1. Any decision to allow trials of genetically modified crops to take place on Church owned land is liable to have a profound effect on public perceptions of the Church. In the past the Church has often attracted criticism from environmentalists for teaching about human dominion without emphasising the need for good stewardship. In recent years a series of events and initiatives organised by the Board for Social Responsibility and Christian Ecology Link has helped to improve understanding within the Church. It would be most unfortunate and untimely for the Church now to give a public signal that it is willing to take the kind of environmental risks that other landowners evidently wish to avoid.

2. Too little information has so far been made public on the approach made by MAFF to lease church owned land in the York area. It is unclear how much land has been requested, whether the land is currently tenanted, what tests would be undertaken and for whom. Such information should not be kept secret but should be revealed as part of the process of public debate. Nor is it clear why MAFF has judged it necessary to approach a national public institution rather than smaller landowners. It is liable to be seen as an attempt by Government to use the Church to give greater authority to its current policy.

3. There has not been adequate consultation within the Church. Indeed Christian Ecology Link, Britain's leading church-based environmental organisation, with approximately 500 church and individual members, only became aware through the press of the prospect of Church owned land being used in this way. There was a fringe meeting at the recent Synod, but this was closed to non-members, there was very limited time for questions, and no collective opinion was established. Prior to any decision being taken it is important to consult theologians and social scientists as well as independent scientists.

4. The BSR briefing paper on Genetically Modified Organisms provides some interesting insights on the issue. However, it takes an uncritical approach to science and does not adequately address some important ethical and theological considerations. Christian Ecology Link has produced a comprehensive critique of the paper, which is attached. The description of the BSR briefing paper as 'The Church of England's View' on its web-site* is misleading, as the stance taken will be unacceptable to many Church members. (* http://www.cofe.anglican.org/view/environ.html)

5. The use of land for trials of genetically modified crops is to be treated as a potential investment by the Church. The decision should be determined by ethical criteria as much as by financial considerations. In any case, however, there is a concern that land upon which genetically modified crops have been grown will decline in value (as may land on neighbouring farms). Moreover, the issue of liability for possible legal claims in the event of unforeseen environmental or health problems remains unresolved.

6. More generally, the use of farm scale trials is premature and dangerous. Research should be done in a closed environment for the foreseeable future. The precautionary principle should be adopted, which puts the onus of proof on the scientists to show that their activities will not cause any harm.

7. The Church need to review its approach to alternative farming options. Last November Professor David Bellamy, speaking at a major conference on Christianity and the Environment held at Southwark Cathedral, shared a vision that all Church land would be farmed organically and that churches would become distribution centres for organic food. There are. of course, limits to the ability of Church Commissioners to impose any particular type of farming on its tenants. However, it is within their power to offer advice and support, and to make recommendations. It should also consider the need to introduce conditions to leases in relation to environmental concerns.

8. It is our belief that the Church Commissioners should not at the present time permit trials of genetically modified crops to be take place on Church owned land. This will allow for further laboratory research, adequate consultation within the Church, and additional public debate on this important issue.