U.S. Fish and Wildlife Service
Division of Conservation Planning
Attention: Farming EA
BHW Federal Building, Room 530
1 Federal Drive
Ft. Snelling, MN 55111
RE: ENVIRONMENTAL ASSESSMENT: USE OF ROW CROP FARMING AND GENETICALLY-MODIFIED, GLYPHOSATE TOLERANT CORN AND SOYBEANS ON NATIONAL WILDLIFE REFUGES AND WETLAND MANAGEMENT DISTRICTS
February 14, 2011
To whom it may concern:
The Organic Trade Association (OTA) thanks the U.S. Fish and Wildlife Service (FWS) for this opportunity to comment on the Environmental Assessment (EA) entitled, “Use of Row Crop Farming and Genetically-modified, Glyphosate-tolerant Corn and Soybeans on National Wildlife Refuges and Wetland Management Districts.”
OTA is the membership-based business association for organic agriculture and products in North America. Its members include growers, shippers, processors, certifiers, farmers’ associations, distributors, importers, exporters, consultants, retailers and others. OTA’s Board of Directors is democratically elected by its members, and its mission is to promote and protect the growth of organic trade to benefit the environment, farmers, the public and the economy (http://www.ota.com/).
Ecological impact and FWS goals
The EA states, “The Service’s policy is to manage Refuge System lands using the most natural means available that will achieve the purposes and wildlife objectives for the refuge or wetland management district.”
The planting of genetically-modified glyphosate-tolerant (GMGT) crops on refuge land is not supported by the Service’s stated objective, since GMGT crops are by definition artificial organisms that cannot exist through natural means. GMGT crops are patented, novel organisms that contain genes from species that could never cross-pollinate using natural reproduction, as evidenced by the Service’s definition:
“Contains a gene or genes that have been artificially inserted instead of the plant acquiring the gene or genes through pollination. The inserted gene or genes may come from an unrelated plant or from a completely different species.”
The EA states that “the Service will adhere to biological integrity, diversity and environmental health of the Refuge System.”
The planting of GMGT crops, however, compromises biological integrity; reduces biological diversity; and endangers environmental health, as evidenced by statements made in the EA and demonstrated through additional research.
The EA acknowledges that the use of GMGT crops accelerates the development of glyphosate-resistant weeds, by stating, “Almost 90 percent of all herbicide-tolerant crops are glyphosate-tolerant. The use of glyphosate is being threatened by the evolution of glyphosate-resistant weeds (Duke and Powles 2008). Currently, more than 90 percent of the soybeans and 80 percent of the corn planted in North America is glyphosate tolerant. Regular, widespread use of the same herbicide increases the risk of developing herbicide resistance.”
Further, the EA states, “In practice, GMGT corn and soybeans are so widely used on a regular basis, that their use actually encourages herbicide resistance (Duke and Powles 2008).”
The “Preferred Alternative” places no restrictions on the planting of GMGT crops on refuge lands or strategies to avoid the development and establishment of glyphosate-resistant weeds, which threaten the biological and genetic integrity of plant communities, becoming invasive plants on refuge lands. Instead of noting the most prominent (and profitable) alternative, organic agriculture, the EA states, “Effective use of Integrated Pest Management (http://www.fws.gov/contaminants/Documents/IPMfinal.pdf) will help manage herbicide resistance.”
The EA contains no analysis of the quantity of herbicides likely to be applied to refuge lands under the various alternatives. Nationally, the use of herbicides has increased dramatically since the introduction of GMGT crops, (1) yet that trend is not discussed in the EA, nor is the environmental impact assessed.
The EA acknowledges that, “Some research indicates that there are commercial formulations of glyphosate that can negatively impact amphibians (Dinehart et al. 2010) and aquatic communities in general (Relyea 2005, Vera et al. 2010).” Yet the ecological significance of this is given very short shrift.
Instead of including an analysis of the quantities of herbicides used or likely to be used when GMGT crops are planted on refuge lands, or an analysis of the herbicide’s likely impacts on aquatic organisms, the concerns are dismissed by the EA’s assertion, “Using herbicides will not impact threatened or endangered plants if: 1. Herbicides are applied following pesticide label instructions.” This would depend on the proximity of the application to threatened or endangered plants—and in speaking only of threatened or endangered plants, is tellingly silent regarding any effects on the broader ecology, including amphibians and aquatic communities in general.
