Changing genes in an untimely fashion: How genetically modified field crops transform agriculture and

threaten biodiversity in the North Country

Katie Oram and Ryan Gillard

Conservation Biology

May 6, 2011

Table of Contents

Executive Summary …………………………………………………………………………… 1

Problem Definition …………………………………………………………………………….. 3

Identification of Stakeholders ………………………………………………………………… 25

Governmental Issues ………………………………………………………………………….. 33

Development of Solutions to the Problem …………………………………………………….. 41

Ease of Implementation ………………………………………………………………………... 54

Step-by-Step Implementation Plan …………………………………………………………….. 56

Conclusion ……………………………………………………………………………………... 59

Appendix A …………………………………………………………………………………….. 61

References ……………………………………………………………………………………… 69

Oram and Gillard

I. Executive Summary

Genetically modified crops have become widely implemented throughout agriculture

systems in the United States. A growing human population has resulted in an increased demand

of food, which has caused new innovations in biological technology. Genetically modified

organisms, organisms with altered DNA, have been introduced in agriculture to improve yields,

deter pests, and allow herbicide tolerance. Large biotechnology companies have created two

main types of genetically modified corn varieties that are widely used in St. Lawrence County:

herbicide tolerant (e.g Roundup Ready) and insect resistant (Bt). Such traits have resulted in

increased use of glyphosate herbicide and decrease use of pesticides targeting insects such as

corn borer or root worm.

Genetically modified crops are thought to have negative effects on biodiversity. Such

impacts include harm to non-target species, gene escape, hybridization, and creation of herbicide

resistant weeds and pesticide resistant insects. Other secondary environmental effects also exist

through pesticide applications, monocrop practices and increased intensity of farming scale.

Some health effects on mammals due to ingestion of GM crops have also been studied. Research

suggests that ingestion of food containing GM products may be toxic and result in decreased

liver and kidney functions.

Large biotechnology companies such as Monsanto, Dow or DuPont hold patents to all

traits that have created, which allows them to have complete control over the agriculture

industry. Farmers are no longer allowed to save seed and must buy new seed every season from

the large companies. If farmers are found to be growing genetically modified crops that they did

not buy the seed for that year, they can be sued for patent infringement. This is the same for

conventional or organic farmers who may suffer from cross pollination of GM crops with their

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crops via wind dispersal.

Currently, the governmental agencies that regulate and monitor genetic modification

technology are the Federal Department of Agriculture (FDA), the Environmental Protection

Agency (EPA) and the United States Department of Agriculture (USDA). These agencies have

mainly used existing policy from conventional foods and crops to regulate genetically modified

crops. Expedited approval processes have been created for new genetically modified traits that

already meet certain conditions and research on the new traits are provided by the biotechnology

companies. Scope of environmental impacts of genetically modified crops is insufficient and

regulations are poorly mandated. Biotech companies have extreme amounts of power and can

easily manipulate government agencies allowing most GM traits to be introduced for commercial

cultivation. Part of their power stems from their ability to encourage policy by supporting

political candidates with millions of dollars toward campaigns.

Possible solutions include creating a new branch in the government specifically

responsible for regulating and monitoring genetically modified crops. New regulations and

policies should be implemented to better control the introduction on the genetically modified

traits. Regulations should include creating buffer zones are farms planting genetically modified

crops, require crop rotation and diversity, required planting of cover and refuge crops, require

permits for farmers, set time limit on biotech company patents, and increase regulations on

glyphosate and other chemicals. Other requirements include labeling of any genetically modified

products as well as tracking the entire lifespan of genetically modified crops. The final essential

component is increased research of current and new genetically modified technology. This can

be achieved through research by scientists independent of biotech companies in order to

determine safety of traits and environmental or health risks.

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In order for these solutions to be implemented, the government must restructure its

regulatory agencies, implement policies and fund long term research projects. There also must be

a push for broader awareness and education on genetically modified crops and technology.

Genetically modified crops in the North Country are causing possible health and environmental

effects, giving biotech companies extreme power and altering farming practices. We need to shift

away from a risk-based approach to policy to a precautionary based approach. If specific

restructuring is done within the government and we increase our understanding of genetic

modification, perhaps we can safely control the cultivation of genetically modified crops in the

North Country.

