Executive Summary

1. Enhance research efforts on ecological and socioeconomic effects of GMPP plants, and
   
   
2. Alter the current research trajectory to develop GMPP plants resistant to insect or virus damage rather than to the insects or viruses themselves.

Introduction

Thank you for the opportunity to offer comments to the Committee. We think it is critical to assess the scientific risks and benefits associated with genetically modified pest protected (GMPP) plants. The Henry A. Wallace Institute for Alternative Agriculture is a nonprofit, tax-exempt research and educational organization. Established in 1983, the Institute encourages and facilitates the adoption of resource-conserving, environmentally sound, and profitable farming systems. The Institute also seeks to foster the development of food systems that incorporate the interests of all participants, from farmers to consumers. It works closely with producer groups, public research and education institutions, government agencies, and other non-governmental organizations in promoting a sustainable agricultural system. The Institute's prime functions are to serve as a national clearinghouse in Washington, D.C., and develop and implement research and educational outreach programs. It publishes two peer-reviewed publication series: the quarterly American Journal of Alternative Agriculture, and periodic policy studies reports on key issues affecting agricultural and rural development. The Institute has a small professional staff who conduct the research and educational outreach programs. It is governed by a diverse Board of Directors of university and government scientists, commercial farmers, representatives from non-governmental organizations, and others. The Institute is supported by memberships; donations; grants from foundations, corporations, and individuals; and competitive research project awards.

Overview

In general, the Wallace Institute recognizes the current and potential benefits of GMPP plants and other genetically modified organisms (GMOs), provided that appropriate social goals guide the development, regulation, and adoption of such technologies. However, to this point the Wallace Institute believes that the amount of scientific inquiry into the potential long-term ecological impacts of GMPP plants and other GMOs is insufficient in comparison to the rapid pace of adoption—a pace that is unprecedented for modern agricultural technologies. Our position is that there is relatively little science with which to evaluate the short-run environmental and ecological effects of such massive changes, let alone the long-term, whole system effects (e.g., soil microbiology). And there is the potential for large-scale and irreversible environmental changes and damage (Ervin, 1999).

Given the serious nature of the potential impacts; the relative skepticism of many consumers, especially in Europe, about GMOs; and the fact that current world food supplies are plentiful, with hunger caused primarily by lack of access to food, not lack of production—a cautious and comprehensive approach to regulatory approval of such organisms is warranted.

It is important to note that current GMPP plants have some beneficial properties regarding environmental protection and the promotion of sustainable agriculture. However, for a number of reasons, their likely contributions to the development of a sustainable agriculture are limited.

Role of GMPP Plants for Developing a Sustainable Agriculture

Agricultural production can be represented along a spectrum, with conventional production characterized by a limited range of purchased interventions to enhance soil fertility and control pests on one end, and sustainable, ecosystem-based, farm-level management-intensive production on the other. Most farming systems probably fall somewhere in-between the two extremes. From this perspective, sustainable traits tend to be those which do not degrade the environment or substantially impact the surrounding ecology, do not encourage the use of toxic chemical inputs, integrate well with other sustainable practices, do not lose effectiveness over time, and maintain economic viability and social acceptance of agricultural production.

To the extent that GMPP plants move production systems away from the conventional end of the spectrum and toward the sustainable end, they promote sustainability. For example, if GMPP plants reduce the use of toxic agri-chemicals, they can move agricultural production toward sustainability by enhancing the health of farm-level workers and decreasing the potential for negative environmental impacts from pesticide use. In this vein, Hubbell and colleagues (forthcoming) found that Bt cotton adoption resulted in approximately two less insecticide applications per acre. In addition, Hubbell and colleagues (forthcoming) found that pyrethroids accounted for 83% of conventional cotton pesticide applications and only 50% for Bt cotton acres. Therefore, farmers not using GMPP plants might also benefit from their adoption because of reduced resistance development to traditional agri-chemicals, since fewer acres will be treated with such chemicals. Also, if GMPP plants are more cost effective than traditional crop protection chemicals or practices, then farmers will benefit economically. These types of impacts from GMPP plants can make U.S. agriculture more competitive and sustainable.

Concerns

Concerns have been raised about the long-term effectiveness of GMPP plants, such as Bt crops, as a substitute for synthetic insecticides because of the potential for rapid resistance in target pest populations. The efficacy of resistance management plans which set aside refugia acres of non-Bt crops to allow Bt susceptible insects to reproduce with Bt resistant insects has been questioned by a number of scientists (Rissler and Mellon, 1996). Depending on the speed of development of resistant insects, the benefits of GMPP plants in reducing insecticides could disappear in a few years resulting in the reoccurrence of conventional pesticide use, possibly at higher levels (Kennedy and Whalon, 1995).

