Letter to National Academy of Sciences Regarding Biotech Crops

February 20, 2015

Dr. Fred Gould
The National Academies
Genetically Engineered Crops Study Committee
500 Fifth Street, NW
Washington, DC 20001

Re: A Science-Based Look at Genetically Engineered Crops

Dear Dr. Gould and Members of the Committee,

The undersigned organizations, each of which has a substantial interest in the development and commercialization of new plant varieties enhanced through modern biotechnology, appreciate this opportunity to comment on the National Academy of Sciences (NAS) study A Science-Based Look at Genetically Engineered Crops.

For two decades, the U.S. has been viewed as the global leader in ag biotech innovation. Our past success was attributable, in part, to a science-based regulatory system that facilitated the development of safe and beneficial products and encouraged investment in agricultural innovation.

This investment in agricultural innovation has allowed U.S. farmers and ranchers to provide the safe, affordable food supply we enjoy today. Ever since the first biotech crop was commercialized in 1995, U.S. farmers have adopted new biotech crops at an unprecedented rate. The reason for this unparalleled acceptance is straightforward: biotech crops have boosted agricultural productivity while simultaneously lessening agriculture's environmental footprint.

According to USDA's Economic Research Service (ERS)^[1], 93 percent of soybean acreage, 82 percent of cotton acreage, and 85 percent of corn acreage was planted to biotech varieties in the U.S. last year, because adoption of biotech crops has "saved farmer's time, reduced insecticide use, and enabled the use of less toxic herbicides."  Other studies of biotech cropshave shown "lower production costs, fewer pests, better yields, improved water quality,^[2] preserved topsoil, and reduced fuel and water use^[3]."

Last year the soy, corn and cotton crops produced by U.S. growers had a farm gate value of $110 billion. The production efficiencies and economic gains provided by biotech crops have not only preserved jobs, especially in rural America, they have also given U.S. growers a competitive advantage in an increasingly global marketplace.

In addition to their proven economic and environmental benefits, biotech crops have an impeccable record of safe use^[4]. During 30 years of research on biotech plants^[5] and 15 years of widespread production and global consumption, not a single instance of actual harm to human health, animals or the environment^[6] has ever been demonstrated. And yet, in spite of the history of safe use and many environmental benefits of biotech crops, litigation has prevented farmers from planting approved biotech crops and has significantly delayed regulatory approval of ag biotech products in the pipeline.

To date, the tone of the presentations to the NAS Committee has been predominantly negative. The large majority of the invited presentations at the September 15-16 public meeting were from well-known anti-biotech activists who described a litany of harms with few, if any, economic benefits to justify the high seed costs growers pay. It is clear by the widespread adoption of GE crops that our members find value in producing food derived from modern biotechnology. We suggest the committee reach out to more growers to present to the committee the reasons why they choose to utilize GE crops.

According to the 2010 National Research Council (NRC) report^[7], farmers who adopted biotech crops have benefitted not only from lower production costs and/or higher yields, due to more cost-effective weed and insect control, but also from safer working conditions. The report states that improvements in water quality may be the single greatest benefit of GE crops, due not only to decreases in overall insecticide use, but also a shift to insecticides and herbicides that do not linger in soil and waterways.  Finally, the report found that farmers who grow GE herbicide-resistant crops use tillage for weed control less often; when they do till the soil, they are more likely to practice conservation tillage.Both no-till and conservation tillage reduce soil erosion, the primary water pollution problem, and improve soil quality, which facilitates water filtration.

With respect to the safety of GE crops for human health, the American Medical Association states "Bioengineered foods have been consumed for close to 20 years and, during that time, no overt consequences on human health have been reported and/or substantiated in the peer-reviewed literature"^[8].This sterling safety record was anticipated by many scientific bodies around the world prior to commercialization of the first GE crop^[9].Scientific understanding of biology, food safety, and agricultural ecosystems predicted that these crops would be as safe as, or safer than, conventional crops.

Thirty years of lab research and field testing have validated those predictions^[10].The EU alone has spent over €300 million on independent lab and field research that was dedicated to assessing the environmental and food safety of GE crops.The research results, which were published in two comprehensive reports^[11], led the European Commission to state: "The main conclusion to be drawn from the efforts of more than 130 research projects, covering a period of more than 25 years of research, and involving more than 500 independent research groups, is that biotechnology, and in particular, GMOs, are no more risky than conventional plant breeding technologies."

Nearly 20 years of real world experience safely growing and consuming GE crops has confirmed the research findings. Today, GE crops are grown annually on over 400 million acres by more than 17 million farmers in 28 countries^[12], and foods derived from GE crops are consumed safely by people and animals all over the world^[13].All of these crops continue to be grown without health or environmental problems.