II. Problem Definition

Introduction to Genetically Modified Organisms

Genetically modified organisms (GMOs) are organisms with DNA that has been altered

from its natural state. Scientists are able to extract a desired gene from a source organism and

insert the gene into the target organisms in order to achieve a desired trait. The target organism

will then reproduce and carry on the novel genes. Several methods are used to insert new genes

into an organism’s DNA. New genes are typically injected by physically inserting a syringe into

the nucleus of the target organism organism and expelling the new gene.

The worldwide use of genetically modified crops has grown steadily since their

introduction to the commercial market in 1996. The three largest seed companies worldwide –

Monsanto, DuPont, and Dow - are also major chemical companies and are the leaders in the

development of genetic modification.

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Monsanto was the early pioneer in biotechnology. In 1983 scientists working for

Monsanto became the first to genetically modify a plant cell (Monsanto Company History); the

technology was not be implemented worldwide for another 12 years. In 1996 Roundup Ready

Soybeans were introduced, providing the first crops to be genetically herbicide resistant to

glyphosate products. In 1998 after Monsanto purchased DeKalb Genetics Corp., the growing

company introduced Roundup Ready Corn along with YieldGard Corn Borer insect-protection.

The introduction of Roundup Ready and YieldGard was the first time a biotechnology company

had developed a GMO with multiple traits or stacked traits. Many biotech companies now offer

mainly products with stacked traits.For instance, every product sold by DeKalb seed is Roundup

Ready, along with an additional trait.

In the North Country several companies market their GM crops: Pioneer (owned by

DuPont), Mycogen (owned by Dow), and Syngenta, Asgrow and DeKalb (owned by Monsanto)

are the most widespread biotechnology companies in the region. Each company has its own

branded version of a the trait and stacks of traits. Insect-resistant corn containing the Bt toxin is

sold by DeKalb as YieldGard and by Pioneer as Herculex. Both brands are genetically modified

to achieve insect resistance using a bacterial gene.

Types of Genetically Modified Crops

Bt Corn

Bt corn receives its name from Bacillus thuringiensis, a soil bacteria that produces the Bt

toxin-protein, which destroys the gut of insects. Although there are 170 different Bt varieties,

each variety has a gene that codes for the Bt toxin-protein, the Cry1Ab. This proteins can persist

in soils until at least seven months after harvest (Baumgarte and Tebbe 2005). The target pests in

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the North Country are typically the European corn borer (Ostrinia nubilalis) and corn root

worm(Diabrotica sp). All of the corn with Bt traits express the toxin-protein that kills any pests

feeding on the crop. Corn borer is more of an issue in the North Country than root worm, though

the Bt crops sold here target both.

LibertyLink

LibertyLink is Pioneer’s trade name for an herbicide tolerance crop. LibertyLink crops

are tolerant of glufosinate, an ammonia-salt compound that is toxic to most plants. Glufosinate

blocks the glutamine synthase metabolic pathway and causes ammonia to build up in plants,

causing death within days. Glufosinate is biodegradeable within 3-20 days. Glufosinate has been

used since 1984 as a non-selective herbicide around railroads. When Bayer released a crop that

was tolerant of Glufosinate, the herbicide’s use increased dramatically. In comparison to other

herbicides, such as glyphosate, its use in the North Country is significantly less (2011 personal

communication Ron Debeer).

Roundup Ready

In 1974 glyphosate was released by Monsanto in their branded herbicide Roundup. With

this product they claimed glyphosate to be a biodegradable and non-toxic herbicide. Glyphosate

kills any non-tolerant or non-resistant plants in 3-7 days by inhibiting the production of EPSP

synthase, an enzyme necessary for amino acid synthesis. Glyphosate is a non-selective herbicide

that has been used for over 25 years also around railroad tracks (GMO Compass). The herbicide

became very popular in the mid-1990s when Monsanto released a Roundup Ready soybean

variety. The Roundup Ready Soybean plant was the first of its kind to be tolerant of an herbicide.

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The transgene in Roundup Ready and other glyphosate-tolerant crops encodes for an enzyme

derived from Agrobacterium tumerfaciens. The enzyme, enol pyruvate shikimate-3-phosphate

synthase, is a glyphosate-insensitive version of EPSP synthase.

