With little fanfare, last summer the U.S. Fish & Wildlife Service announced it would formally ban the use of seeds treated with neonicotinoid pesticides, (a newer, safer generation of seed treatments to protect against pests) and the use of crops improved through biotechnology throughout the fish and wildlife refuge system.
It is worth quoting at some length the announcement, which came via a memo from the Chief of the National Wildlife Refuge System:
The Leadership Team agreed that by January 2016, the System will only use an agricultural practice where it specifically contributes to wildlife objectives. This conforms to 601 FW 3, the Service’s Biological Integrity, Diversity and Environmental Health policy (BIDEH). BIDEH directs us to maintain and restore the biological integrity, diversity, and environmental health of refuges and is based on the underlying principle of wildlife conservation that favors management that restores or mimics natural ecosystem processes or functions to achieve refuge purpose(s).
By January 2016, we will no longer use neonicotinoid pesticides in agricultural practices used in the System. Service policy 569 FW 1 Pest Management directs that we use long-standing integrated pest management principles to guide and evaluate our pesticide use practices. We have determined that prophylactic use, such as a seed treatment, of the neonicotinoid pesticides that can distribute systemically in a plant and can potentially affect a broad spectrum of nontarget species is not consistent with Service policy. We make this decision based on a precautionary approach to our wildlife management practices and not on agricultural practices.
There can be appropriate and specialized uses of neonicotinoid pesticides and decisions for those uses in the Service are subject to review through all applicable laws, regulations, and policies including, but not limited to, the National Environmental Policy Act.
By January 2016, we will phase out the use of genetically modified crops to feed wildlife. Service policy 601 FW 3.15 C states: “We do not use genetically modified organisms in refuge management unless we determine their use is essential to accomplishing refuge purpose(s) and the Regional Chief, National Wildlife Refuge System, approves the use.” Refuges throughout the country successfully meet wildlife management objectives without the use of genetically modified crops. We have demonstrated our ability to successfully accomplish refuge purposes over the past two years without using genetically modified crops, therefore, it is no longer possible to say that their use is essential to meet wildlife management objectives. We will no longer use genetically modified crops to meet wildlife management objectives system-wide.
Leaving aside the astounding nature of this statement, (implying that wild animals shouldn’t be eating GMO crops), there are a number of simply false assumptions embedded in this statement, which raises additional policy and legal issues. But first some logic, and some science.
It must be noted that the primary purpose of the National Refuge System is not agriculture.
The Mission of the National Wildlife Refuge System is to administer a national network of lands and waters for the conservation, management, and where appropriate, restoration of the fish, wildlife, and plant resources and their habitats within the United States for the benefit of present and future generations of Americans.
The Fish & Wildlife Service website further explains “We are land stewards, guided by Aldo Leopold’s teachings that land is a community of life and that love and respect for the land is an extension of ethics. We seek to reflect that land ethic in our stewardship and to instill it in others.”
Established in 1903 through one of Teddy Roosevelt’s far-sighted initiatives, the refuge system today embraces 598 protected areas (refuges & wetland management districts) covering 150 million acres providing
…habitat for more than 700 species of birds, 220 species of mammals, 250 reptile and amphibian species and more than 1,000 species of fish. More than 380 threatened or endangered plants or animals are protected on wildlife refuges. Each year, millions of migrating birds use refuges as stepping stones while they fly thousands of miles between their summer and winter homes. National wildlife refuges host more than 47 million visitors each year, generating $1.7 billion and creating about 27,000 jobs in local economies.
These are noble objectives and praiseworthy accomplishments. But even if the habitats could be restored to a “natural” state (the definition of which could be argued for eternity) they would not produce enough feed to sustain the concentrated populations that depend on the refuge system, hence the language “where appropriate”. To optimize the preservation of wild habitat, therefore, it is important that areas allocated to agricultural production be productive. To do less than that would risk crushing wild habitat under significant population pressure.
The logic is clear. The optimal methods of agricultural production on refuge lands dedicated to that purpose are those that produce the maximum sustainable yields with the minimum environmental impact. Obsolete production methods, no matter how innovative they might have been thousands of years in the past, are not, today, “green” in any sense. They produce vastly less than modern techniques, requiring much more land to produce the same harvest, thus impacting far more habitat than modern varieties. The superiority of modern crop varieties (e.g., genetically modified organisms or GMOs) in this regard has been demonstrated time and time again. The prohibition of “genetically modified” crops is a wrong-headed and anti-environmental policy, and the irony that it is being advanced out of respect for a “land ethic” is indefensible.