Several webinars focused on the problems of glyphosate-resistant weeds. The development of weed resistance is not a new phenomenon in agriculture. Farmers have been managing weed resistance with the adoption of new products that incorporate different modes of action for decades. In recent history, the decline in the availability of new modes of action, coupled with hard-learned lessons on the farm involving new production practices, has made weed resistance management a high priority issue for farmers across the country. Farmers are already engaged or rapidly engaging on the issue of weed resistance management. And, as a result, the sector has seen significant increases in farmers embracing weed resistance best management practices. Farmers care about weed resistance management because their livelihoods and the long-term viability of their operations depend upon it. Farmers already use a diverse array of herbicide products across the United States. One of the best tactics for minimizing problems with resistance is by having access to as many pest and weed controls as possible; this includes biotech crops.

Another issue that the committee has been exposed to is the issue of coexistence. For decades now, a hallmark of U.S. agriculture has been the ability of farmers to pursue diverse cropping systems and respond to consumer demand for high-value identity-preserved and specialty crops. The diversity and vitality of our industry would not be possible if not for the past success of coexistence.

Although much recent discussion on coexistence relates to the introduction of agriculture biotechnology, it is important to recognize that the presence of genetically engineered crops does not create risks that are novel in agriculture. The principles of coexistence and the need to manage risk and preserve the integrity of crops apply to all agriculture production, and are particularly important in any identity-preserved (IP) cropping system.

Producers who grow different crop varieties have managed to reduce pollen flow from one variety to another to make sure that blue corn stays blue, for example, or that popcorn pops. For decades, producers have cooperated with one another in considering which fields to use for different crops and varieties, coordinated planting to stagger dates of flowering and pollination, and used seed produced under quality-controlled conditions. Compromises are worked out between neighbors, without any need for government involvement. The National Organic Program addresses the issues related to pollen flow by directing organic growers to establish buffer zones and utilize other production practices to minimize any impacts from neighboring production practices.

Recently, the USDA's Advisory Committee on Biotechnology & 21^st Century Agriculture (AC21) heard presentations from diverse members of the agricultural industry—from several growers, both organic and conventional; the seed industry; the biotechnology industry; and data from a large organic canola processor—that demonstrated the diversity of risk mitigation tools that have evolved and improved over time and are currently being used successfully. They also heard of new initiatives from members of the organic and agriculture biotechnology industry that demonstrate continued development of new tools and approaches to managing economic risks as technology and markets evolve.

The parallels between coexistence practices for genetically engineered crops and other conventional or IP crops is particularly significant given that approved technologies have been thoroughly reviewed by scientific experts and regulators, and have been determined to be as safe for humans and the environment as conventional crops. Coexistence is not about health or safety; it is about finding ways to improve working relationships when different production systems are used in close proximity.

Because the U.S. regulatory framework is based on a scientific evaluation of safety and risk, the emergence of premium markets for crops that exclude the use of approved biotechnology as a method of production is purely market-driven. In fact, organic agriculture is one of the fastest growing consumer markets in U.S. agriculture and is increasingly viewed as a significant and vibrant sector within the agriculture economy. For example, Catherine Greene of USDA's Economic Research Service reported to AC21 that organic food sales have grown roughly 10 percent annually over the past decade—in addition to other non-biotech products marketed through private verification and labeling initiatives—and that organic farms exceed the national average for total farm sales and average farm profitability.

While strategies for coexistence have developed to allow farmers the freedom to choose the crop they want to grow and how they want to grow it, one fundamental principle has applied throughout the history of diverse cropping systems: the entity who derives value from a premium, differentiated crop accepts responsibility to implement the production practices necessary to preserve the value of that crop. In all examples of IP production, the additional costs of production and the costs associated with accepting additional risk are offset by higher prices. As in the rest of U.S. agriculture, the market sets prices and provides growers with the information needed to make sound cropping and business decisions.

One of the other misconceptions presented to the committee was the idea that growers do not have choice as to what seeds they could grow. First, growers are not forced to buy biotech seeds. As stated above, the market helps guide decisions relating to what seeds to grow and what cropping practices to employ. Many seed varieties, both biotech and non-biotech, are available to growers. If anything, the U.S. regulatory system is impeding access for growers to plant new varieties while regulatory systems in other exporting countries are facilitating access to new, safe and beneficial traits.