From the onset of Roundup Ready technology, the use of Roundup and other glyphosate

chemicals, such as Dupont’s Agrisure skyrocketed.From 2001 to 2007 glyphosate was the most

used active ingredient in pesticides in the agricultural sector (Table 1). One of the reasons

Roundup is widespread is because of its accessibility. Many herbicides in the past have been

restricted in their use – meaning farmers need to obtain a license to apply the herbicide. Roundup

does not require a license to use and can be purchased at the local hardware store because it is

considered overall as non carcinogenic and non-toxic for humans by the EPA standards (EPA

Integrated Risk Information System)

GM crop introduction to the North Country

In the past decade many farmers in the dairy industry have struggled with milk prices,

cost of fuel, and volatility of field crop yields. Market prices and weather both fluctuate

expectantly, causing sharp declines in the already slim profit margin. In an attempt to counteract

fluctuations and meet growing demands for cheaper dairy, farmers have tended toward larger-

scale production. Small farmers have been pushed to bigger scales or forced to leave the industry

because of efficiencies of scale and a “Get Big or Get Out” mentality by Cornell and other

agricultural institutions (2011 personal communication Ray Hill). Subsidies are given to mostly

larger farmers for growing their own grain (Figure 1). Companies such as Bourdeau Brothers in

Canton, NY are able to keep prices low by selling bulk seed and fertilizer packages (2011

personal communication Stephen Canner).

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The volatility of dairy prices also drives production higher. When milk prices are high,

farmers buy more cows to take advantage of the demand. More cows necessitate more feed,

which equates to more land to grow the feed, which usually means a need for a larger tractors.

Either loans or increased production will pay for expensive new equipment and the cycle

continues to spiral upwards (2011 personal communication Ray Hill). Higher production per

cow means fewer farmers, better efficiency and bigger farms (2011 personal communication Jon

Greenwood and NCPR). In New York, the 3rd largest producer of dairy in the nation, milk

accounts for over half of all of the agricultural sales (NYS Dept. of Agriculture and Markets).

In 2007 over fifty percent of farm land in St. Lawrence County was being used to grow

crops (USDA Ag. Census 2007), most of which was corn. Since 1987, the number of farms in St.

Lawrence County that grow corn for silage has decreased by nearly two-thirds. Meanwhile, the

number of grain farms have remained relatively constant while the number of farms growing soy

has increased (Figure 2). The amount of acreage in production for grain has increased and the

bushels of corn grain harvested in 2007 were over double that of 2002 (Figure 3; Figure 4).

Overall, the production of grain corn has been increasing as the number of farms decrease.

Twelve years ago, a change in the agriculture industry was introduced to the North

Country: genetically modified organisms (GMOs). Marketers of these new genetically modified

varieties attracted farmers with the plausible savings in pesticides, herbicides and labor and an

increase in yields. Genetically modified crops are now primarily used throughout the North

Country. Several seed companies - including Dekalb Seed owned by Monsanto- only sell

genetically modified seeds.

Today many agree that it is difficult to find conventional seed. Conventional seed is

defined as seed that does not contain a genetically modified trait. According to Ken Hill, a small

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feed producer, almost everyone in the North Country uses GMOs. Some people are still

unwilling to grow genetically modified seed: members of the Amish community buy the

conventional, which is cheaper and lower yielding and many small organic producers are not

permitted to grow GMOs. There are some seed companies, such as Bordeau Brothers, that sell

conventional seed in the North Country; however the supply is much less than any GM seed

(2011 personal communication Bryan).

As this technology has allowed the production of corn to increase, the demand for corn

has also increased dramatically because of ethanol production. In 2001 Monsanto became the

first corporation to order full-size pickup trucks that ran on 85% ethanol and 15% gasoline

(Monsanto Company History). The next year, Monsanto marketed a specific variety of corn that

yielded more ethanol per bushel. The Processor Preferred Corn hybrids have allowed farmers to

grow more corn for ethanol and have changed the corn industry (Monsanto Company History).

