughter of healthy animals because of diseases that do not infect humans and which the animals can readily survive or be vaccinated against by their profit-hungry owners.

(2) The biological and cultural diversity
We doubt that the obligations under the Rio convention can be upheld without incorporating protection of the traditional farming culture. The highly technical gene-oriented model will demand greater financial resources while at the same time conserving less.
Breeders of traditional breeds and varieties are not farmers in the modern sense; rather they are small-scale breeders, hobby breeders, self-sufficient breeders, pure breeders and similar cultural niches where the traditional farming culture has survived since it was forced out of productive agriculture many years ago by considerations of efficiency, just like the traditional breeds we wish to preserve.
The Rio convention obliges us to conserve animals and plants in situ; but also to protect and promote the traditional lifestyle and culture that belongs with rearing domestic animals and growing crops. This is a question of the peoples rights to preserve the living cultural heritage and to manage it in accordance with their own traditions and customs, and the regulation by experts of what should be conserved and by what means, such as we have experienced in Denmark, does not live up to the Rio convention. Signatories to Rio undertake to:
respect, preserve and maintain knowledge, innovations and practices of indigenous and local communities embodying traditional lifestyles relevant for the conservation and sustainable use of biological diversity
(Convention, Article 8(j)), and
protect and encourage customary use of biological resources in accordance with traditional cultural practices that are compatible with conservation or sustainable use requirements
(Convention, Article 10(c)).
Where both animals and plants are concerned, the grass-roots participation of the people in conservation work is for a totally different reason than the production-oriented interest modern agriculture has in preserving genes with production potential.
That distinction is quite pronounced in a highly productive country such as Denmark where agricultural production is a highly specialised, closed industrial sector and hobby breeders can afford to produce animals or plants exclusively for conservation purposes, aesthetic qualities, historical interest, taste - ignoring a return in quantity terms.
When breeds or varieties lose their financial significance they either disappear or producers continue to breed them for other reasons such as conservation, thoroughbreeding, competitions - thus for cultural and social purposes.
Under the right conditions traditional breeds can become popular for such alternative purposes, perhaps so popular that aid schemes become less important for them - that is already the case for poultry, pigeons, ducks, geese, sheep, goats and horses. The problem for these species is not a dearth of interested breeders but that the breeders are being frightened off by the maze of rules, bureaucracy and stringent animal health regulations.
So the cultural dimension and the promotion of breeding for purposes other than production are very important in our rich country where agriculture is too efficient for traditional breeds and where, in contrast, ordinary people can afford to rear animals for cultural purposes.
The breeding culture is also a valuable lifestyle in terms of both the environment and society because it gives people more things to do in their leisure time, does not consume resources and reinforces local social networks.
It is important the legislators and administrators acknowledge that modern productive agriculture to a large extent represents the opposite interests and that the rules should be adjusted to take account of current breeders and favour the production of animals and plants for purposes other than pure production.
The grass-roots will take great profit from having our raison dÍtre acknowledged through the establishment of a structure with the direct objective of safeguarding the interests of the popular breeding cultures more cultural and social use of the biological diversity, and not simply of having us along as a compulsory appendix to conservation efforts the purpose of which is to secure the raw material for agricultures improvement work. In most areas our interests are quite different from those of agribusiness and there is a need for quite different measures to preserve the popular cultural tradition surrounding hobby farming and conserve species diversity and variation.
In Denmark the Centre for Biodiversity has proposed to Food Minister Mariann Fischer Boel setting up a Committee for biological and cultural diversity; something similar would be advantageous at EU level because not only national law, but to a large extent EU law too affects developments.
Without breeders and the breeding culture cultivated plants and livestock would be homeless so it is a major paradox that the authorities make life so difficult for breeders that they give up hobby farming while at the same time devising fine aid schemes for the preservation of old breeds/varieties!
Indications from the livestock genetics committee in Denmark are frightening, since the rate of replacement among producers who are contracted through attractive livestock premiums is incredibly high in comparison with the breeds with which the breeders have a link through a breed association - regardless of whether they receive support or not!
It has been found that aids neither replace the commitment of breeders who have selected breeds out of affection nor compensate for the bureaucracy or difficulties involved in constantly registering and finally those same aids just trigger another burst of rules and forms.