And while we appreciate the opportunity to provide input in the form of comments, the following points highlight the apparent bias in the NAS process since the first Sept. 10 meeting:

• Only 1 hour and 45 minutes was set aside to hear the perspectives of developers (Dec. 10 meeting), compared to nearly two days for opponents in September.
• Plant breeders and ag extension specialists (10/2 and 1/27 meetings) included so far do not represent the mainstream, do not use the technology in their breeding programs, and/or have agendas against the technology.
• Sociologists on the 2/4 panel are associated with skepticism about the benefits of adopting the technology. Groups with more real-world experience in the successful deployment of the technology in developing countries are not represented.
• To date, the committee has not heard from grower groups and others who have adopted, and benefit from, the technology.

If the committee is seeking to provide an "evidence-based report," it is important that it reach out to more farmers who actually utilize the technology in order to address some of the questions that have been presented from self-proclaimed anti-biotech activists. The report should be grounded in sound science and fact checked by inviting those with 'dirt under their finger nails' to address any additional questions the committee might have.

We appreciate the NAS and this committee for undertaking this very important report. We look forward to working with the committee and would be happy to provide any additional input requested.

Sincerely,

Agricultural Retailers Association
American Farm Bureau Federation
American Soybean Association
American Sugarbeet Growers Association
National Association of Wheat Growers
National Corn Growers Association
National Cotton Council
U.S. Soybean Export Council

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[1]Fernandez-Cornejo, J., et.al. 2014.Genetically engineered crops in the United States.http://www.ers.usda.gov/publications/err-economic-research report/err162.aspx#.Uw5mgPldXO4

[2]National Research Council. 2010. Impact of Genetically Engineered Crops on Farm Sustainability in the United States. http://www.nap.edu/openbook.php?record_id=12804

[3] Brookes and Barfoot. 2012. Global Impact of Biotech Crops: Environmental Effects, 1996-2010. GM Crops 3: 1-9. www.landesbioscience.com/journal/gmcrops; Brookes and Barfoot.2012. The income and production effects of biotech crops globally 1996-2010. GM Crops 3: 265 - 272. http://www.landesbioscience.com/journals/gmcrops/article/20097/

[4] American Medical Association Statement on the Safety of Bioengineered Foods. https://ssl3.ama assn.org/apps/ecomm/PolicyFinderForm.pl?site=www.ama-assn.org&uri=%2fresources%2fdoc%2fPolicyFinder%2fpolicyfiles%2fHnE%2fH-480.958.HTM

[5]EC-sponsored Research on Safety of Genetically Modified Organisms (2001) http://ec.europa.eu/research/quality-of-life/gmo; and A decade of EU-funded GMO research (2001-2010)http://ec.europa.eu/research/biosociety/pdf/a_decade_of_eu-funded_gmo_research.pdf

[6] "The US EPA's analysis of Bt crops finds that they pose no significant risk to the environment or to human health." From Are Bt crops Safe?by M. Mendelsohn, J. Kough, Z. Vaituzis & K. Matthews. Nature Biotechnology: vol. 21. Sept 2003.

[7] National Research Council.2010.Impact of Genetically Engineered Crops on Farm Sustainability in the United States.http://www.nap.edu/openbook.php?record_id=12804

[8] https://ssl3.ama-assn.org/apps/ecomm/PolicyFinderForm.pl?site=www.ama-assn.org&uri=%2fresources%2fdoc%2fPolicyFinder%2fpolicyfiles%2fHnE%2fH-480.958.HTM

[9] See, e.g.,Recombinant DNA Safety Considerations (OECD National Experts on Biotechnology, 1986); Introduction of Recombinant DNA-Engineered Organisms into the Environment: Key Issues (NAS, 1987); Field-Testing Engineered Organisms: Genetic and Ecological Issues (U.S. Office of Technology Assessment, 1988); Field Testing of Genetically Modified Organisms: Framework for Decisions (NAS, 1989); Biotechnologies and Food: Assuring the Safety of Foods Produced by Genetic Modification (International Food Biotechnology Council, 1990; published in the journal Regulatory Toxicology and Pharmacology, volume 12); Strategies for Assessing the Safety of Foods Produced by Biotechnology (FAO/WHO. 1990); Safety Evaluations of Food Derived from Modern Biotechnology: Concepts and Principles (OECD, 1993).

[10] See the GENERA database for a list of over 600 scientific, peer-reviewed articles. http://www.biofortified.org/genera/studies-for-genera/

[11]EC-sponsored Research on Safety of Genetically Modified Organisms (2001) http://ec.europa.eu/research/quality-of-life/gmo; and A decade of EU-funded GMO research (2001-2010)http://ec.europa.eu/research/biosociety/pdf/a_decade_of_eu-funded_gmo_research.pdf

[12] More than 4 billion people, or 60% of the world's population, live in the 28 countries where GE crops are grown.

[13] Contrary to a popular belief that the EU has banned GE crops, farmers in five EU countries grew GE crops in 2012.