Aside from ethanol, corn has been incorporated into almost every processed food product,

packaging, plastics and homebuilding material. Due to a deficit of sugar produced domestically,

the United States government has given large subsidies to corn farmers for production of corn

syrup to decrease reliance on imports.

In the North Country, a recent interest in biofuels and a newly constructed ethanol plant

in Fulton, NY have caused a two-fold increase in the price of corn in the past few years (2011

personal communication Ellie Stripp). Now dairy farmers are “competing with cars” for fuel. In

New York State, corn-based fuel (ethanol) will increase by 5% every year. According to Ellie

Stripp, manager at Wight & Patterson feed producer, this will cause an increase in sub-standard

corn production – i.e. when corn is produced on soil that is not fit for growing corn – and an

increase in monoculture corn production.

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Corn prices have reached an all-time high; three years ago corn was $3/bushel and

currently it is $7.45/bushel (2011 personal communication Scott Walker). The demand for corn

is also increasing and will continue to grow. In seven of the last eight years the corn demand has

exceed the supply (2011 personal communication Scott Walker). Although conventional seeds

are cheaper, farmers want to get the maximum yield per seed because of prices (2011 personal

communication Scott Walker). Farmers are trying to fulfill the supply and produce more corn by

using genetically modified technologies. Monsanto has plans to double corn yields by 2030

(2011 personal communication Scott Walker). By decreasing pests and weeds, and decreasing

necessary inputs like water and nitrogen with biotechnology, Monsanto plans to achieve 300

bushels to the acre – a four fold increase from 1970 and two fold from current yields (2011

personal communication Scott Walker).

Positive Outcomes of GMO use

Decreasing pesticide use

Members of the International Council for Science (ICSU) are in agreement that the use of

genetically modified insect-resistant Bt crops has reduced the use of insecticide on corn and

soybean cultivation in the United States (Fresco 2001). As a result, ground water contamination

is less and damage to non-target insects has been reduced in some cases (Fresco 2001). There is

evidence however, that Bt crop debris can have a negative impact on non-target invertebrates in

aquatic systems(see below).

Many of the fields in St. Lawrence County are relatively small in size and are not fit for

aerial spraying of pesticides. In the past, farmers have been left to pay for high-rise insecticide

application with expensive equipment or, if they are small enough in scale, they managed

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pesticide application on their own (2011 personal communication John Greenwood). Another

option was to not apply pesticides and absorb the loss to pests (2011 personal communication

John Greenwood). Caustic pesticides such as Feridan, were used by some farmers to eliminate

rootworm, wire worm, army worm and corn borer.

With the advent of Bt technology however, many of these practices changed. Now,

farmers do not have to apply any or can apply reduced amounts of caustic pesticides. Farmers

can achieve the same weed control with an application of 1.5 quarts of a toxic chemical such as

Synch per acre of Bt corn as they could have in the past with 2.5 quarts per acre of conventional

corn (2011 personal communication Bryan, Bourdeau Brothers). In the past, farmers would

apply gallons of a pesticide Basis per acre, whereas the same action can be achieved with of 3 oz

of Basis per acre on Bt corn (2011 personal communication Bryan, Bourdeau Brothers).

Decreasing residual herbicide use

Prior to the introduction of herbicide-tolerant crops in the North Country, farmers would

use chemicals such as Paraquat, Atrasime, 24D, Basis, Dual, and Lumax to control weeds. Most

applications would occur in the spring as a pre-emergent application with residual effects and a

post emergent application, once the corn had five or more leaves. Over time, herbicide-resistance

developed in some weeds causing farmers to begin using a combination of potent herbicides for

a stronger attack on weeds. According to a report by the National Academy of the Sciences

(NAS) for controlling problematic weeds, growers prefer increasing the magnitude and

frequency of glyphosate applications, using other herbicides in addition to glyphosate, or

increasing their use of tillage (Waltz 2010).