Although, producers of GMPP plants have incentives to prevent the development of resistance, competition could lead to sub-optimal outcomes as individual firms try to maximize returns from GMPP plants (Kennedy and Whalon, 1995). Voluntary adoption of resistance management programs by industry requires sacrificing short-term sales revenue for long-term markets or long-term public benefits. Mandating the use of refugia could impact farmers and farming practices in a number of ways. The larger the refugia required, the longer the GMPP plants should remain viable and therefore available for farmers to use. However, the larger the required refugia, the smaller the size of the immediate benefits of GMPP plants to farmers.

In addition, recent research as shown that GMPP plants can negatively impact beneficial insects and non-target organisms (Hilbeck et al., 1998; Losey et al., 1999). The potential for the development of resistance and the negative impacts on non-target organisms may negate the contributions of GMPP plants to sustainability. Given current GMPP technologies, the best-case scenario regarding their contributions to sustainability would be as transitional technologies. That is, GMPP plants could reduce pesticide use in the short to medium term, while sustainable, ecosystem-based systems and technologies are developed and adopted.

Research Focus on Resistance to Damage

A number of the previously mentioned shortcomings of GMPP plants regarding sustainable agriculture originate from the fact that the current set of GMPP plants are designed to be resistant to insects or viruses instead of resistant to insect or virus damage. The distinction between resistance to insects and viruses and resistance to insect or virus damage is critical. The former represents a component-based approach to agricultural systems management wherein ecological factors are manipulated through destruction of a disease or insect. This approach disturbs the agroecology, causing ripple effects to occur throughout the ecosystem. That is, pest predators are deprived of prey, potentially reducing populations of beneficials; or removal of key pests increases the food supply for secondary pests (Snow and Palma, 1997). The benefit of damage resistant crops is that they do not put selective pressure on pest populations, and thus do not lead to the development of resistant pest populations. Large numbers of plants display a certain degree of resistance to damage (Pedigo, 1989), thus transgenic technology could be used to amplify these properties.

Another form of natural resistance to damage is the ability to delay symptoms and damage from pathogens until after the plant has produced the valuable seeds or fruit. Delayed damage would remove the necessity for treatment with chemicals or other ecologically disruptive agents. This type of trait would not interfere with the pathogens' ability to reproduce, and thus should not breed more aggressive pathogens, yet would allow farmers to realize the full economic benefits of their crop plantings (Krimsky and Wrubel, 1996).

Current versions of GMPP plants can contribute environmental benefits from reduced use of agri-chemicals. However, in the long-term, alternate GMPP technologies designed to resist or delay insect or virus damage should prove more promising in terms of realizing a sustainable agriculture (Hubbell and Welsh, 1998). Equally important is to enhance research efforts on the full range of ecological and socioeconomic aspects of GMPP plant development and use.

References

Ervin, David E. 1999. "Agricultural biotechnology is a double-edged environmental sword." Remarks at the annual meeting of the American Agricultural Journalists in Washington, D.C., April 19.

Hilbeck, Angelika, Martin Baumgartner, Padruot M. Fried, and Franz Bigler. 1998. Effects of transgenic Bacillus thuringiensis corn-fed prey on mortality and development time of immature Chrysoperla carnea (Neuroptera: Chrysopidae). Environmental Entomology 27:480-487.

Hubbell, Bryan, Michelle Marra, and Gerald Carlson. Forthcoming. "Estimating the demand for a new technology: Bt cotton and insecticide policies." American Journal of Agricultural Economics.

Hubbell, Bryan and Rick Welsh. 1998. "Transgenic crops: Engineering a more sustainable agriculture?" Agriculture and Human Values 15:43-56.

Kennedy, G.G. and M.E. Whalon. 1995. Managing pest resistance to Bacillus thuringiensis endotoxins: Constraints and incentives to implementation. Journal of Economic Entomology 88:454-460.

Krimsky, S. and R. Wrubel. 1996. Agricultural Biotechnology and the Environment. University of Illinois Press.

Losey, John E., Linda S. Rayor, and Maureen E. Carter. 1999. Transgenic pollen harm monarch larvae. Nature 399:214.

Pedigo, L. 1989. Entomology and Pest Management. New York: MacMillan.

Rissler, Jane and Margaret Mellon. 1996. The Ecological Risks of Engineered Crops. MIT Press.

Snow, A.A. and P.M. Palma. 1997. "Commercialization of transgenic plants: Potential ecological risks." Bioscience 47:86-96.

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