What were they thinking? It is not clear – the decision making process has been anything but transparent, falling far short of the notice and comment rulemaking process required for major federal actions, but it appears they have swallowed the notion that “genetically modified” crops are somehow unnatural (as if there were a form of agriculture that isn’t) and should therefore be shunned. This is worse than it seems. For more than a decade, the Fish and Wildlife Service has been fumbling towards a policy on “biotechnology” making no apparent progress beyond identifying it as one of “…four key challenges facing the Service in the context of large-scale landscape change.” They now appear to have settled on a ban as the appropriate way to address this so-called challenge, without ever having defined precisely what the challenge actually is, nor even, apparently, defining the “genetically modified organisms” they have decided to ban.
In the absence of a FWS definition of ”GMO”, we will assume they take it to mean what it does in common usage: “organisms (i.e. plants, animals or microorganisms) in which the genetic material (DNA) has been altered in a way that does not occur naturally….” Those who know just a little biology have been unhappy with this definition from the beginning, with its focus on genetic modification as though it were something to be concerned about, rather than the bedrock on which all life on earth (or anywhere else) is grounded. But this concept of what is “natural” is more profoundly misguided. The fact is that in vitro (literally “in glass”, i.e., in the test-tube) genetic modification is brought about using techniques derived directly from those we find ubiquitous in nature. The enzymes scientists use are the same ones used by organisms in the wild, and the techniques for moving DNA from one organism to another are directly derived, if not indistinguishable from those we find operating in nature. In other words, the antipathy toward “genetically modified organisms” is based on the false conceit that there is any other kind, and rooted in a profound misunderstanding of, if not alienation from the natural world.
So the Fish and Wildlife Service’s approach to “GMO”s is rooted not only in profound misinformation, but an ideological frame that seeks to go backwards in time. As such it works against the very pro-environment mission it is charged to advance.
Moreover, while FWS might not admit it, part of their responsibility is to accomplish their mission in the most cost-efficient way. For whether they were experiencing flush or tight budgets, the more efficient they are, the more resources they can devote to accomplishing their true mission: managing these critical lands. But in their ideological drive for recreating a pre-industrial, faux-natural world they seem to think that cost is no object. In other words, by banning GMOs they are saying that they are willing to spend more of limited taxpayer dollars than they need to, for no environmental gain. While yuppie consumers might be able to afford organic foods at Whole Foods, certainly deer, chipmunks, and birds can do with the food the rest of us eat (e.g., lower cost GMO-based foods).
What about the ban on neonicotinoids? Sadly, no better. First, what is a “neonicotinoid”? Wikipedia gets it right:
Neonicotinoids are a class of neuro-active insecticides chemically similar to nicotine. The development of this class of insecticides began with work in the 1980s by Shell and the 1990s by Bayer. The neonicotinoids show reduced toxicity compared to previously used organophosphate and carbamate insecticides. Most neonicotinoids show much lower toxicity in birds and mammals than insects, but some breakdown products are toxic. The neonicotinoid imidacloprid is currently the most widely used insecticide in the world. The neonicotinoid family includes acetamiprid, clothianidin, imidacloprid, nitenpyram, nithiazine, thiacloprid and thiamethoxam.
Less toxic than organophosphates and carbamates – well, that certainly sounds like a plus. But Wikipedia goes on to say:
In the late 2000s some kinds of neonicotinoids began to come under increasing scrutiny over potential environmental impacts. The use of neonicotinoids was linked in a range of studies to a number of adverse ecological effects, including honey-bee colony collapse disorder (CCD) and loss of birds due to reduction in insect populations. Increased scrutiny eventually led to restrictions and bans on the use of different neonicotinoids in several countries.
We may be on to something here. If the FWS wants to grow crops for the purpose of attracting pests to sustain songbirds, then neonics may not be ideal. But if the purpose of growing a crop is to produce a harvest sufficient directly to nourish, for example, migratory waterfowl, then their use to optimize production of seeds treated with pesticides less toxic than their predecessors or alternatives would seem to be logical, praiseworthy, and essential good stewardship of the land. Unless, perhaps, they were toxic to some endangered species? But we know neonics are kinder to birds and vertebrates. But what about endangered insects?