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North Country corn farmer Ken Hill remembers when he applied the herbicide Paraquat,

a defoliant used to burndown fields in the fall in order to kill any remaining weeds that could be

transferred to the next season. After the introduction of GM crops with herbicide resistance, Ken

Hill stopped using herbicides such as Paraquat (2011 personal communication Ken Hill). “I don’t

know anyone that would touch that anymore” he said of the chemical. The chemical is highly

toxic and restricted for its use in agriculture. Paraquat was registered with the EPA in 1964 and

not issued a Registration Standard until 1987. Currently, Paraquat has been placed on the EPA’s

toxicity categories at II for eye irritation and IV for dermal irritation (on a scale from I to IV

where I is most dangerous). Farmers and seed distributors claim that now they are using less of

highly toxic chemicals and more of widely accepted chemicals such as glyphosate (2011

personal communication Ken Hill, Bryan, Bourdeau Brothers).

Although there are claims that pesticide use has decreased because of Bt technologies and

residual herbicide use has decreased because of Roundup Ready technology, the EPA Pesticide

industry sales and usage report shows a different trend. Glyphosate, the number one active

ingredient in all pesticides, has increased in use from 6-8 million pounds in 1987 to 180-185

million pounds in 2007 (Grube et al. 2011; Table 1; Table 2). The use of Atrazine, the next most

commonly used active ingredient in all pesticides and also used as a residual herbicide remained

constant in its use with 71-76 million pounds in 1987 (before cultivation of GM crops) and 73-38

million pounds in 2007 (Grube et al. 2011; Table 1; Table 2). Another commonly used toxic

chemical in pesticides, 24D has also remained constant in its use from 29-33 million pounds in

1987 to 25-29 million pounds in 2007 (Grube et al. 2011; Table 1; Table 2). Nationally it does

not appear that herbicide or pesticide use has decreased.

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Increasing yields farmers, increased company revenues

Regional farms have experienced increased yields when using GM crops. In the North

Country yields have been elevated with GM crops due to decreased competition with weeds and

predation by pests. According to Scott Walker (2011 personal communication), Monsanto’s VT3

seed out-yielded the conventional seed by 10 bushels per acre. The benefit of Bt corn however is

not limited to the grower of GMOs.

A recent study showed that non-GM varieties of corn grown near GM corn experience a

decrease in pests (Black 2010). Farmers may want to consider planting a higher proportion of

non-GM, less expensive seed around the areas of GM seed so they can reap the benefits of the

traited variety. The EPA already requires a certain percentage of area of conventional corn be

planted within close proximity of the GM field, but farmers may benefit from a higher

percentage of non-GM crops planted (Black 2010)

Less soil tillage

Herbicide resistant crops have allowed farmers to adopt low or no-till techniques, which

has resulted in less erosion and overall increased conservation of soil (2011 personal

communication Ken Hill; Fresco 2001). No-till has gained popularity despite slowing soil

warming and requiring a fall herbicide burn down. In a typical no-till scenario, a farmer will do a

burndown in the fall to kill any weeds. A burndown might consist of Roundup with a small

addition of 24D. In the spring, the corn will be cultivated without tilling. Afterwards, some

farmers apply a post-plant pre-emergent herbicide mix such as Atrasine and Lumax even if their

crops are Roundup Ready, in order to add greater potency (2011 personal communication John

Greenwood). Other farmers will wait until corn has emerged and spray a combination of

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Roundup onto the 18 inch corn. Often the use of a small amount of 24D or other herbicide is

used to target those weeds who have gained a resistance to Roundup.

By eliminating the cost and risks of insecticides, decreasing the use of herbicides and

creating savings of time and resources with non-tilled Roundup Ready corn, many farmers have

switched to GMOs. In the North Country, this switch has been in the past five years (2011

personal communication Ken Hill).

Negative Effects of GM crops on biodiversity

Effects of increased glyphosate usage

One of the most widespread GM crops that are planted are those that are Roundup Ready.

The main herbicide used now in agriculture is glyphosate. The usage of glyphosate has increased

dramatically as a result of increased planting of GM crops (Grube et al. 2011).

According to the Environmental Protection Agency (EPA), glyphosate is a non-

carcinogenic, non-toxic chemical at levels of 0.1 ppm for grain (EPA and Monsanto – Summary

of Human Risk Assessment and Safety Evaluation on glyphosate and Roundup Herbicide). The

EPA rates glyphosate at III on the toxicity class for oral and inhalation exposure. It does not

bioaccummulate and is harmless at low levels of exposure (EPA and Monsanto – Summary of

Human Risk Assessment and Safety Evaluation on glyphosate and Roundup Herbicide). Neither

the EPA synopsis of results nor the Monsanto report gave an indication of possible effects on

non-mammals. In fact, there is still concern that increase use of less potent herbicides such as

glyphosate, may still have a negative effect on nearby ecosystems (Fresco 2001).

