May 27, 2016
While the issue of GMO (genetically modified organism) labeling is certainly an important one, there are many other concerns with genetically engineered (GE) crops and food of importance to the sustainable agriculture movement, and that are often at risk of being overshadowed by the labeling debate. A prime example of this are questions regarding the economic, environmental, and social impacts of GE crops and food.
This disparity was front and center following a recent report (“the NAS report”) by the National Academies of Science, Engineering, and Medicine (NAS). The public conversations around this report centered primarily around whether or not GMOs are safe to eat and should be labeled. While the National Sustainable Agriculture Coalition (NSAC) strongly supports a national, mandatory, on-package labeling requirement for GMO/GE foods or foods containing GMO/GE ingredients, we also believe that the other findings of the NAS report – particularly those addressing the economic, environmental, and social concerns around the production of GE crops – deserve more recognition and analysis.
The NAS report calls into question many of the assumptions about GE crop yields and herbicide use, and highlights the need for additional research and support for public plant breeding, as well as for an improved, more transparent regulatory process. We believe that these issues are deserving of greater attention, and we continue to advocate for federal policies that support greater investment in public plant breeding and a more robust and participatory regulatory oversight system. Below we explore some of the key findings of the report as they relate to family farms, sustainable agriculture, and rural communities:
Environmental and Agronomic Impacts
Many farmers and consumers are opposed to the production of GE crops due to the adverse environmental impacts of the crop technology package – namely, the use of herbicides and pesticides – on the environment. According to the NAS report, “if GE crops are to be used sustainably, [then] regulations and incentives must be provided to farmers so that more integrated and sustainable pest management approaches become economically feasible.”
Overall, the NAS report:
Found no evidence of cause-and-effect relationships between GE crops and environmental problems. However, the complex nature of assessing long term environmental changes often made it difficult to reach definitive conclusion [emphasis added]. That is illustrated by the case of the decline in monarch butterfly populations. Detailed studies of monarch dynamics carried out as of 2015 did not demonstrate an adverse effect related to the increased glyphosate use, but there was still no consensus among researchers that the effects of glyphosate on milkweed has not caused decreased monarch populations.
The report also went on to suggest that while there is potential for emerging GE technologies to have a place in a sustainable food system, “broad and rigorous analyses will be necessary to determine the long-term health, environmental, social, and economic outcomes of adding specific crops and traits to an ecosystem.”
NSAC strongly supports such objective analyses that considers independent, scientific peer reviewed literature and empirical evidence of social, health, and environmental impacts, and urges that all resulting information be made available to decision-makers, farmers, and the general public.
GE crops are often touted by proponents of the technology as being higher-yielding than their non-GE counterparts (and hence key to improved world food security), but – as the NAS report found – this assumption is not supported by the data.
The nationwide data on maize, cotton, or soybean in the United States do not show a significant signature of [GE] technology on the rate of yield increase . . . . There is a need for improved survey and experimental approaches that disentangle the effects of the GE trait itself from other factors that affect yield, [and] given the uncertainty about how much emerging [GE] technologies will increase crop production, viewing such technologies as major contributors to feeding the world must be accompanied by careful caveats [emphasis added].
Many GE proponents also suggest that GE crop production leads to a reduction in herbicide use, but this assertion can be misleading. The NAS report points out that, “the use of [herbicide resistant] crops is sometimes initially correlated with decreases in total amount of herbicide applied per hectare per crop per year, but the decreases have not generally been sustained.” Moreover, the report found that “such simple determination of whether total kilograms of herbicide used per hectare per year has gone up or down is not useful for assessing changes in human or environmental risks,” and recommends that “[r]esearchers should be discouraged from publishing data that simply compares total kilograms of herbicide used per hectare per year because such data can mislead readers.”
The widespread use of GE crops has led to an epidemic of herbicide resistant weeds, particularly those resistant to glyphosate. The rise of so-called “super weeds” can lead to a negative spiral in management practices, with increasingly more toxic herbicides applied in greater and greater quantities to combat the resistant weeds. NSAC strongly supports the NAS report’s conclusion that multi-faceted, integrated weed-management approaches – and not simply a reliance on more or stacked herbicide use – are needed to avoid the development of herbicide resistant weeds. But, as the report notes, in order to expand awareness and use of these integrated management techniques, effective education and extension programs, as well as incentives for farmers, are needed.
Social and Economic Impacts
Many farmers and consumers choose not to grow or purchase GE crops and foods because of the social and economic implications associated with the technology. The NAS report acknowledges these concerns and the need to further explore the socioeconomic impacts of GE crop production in order to properly assess its risks and rewards.
Public Plant Breeding
For years GE technology has been framed as the savior of family farmers and global hunger; the mantra being that technological advances in crops will help farmers overcome trouble with disease, pests, and even inclement weather. However, as the NAS report cautions, GE crops are not a silver bullet solution to the many, and often unpredictable perils of farming:
Investments in GE crop R&D may be just one potential strategy to solve agricultural-production and food-security problems because yield can be enhanced and stabilized by improving germplasm, environmental conditions, management practices, and socioeconomic and physical infrastructure. Policy-makers should determine the most cost-effective ways to distribute resources among those categories to improve production [emphasis added].