Don Huber, recently retired from Purdue University, and co-author G.S. Johal, at Purdue’s Dept. of Botany and Plant Pathology, stated in a paper published in the October 2009 issue of European Journal of Agronomy that the widespread use of glyphosate in the United States can “significantly increase the severity of various plants diseases, impair plant defense to pathogens and diseases, and immobilize soil and plant nutrients rendering them unavailable for plant use.” (2)
Avoidable problems associated with glyphosate
The only reason to plant glyphosate-resistant plants is to be able to use glyphosate, a questionable goal for FWS. There is no need to incorporate an ecologically questionable agricultural practice, such as the use of glyphosate, when the alternative of organic agriculture is both more consistent with FWS goals and would be more profitable for in-holder farmers.
The EA has no discussion of the negative impacts of glyphosate on pathogens, plant diseases, nutrient uptake, or soil organisms. Glyphosate is acutely toxic to humans, showing a wide spectrum of chronic toxicity; it may be persistent over a year; it can drift to unwanted areas; and contrary to the goals of an ecologically friendly agriculture, it kills beneficial insects, harms earthworms, reduces nitrogen fixation, and can increase the spread and severity of plant diseases.
Research shows that “Some soil invertebrates including springtails, mites and isopods are also adversely affected by glyphosate. Of nine herbicides tested for their toxicity to soil microorganisms, glyphosate was found to be the second most toxic to a range of bacteria, fungi, actinomycetes and yeasts.” (3)
Even more disturbingly, glyphosate has been shown to be toxic to human placental cells (4) and teratogenic. (5)
Organic Agriculture an alternative for Wildlife Refuge land
The FWS is responsible for protecting and maintaining the ecological balance and biological integrity of all species found on refuge lands, including amphibians, arthropods, bacteria, fungi, and other species negatively impacted by glyphosate.
The EA states, “We do not allow Refuge System uses or management practices that result in the maintenance of non-native plant communities unless we determine there is no feasible alternative for accomplishing refuge purposes(s).” The EA further states, “We do not use genetically modified organisms in refuge management unless we determine their use is essential to accomplishing refuge purpose(s).” However, nothing in the EA indicates that the planting of GMGT crops on refuge land is “essential to accomplishing refuge purposes.”
The EA does not consider any feasible and fully compatible alternative such as organic farming. As acknowledged in the discussion of organic soybeans in the EA, organic crops must be managed in accordance with the Organic Foods Production Act of 1990 to “respond to site-specific conditions by integrating cultural, biological, and mechanical practices that foster cycling of resources, promote ecological balance, and conserve biodiversity.”
The objectives of organic production, as defined in 7 CFR Part 205 National Organic Program Final Rule, require that organic production systems foster cycling of resources, promote ecological balance, conserve biodiversity, protect soil and water resources, and prevent soil erosion. Organic systems have been found to enhance biological diversity at all levels, from soil organisms to birds and mammals. Markets are strong for organic products, and their use on refuges would be fully consistent with FWS’s objectives.
The EA does state, “Under Alternative A, the use of GMGT corn on Refuge System lands has the potential to negatively affect organic farmers who have fields within 660 feet. Typically, organic farmers are responsible for providing their own buffers to ensure that they meet organic farming standards. If Refuge or District Managers are made aware of adjacent Certified Organic farm acres for corn, they may take measures to address neighboring landowner concerns and assist in providing required buffers.”
If GMGT crops are to continue to be planted on refuges, the FWS, the operator, and the biotech company, which owns the proprietary DNA, must take full responsibility for all harm caused by the plantings, both to the environment and to any organic farming operations.
If, on the other hand, organic agriculture is used, the mission and goals of FWS are much more easily met, while providing in-holder farmers with a more profitable agricultural practice.
1 Impacts of Genetically Engineered Crops on Pesticide Use: The First Thirteen Years. http://www.organic-center.org/science.pest.php?action=view&report_id=159
2 Scientists Reveal Glyphosate Poisons Crops and Soil. http://www.i-sis.org.uk/glyphosatePoisonsCrops.php
3 Glyphosate fact sheet. http://www.pan-uk.org/pestnews/Actives/glyphosa.htm
4 Sophie Richard, Safa Moslemi, Herbert Sipahutar, Nora Benachour, and Gilles-Eric Seralini, Differential Effects of Glyphosate and Roundup on Human Placental Cells and Aromatase Environ Health Perspect. 2005 June; 113(6): 716–720. Published online 2005 February 25. doi: 10.1289/ehp.7728.
5 Paganelli, A., Gnazzo, V., Acosta, H., López, S.L., Carrasco, A.E. 2010. Glyphosate-based herbicides produce teratogenic effects on vertebrates by impairing retinoic acid signalling. Chem. Res. Toxicol., August 9. http://pubs.acs.org/doi/abs/10.1021/tx1001749.