In the worst kept news since the disclosure that Israel keeps an arsenal of nuclear weapons, the Environmental Protection Agency (EPA) announced this week its widely expected approval of Enlist Duo™, the latest class of herbicide designed for use with herbicide-resistant corn and soybeans.
Following approval last month from the Department of Agriculture (USDA) for the matching resistant transgenic crops, the door is open for the package of seeds and herbicide to be marketed for the upcoming production season as the Enlist Weed Control System. Herbicide and seed are designed to work with one another. They are both manufactured by the same company, Dow AgroSciences. Predictably, the company’s president is jubilant: “Our company is uniquely positioned to answer the need for new, innovative weed control technology.”
Reads like a standard business story: new product for a big market. But the actual news is that this technological approach to weed control only makes the problem it intends to address worse, and the herbicide and seed industry appear not to get it. They can only think of more of the same in response. Imagine trying to return a vacuum cleaner that blows rather than sucks dust, only to be offered a newer model of vacuum that blows rather than sucks dust. The obtuseness and myopia illustrate the piquant insight of Upton Sinclair’s observation that “It is difficult to get a man to understand something, when his salary depends upon his not understanding it.”
But it isn’t merely funny or ironic. There is a major crisis in farm country of runaway, uncontrollable and economically-damaging weeds that would not exist if herbicide-resistant approaches had not been introduced. The threat to farming is such that the National Academy of Sciences and the Weed Science Society have called special summits to explore alternatives, and the USDA (yes, the same agency that approves the use of these crops) has funded a project to investigate how to persuade farmers and the industry that there is a broader and more effective spectrum of weed control strategies than herbicide resistance.
But here is the real question: how long will we continue to abide a regulatory system that is intended to protect the public interest, yet perpetually bends to the interests of industry at the expense of that public interest, and in the face of established science?
In this case, the public interest is a healthful food supply that protects natural resources and does not foul the environment (and do not overlook that the public is not asking corn/soy farmers for favors in this respect. The public directly guarantees the income of corn/soy farmers and covers their risk through an intricate gold-plated system of federal subsidies.) And this is the science on weed control with herbicides: weeds are living and adaptable organisms. Exposing them consistently to intensive applications of the same herbicide is exactly how you would generate resistance if that is what you intended to do.
Therefore, every college agricultural curriculum teaches how to avoid consistent over-utilization of herbicides, on the rationale that this both extends the lifetime of valuable herbicides, and assures their effectiveness when they are needed as a tool of last resort. The protocol, known as Integrated Pest Management (IPM), is a standard and conventional part of agricultural production curricula. As someone who taught this to beginning agronomy students for 26 years at Iowa State University (a paragon of four-square agricultural orthodoxy), I can attest to this from personal experience.
The strategy consists of acknowledgment that a farm field is a living, dynamic biological system. Insects, weeds and disease-causing agents will always be present, and their presence alone does not require control measures, because there are natural countervailing forces that usually keep any of those potential pests in check. The key to successful IPM is to monitor the levels of potential problems, and act only when economically important thresholds are surpassed. The response should be diverse, combining cultural and biological methods such as crop rotation, cover crops, and the protection and use of beneficial insects.
It is only when this succession of steps fails and (for example) a weed infestation runs away, that an herbicide should be applied. Doing this guarantees that levels of the herbicide in the environment are low and that the herbicide is effective when it is needed. Farmers who practice IPM know their fields and their crops, spend less on purchased inputs, have higher quality soil and water, and a greater share of their returns are to their management, less to capital investment. In other words, they don’t buy as many inputs.
To hear Dow’s business case for schemes of designer-made herbicides and resistant crops, they enable “the company to bring to the market this necessary, innovative technology that is expected to deliver significant growth for Dow while at the same time addressing a critical global challenge.” As we’ve seen, the “need” to which Dow refers is about selling more inputs, not actually for controlling weeds. The “global challenge” that Dow insinuates is not actually evolved herbicide resistance, which you don’t address with more of the same. The accurate diagnosis of this problem is that it results from the improper use of herbicides in a way that perpetuates, accelerates and aggravates the problem that the technology ostensibly addresses. And (let us not overlook)… assures a permanent market.
Of course it is in the interest of every corporation to sell as much of their product as possible and to expand markets. But the public and our government should not abet that effort. Common sense, scientific analysis and responsible public policies should protect farmers and the public from patently cynical business schemes.