NSAC strongly supports a more comprehensive approach to improving our food security, particularly through the advancement of public plant breeding. According to the NAS report, farmers who choose not to use GE crops have fewer options today (for non-GE varietals) than they did before their introduction. This is coupled with the fact that our nation’s public investment in public sector breeding programs (i.e. government or university funded research, the results of which are publicly available) has been steadily declining for years. Over the past 20 years we have lost over a third of our country’s public plant breeding programs. The slow atrophy of public funding for this research leaves farmers with fewer and fewer seed choices, making them ill-prepared to adapt to a rapidly changing climate.
According to the report, “[b]alanced public investment in emerging [GE] technologies and in a variety of other approaches should be made because it will be critical for decreasing the risk of global and local food shortages.”
GE crop production is a significant component in the industrialization and consolidation of agricultural production systems; developments which often force family farms out of business and price beginning farmers out of the market for new working lands. As the economic base of small and medium family farms is eroded, rural communities suffer:
[I]ndustrial agriculture adversely affects the quality of life in rural communities . . . although the causual mechanisms that drive such outcomes remain under debate…[T]he implication of [this general] thesis is that if the adoption of particular technologies contributes to further industrialization of the farming sector, with increased consolidation and decreasing family farms, there will probably be deleterious consequences for rural communities [emphasis added].
In general, the NAS report recommends that additional research be conducted, which pays attention to changes at the community and household level in order to draw more conclusions about the impacts of GE crops in particular on rural communities. NSAC supports the undertaking of such research, given the prominent role that GE crop production has played in industrializing our agricultural systems.
Intellectual Property and Seed Market Concentration
Additional concerns about GE crops are based in objections to the control of crop germplasm through utility patents on intellectual property. These patents negatively impact competitive prices for farmers through market concentration, restrict independent researchers’ access to seeds and related inputs.
The NAS report concludes that there is not yet scientific consensus as to whether patents generally facilitate or hinder knowledge sharing and innovation, nor specifically whether utility patents on GE crop germplasm are used to block crop research. NSAC strongly opposes the granting of utility patents for seed or crop varieties, whether developed through GE or other breeding methods, but supports NAS’ recommendation that additional research be done to determine the effect of GE patents on seed markets, as well as how these effects in turn impact farmers.
This issue is one that the Obama Administration took up in 2010, as representatives from the Department of Justice and USDA held public meetings across the country to hear concerns about anti-competitive practices in various sectors of the agricultural economy. The very first of these meetings focused on seed market concentration, yet nothing substantive came of these groundbreaking inquiries. We would encourage the next administration to return to an exploration of this issue, and to translate farmer concerns into actions and policies that support a diverse food and farm economy.
There is far more to an analysis of the impact of GE crop production than just the science and social implications; there are also complex regulatory and legal dimensions that must be explored.
The report recognizes this reality, and includes a series of astute observations and recommendations regarding the importance of transparency and public participation in the regulatory process. We have included several of them below:
In addition to issue of product safety, socioeconomic issues that go beyond product safety are technology-governance issues that should be addressed by policy-makers, the private sector, and the public in a way that considers competing interests of various stakeholders and inherent tradeoffs.
Transparency and public participation have been shown by research to be critically important for appropriate, sound, and credible governance of all aspects of the development, deployment, and use of GE crops [emphasis added].
Regulating authorities should be particularly proactive in communicating information to the public about how emerging [GE] technologies . . . or their products might be regulated and about how new regulatory methodologies . . . might be used. They should also be proactive in seeking input from the public on these issues [emphasis added].
In deciding what information to include from public disclosure as confidential business information or on other legal grounds, regulating authorities should bear in mind the importance of transparency, access to information, and public participation and ensure that exemptions are as narrow as possible.
The Report also makes several substantive recommendations regarding the need for ongoing monitoring and evaluation of GE crops:
Regulatory agencies responsible for environmental risk should have the authority to impose continuing requirements and require environmental monitoring for unexpected effects after a GE crop has been approved for commercial release.
In determining whether a new plant variety should be subject to a premarket government approval for health and environmental safety, regulators should focus on the extent to which the characteristics of the plant variety (both intended and unintended) are likely to pose a risk to health or the environment on the basis of the novelty of traits, the extent of uncertainty regarding the severity of potential harm, and the potential for exposure regardless of the process by which the novel plant variety was bred.
We are pleased to see NAS make these recommendations, which reflect many of our own recommendations and policy positions on GE crops and livestock. NSAC has long advocated for a more transparent and rigorous regulatory oversight system for GE crops; one that includes regulating agencies’ authority to impose restrictions on experimental or commercial cultivation of GE crops and production of other agricultural inputs to prevent harm to the general public, non-GE farmers, and the environment. We also support a regulatory process that is transparent and informed by independent science, while considering social, economic, and environmental factors, with data on the safety and efficacy of GE crop technologies available to the public at all critical decision-making stages, and including meaningful opportunities for public input.
As USDA considers new rules governing the regulation of GE crops, we hope they are considering the recommendations posed by the NAS report. NSAC will continue to provide input to the regulating agencies and information to the public throughout the process.