(3) Greater latitude in definitions
The new genetic resources regulation should be made broader, beyond the formulation that genetic resources cover species which are or may be important for agricultural production. Precisely in the most developed parts of the world where many breeds and varieties have already been converted to a primarily cultural use, e.g. many breeds of poultry and horses, and where the survival changes of many breeds depends on their finding a niche where their productive characteristics are replaced by a more recreational purpose.
In addition, there are many breeds of pigeons, dogs and cats that have never been bred with a view to food production in Europe; instead they are bred for social functions, for amusement or for display for various purposes.
Article 2 of the Convention on Biological Diversity defines precisely those domesticated or cultivated species as: species in which the evolutionary process has been influenced by humans to meet their needs.
Many third world countries list in the FAOs World Watch List breeds which are only produced for cultural purposes and entertainment and we in the EU should understand that mans needs go far beyond agricultural products we can eat, and we can afford to preserve species without production potential.
In The Global Strategy for the Management of Farm Animal Genetic Resources the FAO describes domestic animals cultural significance as follows:
Domestic animals as social and cultural assets
Many communities have traditions and lifestyles that are fundamentally linked to domestic animals. While it is not always possible to assign monetary values to such linkages, the non-monetary values to local community identity are essential.
Social and cultural values are often underappreciated outside indigenous and local communities. However, to many communities, livestock and particular genetic types of livestock are fundamental aspects of social and cultural identity, linked to marriage, religious practices and other community events. (p. 11) Rome 1999
and in its Primary Guidelines for Preparing National AnGR Management Plans the FAO stipulates the best way to describe each individual breed as follows:
List all important uses of livestock in the nation. These will obviously include the production of food, fibre and animal power, but should not neglect the value of manure for fuel and fertiliser; recreational, cultural and religious uses; and the use of farm animals as a method of risk reduction and holding and protecting assets in unstable economies. (p. 49)
The new regulation should start from a broader view of what biological diversity is. It is possibly best defined by describing what it is NOT. Biological diversity is not worldwide breeds or industrial hybrids.
Biological diversity is not a collection of numbered genes defined by scientists in the service of agribusiness - it is a dynamic quantity in constant interaction between committed breeders, nature and time.
Biological diversity is not an end-product which we can preserve and freeze but a dynamic evolution of old and new gene combinations.
If we wish to preserve biological diversity we will need to do something for the entire living cultural heritage and something extra for breeds only found in a few countries or of particular genetic value.
 
(4) EU support to NGOs
The peoples participation in conserving the biological diversity is mostly completely unorganised; people do it out of tradition and do not connect it with the wider context of the preservation of varieties, etc. We consider that to be the traditional lifestyle and breeding culture that the Rio Convention calls on us to promote and preserve. It is a peasant culture and cannot by definition by registered, organised, etc., without losing its character.
The organised associations role is to increase quality, e.g. by facilitating the exchange of plant material which is often highly local to a broader circle, by disseminating information, e.g. by promoting understanding of the importance of avoiding incrossing and inbreeding and by maintaining a different approach to and understanding of biological diversity than the systems technical and productivity-oriented view of plants.
For those reasons financial support to NGOs should be directed much more towards local and regional information; conditions that projects should always cross country borders are irrelevant in the context of biological diversity because it is much more the result of localising than of globalising. Some of the most obvious approaches will be linked to small regions within a single Member State.

© Center for Bio-diversitet. Denmark

latest update January 2004.

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Center for Bio-diversitet is an independent NGO/CSO information-center. We aim to promote biological diversity and the protection and conservation of old and new varieties with valuable characteristics.

Editor: Heine Refsing