According to the EIS, “‘Protecting American agriculture’ is the basic charge of APHIS-USDA.” Under the federal government’s Coordinated Framework for the Regulation of Biotechnology in place since 1986, APHIS’s role is to determine if a biotech crop poses a plant pest risk. The Biotechnology Regulatory Service uses a science-based regulatory framework to perform a Plant Pest Risk Assessment to determine if the biotech crop poses a greater plant pest risk than the plants from which it was derived. The Food and Drug Administration (FDA) is responsible for the safety of biotech crops for food and feed uses. The Environmental Protection Agency (EPA) regulates the sale, distribution and use of pesticides like glyphosate. FDA enforces the pesticide residue tolerances on food and feed established by EPA.
APHIS considered in detail three alternatives. Alternative 1 would deny Monsanto’s petition to deregulate and APHIS would regulate by notification and permit. No partial deregulation would be allowed. Alternative 2 would be full deregulation as requested by Monsanto. Alternative 3 would be partial deregulation as used for the 2011 crop while APHIS developed the EIS. The environmental impacts of the three options are mostly related to herbicide usage and impacts on producers.
According to the EIS, Alternative 1, no deregulation, would decrease the use of glyphosate and increase the use of 12 other herbicides, many of which are more toxic than glyphosate. Alternatives 2 and 3 would have the opposite impacts, but total pounds of herbicide applied would be greater under Alternatives 2 and 3. Herbicide usage under Alternative 1 would have a greater environmental impact on animals, micro-organisms, non-target plants, human health and the physical environment. Alternative 1 is also expected to reduce the effectiveness of chemical weed control because many of the weeds in sugar beet fields are resistant to the non-glyphosate herbicides. In some areas, growers may choose to quit producing sugar beets. Herbicides costs in 2008 in Minnesota and North Dakota ranged from $7-22 per acre for biotech sugar beets versus $45-55 per acre for conventional sugar beets. Glyphosate resistant weeds could become a problem under Alternatives 2 and 3, but growers are aware if the potential and will likely be pro-active to avoid it.
Cultivation of non-biotech seeds under Alternative 1 is expected to increase conventional tillage and soil erosion and negatively impact water quality. Alternatives 2 and 3 would likely result in more reduced tillage and strip tillage. Under Alternative 1 conventional seed could be in short supply until 2014, as well as some of the six herbicides that are used almost exclusively on sugar beets.
Sugar beets can cross pollinate with Swiss chard, table beets and wild beets, but require flowering. Sugar beets, Swiss chard and table beets are harvested before flowering. About half the vegetable beet seeds are grown in areas geographically isolated from sugar beets. Vegetable beet seeds grown in the Willamette Valley are separated from sugar beet seed by isolation distance to ensure varietal purity.
Under Alternative 1 herbicide drift is expected to be greater because of more frequent applications of non-glyphosate herbicides and greater use of aerial application. Also under Alternative 1, the herbicides used could be a risk for sub-lethal and chronic effects on mammals, birds and reptiles, and fish and aquatic amphibians, but will not have risks of population-level affect if used according to the label. The biotech sugar beets are not expected to be more invasive or affect critical habitat differently than conventional sugar beets. Nutritional contents are also similar.
Biotech sugar beets under Alternatives 2 and 3 can result in lower weed control costs, but the technology fee offsets some of those savings. Alternative 1 would likely reduce sugar beet yields, particularly where non-glyphosate herbicides do not adequately control weeds.
The EIS notes, “Sugar beet sugar that would be derived under Alternative 1 would be chemically identical to the sugar derived from H7-1 sugar beets under Alternatives 2 and 3.” No adverse effects have been found on human health or worker safety from biotech sugar beets. APHIS did estimate that 95 non-fatal injuries would occur each year to sugar beet growers when tilling and applying herbicides. The biotech sugar beets would reduce equipment use by 70 percent, with an equivalent reduction in injuries.
According to the EIS, 11 countries, excluding the U.S., that regulate the importing of biotechnology-derived crops and derived products have granted approval for the H7-1 biotech sugar beets. Canada has approved it for food, feed and planting; Japan for food, feed, importing and processing; the EU, Mexico, the Philippines and Singapore for food, feed and importing; and Australia, Colombia, South Korea, New Zealand, and Russia for food and importing. The regulators in these countries have concluded that food and/or feed from biotech sugar beets are as safe and healthy as food and feed from conventional sugar beets.
Based on the EIS, APHIS has found that biotech sugar beets (event H7-1) will not be a plant pest if granted deregulated status. FDA and similar regulators from 11 other countries have determined biotech sugar beets are as safe and healthy for humans as conventional sugar beets. Weed control in sugar beet fields will be improved through deregulation, while herbicide costs and soil erosion will be reduced. From an economic policy perspective, Alternative 2, full deregulated status, is the correct action for APHIS to pursue.
Ross Korves is an Economic Policy Analyst with Truth About Trade and Technology