What specifically are the scientific alternatives? A weed is a plant that has opportunities to grow in a friendly space that exists within a cropping system. Ecologists refer to that space as a “niche.” Applying ecology to agriculture is the science of agroecology. The highest form of this knowledge applied to weed control reveals that the most effective strategy is to prevent the weed from expressing in the first place. In other words, you farm in such a way that you favor crop growth and do not provide niches for weeds to express. This saves costs, enhances productivity and increases profits to farmers, but not to industry. That is the ultimate dynamic at play in this scenario.
At the Union of Concerned Scientists, we advocate for scientifically sound, agroecologically managed farms and agricultural landscapes for all the benefits outlined here. However, the question must be asked: “if industry has no incentive to develop agroecological knowledge and methods, then how will that knowledge be generated, imparted to farmers and implemented on farms?”
This nation has invested in a system that is the answer to that question. The nation’s network of public state colleges of agriculture, the “Land Grant System,” exists to perform research, teaching and continuing education in the public interest. Yet, due to chasing dollars, the research agenda for this national jewel has been increasingly influenced by private sector interests at the expense of those in the public interest. For this reason, we have joined with nearly 300 prominent agricultural scientists in demanding that the USDA provide more and adequate research funding to develop the agroecological knowledge and practices that will be the foundation for the future of agriculture.
Public investment in scientific research and outreach is what made this nation’s agricultural system great to begin with, and it is appropriate to apply that strategy to our current and future needs. But the agencies responsible for scrutinizing and approving transgenic technologies also need to be more responsible to the science and to the public. This is not an argument against biotechnology, but for competent understanding and assessment of both the agriculture we want and the technologies enabling it.
The storyline here is very clear: In the 1990s, when then Monsanto CEO Robert Shapiro made the case for staking the future of the company on biotech, his argument was that the company needed to move from “dirty chemical” products (which were costing the company due to defending against litigation) and into the new era of “green products.” The idea was that in the agriculture of the future, seeds would be the biological vehicles for improved traits, such as pest resistance, drought resistance, nitrogen fixation and better product composition. No external chemicals needed. The cash cow that would cover the research and development necessary for the transition from dirty to green would be the company’s successful RoundUp herbicide. Instead, the model that actually emerged was for transforming seeds so that they created a larger and perpetual market for that very herbicide.
To track what is actually going on in this elaborate shell game, enter science once again: “Widespread use of herbicide-tolerant crops—with their associated potent herbicides—will exert significant pressure on additional populations of weeds to develop resistance to the herbicides.” So forecast the Biotechnology Working Group in 1990, years before introduction of the first biotech crops, and a full two decades before today’s crisis of herbicide resistant crops. In fact, the point was so scientifically obvious that Dr. Robert Fraley, the molecular biologist in charge of developing the technology for Monsanto, said to Fortune magazine in 1997 that “his worst nightmare is that pests thwarted by Monsanto’s scientists will eventually adapt and create an untamed new menace.”
Well, Dr. Fraley’s worst nightmare has come true, but sadly is not a nightmare for him alone, but for all of us. Application of the existing science could have prevented it. Yet the industry pretends, dragging all of production agriculture with it, that all is fine, and that none of us see or understand the big picture.
Scandalously, public agencies are happy to collude. EPA intentionally set the lowest threshold possible to find the new herbicide non-toxic. One of the components of Enlist Duo is 2,4-D, an old herbicide targeting broadleaves that is responsible, as it is, for more crop damage due to drift than any other herbicide. USDA itself estimates that by 2020 the new technology will result in an increase of annual 2,4-D use from 26 million pounds (in 2002) to 176 million pounds. Therefore, it is reasonable to expect greater crop damage due to spray drift. That the regulatory agencies were blithely proceeding with approval of these products in the face of these facts prompted 50 members of Congress this summer to appeal for more rigorous and objective risk assessment of all tradeoffs involved, a plea that went unanswered.
The agencies understand the fragile nature of their decisions, illustrated by the USDA news release this week coupled with that of EPA. In it, the Agriculture Secretary announces “several of the steps [USDA] is taking to help farmers manage their herbicide resistant weed problems in a more holistic and sustainable way.” The fact that none of those steps describes new initiatives, and that the list is merely a collection of existing programs with a mission to address pest management generally, makes transparently clear the window dressing.
So if the EPA and USDA are not prioritizing the public interest, nor acting upon the comprehensive science on weed control, just whose interests are they serving?