As it happens, the argument has been made that neonics may be contributing to declines in some threatened native prairie butterfly populations in the Great Lakes region. This argument is made in a webinar featuring Lisa Williams, the Branch Chief for Environmental Contaminants in the East Lansing Field Office of the U.S. Fish and Wildlife Service. Dr. Williams sees a correlation between areas of neonic use and the habitat distribution and declining numbers over time of the Poweshiek Skipperling and the Dakota Skipper, both candidates for listing as endangered species.. She argues from this correlation that neonics should thus be banned from use on refuges.
As Williams herself admits, this is an argument from correlation, and no matter how much it may seem to be real, better data are needed to establish cause and effect. But even if we suppose such data exist, or are produced, they could not justify a system-wide ban. The National Wildlife Refuge system is vast, involving all fifty states and territories. The butterflies of interest, though once more widespread, are now limited to relictual prairie habitat in a small portion of the country, throughout the remainder of which very different conditions apply. A blanket neonic ban makes no sense. But what about honey bees? They are everywhere. How do neonics impact honeybees? This gets interesting.
We can eliminate “GMOs” as a concern immediately. They comprise the only category of seed that is routinely tested on honeybees (and other organisms) before commercialization to ensure no negative impacts, and they have consistently received a clean bill of health. (Don’t take my word for it – look it up).
But if one enters “honey bees, neonics, CCD” into any search engine the result will be tens of thousands of hits. Many claim GMOs and neonics are at the root of CCD, or colony collapse disorder, which threatens a “beepocalypse” that would devastate modern agriculture. But there are far more likely culprits, and more sober voices have looked at this closely and find the data just don’t support blaming neonics. CCD has been known since long before the advent of neonics, indeed since before the dawn of synthetic pesticides. And CCD is reported from places in countries where neonics have never been used, like alpine Switzerland, and entirely absent from regions where neonics are widespread, like western Canada and Australia. Indeed, after a dedicated study Australian regulators found neonics to reduce the risk to bees:
…the introduction of the neonicotinoids has led to an overall reduction in the risks to the agricultural environment from the application of insecticides. This view is also balanced with the advice that Australian honeybee populations are not in decline, despite the increased use of this group of insecticides in agriculture and horticulture since the mid-1990s.
Within only ten months of the precautionary ban on neonicotinoid pesticides, farmers in the UK are reporting significant crop losses for oilseed rape (OSR) due to an infestation of cabbage stem flea beetles ravaging the British countryside. With OSR crop losses this year estimated to between 20-50 percent, it is known that seeds treated with neonicotinoids (banned in the EU since December, 2013) would have efficiently controlled those predators.
European regulators have shown quite clearly what bad policy looks like (as they often do). Let us hope the U.S. Fish & Wildlife Service notices.
I first read Aldo Leopolds’ A Sand County Almanac when I was twelve. Nothing else I’ve ever read has had a more profound impact on my own world view and values, and Leopold’s notion of a “land ethic” is central. One of the things I admired most about his vision was his unflinching honesty in facing the facts. He did not allow himself to be seduced by a naïve pastoralism that would value ancient varieties simply because they were old, and I do not believe he would have advocated their use in systems where productivity is essential to the conservation and preservation about which he cared so deeply. If the FWS is sincere in its desire to apply Leopold’s land ethic to the management of the National Refuge System, they will reverse the blanket ban on neonics in favor of a case by case approach, and rescind entirely the prohibition on crops improved through biotechnology. Anything else would make a mockery of Leopold’s legacy.
This blog post appeared originally at innovationfiles.org.
Val Giddings is Senior Fellow at The Information and Technologies Innovation Center and President and CEO of PrometheusAB, Inc., which provides consulting services in regulatory compliance, media, and strategic planning to governments, multilateral organizations, and industry clients in the U.S. and around the world. He previously served for eight years as Vice President for Food & Agriculture of the Biotechnology Industry Organization (BIO). He also has served at the Congressional Office of Technology Assessment and as expert consultant to the United Nations Environment Programme, the World Bank, USDA, USAID, and numerous companies, organizations and governments around the world. E-Mail: email@example.com