Glyphosate may reduce plant uptake of nutrients - calcium, cobalt, copper, iron,

manganese, magnesium, nickel, zinc by up to 80% (Johal and Huber 2009). Although glyphosate

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is said to rapidly breakdown in soil, some reports claim it can remain in soil for at least 22 years

(Johal and Huber 2009). Glyphosate kills microbiota in soil, which can limit nutrient availability.

Glyphosate can also create a tenfold drop in soil organisms that make manganese available

(Johal and Huber 2009). Fungi that can cause diseases such as Fusarium, Pythium and

Phytophthora could become super pathogens in the soil and kill soil biota when glyphosate is

used regularly (Johal and Huber 2009).

Glyphosate reduces N-fixation, lignin production and drought tolerance. Roundup Ready

(RR) Alfalfa sprayed with glyphosate reduces nutrients such as nitrogen, phosphorus, potassium,

magnesium, sulfur, and iron from 13-52% by testing nutrient levels in RR Alfalfa (Johal and

Huber 2009). “Decreased biological nitrogen fixation in glyphosate-resistant (GR) soybeans has

been attributed directly to toxicity of glyphosate or its metabolites, to N2-fixing microorganisms”

(Zobiole et al. 2010). Glyphosate is systemic, meaning it can be transported to non-target areas

of the plant, such as the rhizosphere, leaves or pollen.

In a recent study glyphosate was shown to decrease the amount of nickel in the soil

inhibiting symbiotic N-fixing microorganism function (Zobiole et al. 2010). Additionally other

adverse effects included a decrease in photosynthesis. Glyphosate can be translocated to high

concentrations in root nodules where symbiotic N-fixing bacteria are inhibited (Zobiole et al.

2010). In soybeans the symbiotic Bradyrhizobium japonicum bacteria suffers from inhibited

growth and death from glyphosate (Zobiole et al. 2010).

Glyphosate-based Roundup can cause soil depletion when used on a continual and long-

term basis (2011 personal communication Ray Hill). Farmers have reported decreased yields in

other crops planted in a field after it has been sprayed with Roundup for several years. Ray Hill,

a local organically-practicing dairy producer, told a story of a farmer in the Midwest who planted

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Roundup Ready corn and applied Roundup on a field for several years. When the farmer decided

to switch to a conventional crop, “nothing other than Roundup Ready corn could establish itself

for the next three years” (2011 personal communication Ray Hill).

Joel McNair, a small dairy farmer from southern Wisconsin has a similar experience as

that of Ray’s friend in the mid-west. Joel writes,

We graziers have known for at least two decades that it is very

difficult to get grasses established in fields previously planted to

row crops and sprayed with Roundup. None of us actually believed

the stuff just went away, especially after many years of heavy use.

For more than a decade we have had anecdotal evidence from

farmers that their livestock don't seem to perform as well on GMO

grains (McNair 2011).

In addition, a 2005 study (Hileman) at the University of Pittsburg has shown that

Roundup is lethal to amphibians. Tadpoles of wood frogs, gray tree frogs, toads, and leopard

frogs were exposed to Roundup. There was 100% mortality in gray tree frog and leopard frog

tadpoles and significant reductions in wood frog and toad tadpole populations. Previous findings

from studies in Australia indicate that polyethoxylated tallowamine (POEA), an additional

chemical in Roundup that is responsible for penetrating leaves of target weeds was likely the

cause of tadpole death, not glyphosate (Hileman 2005). Round-up has also been classified

highly toxic to rainbow trout by the EPA (EPA Ecological Effects Data). One study found that

glyphosate significantly reduced respiration and N-fixation of Azotobacter vinelandii (Santos and

Flores 1995). Other studies during this period showed that glyphosate can reduce the growth

rates of earthworms. (Springlett and Gray 1998)

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In New Zealand, scientists investigated the possible synergistic effecst of glyphosate on

aquatic ecosystems. They found that glyphosate may increase the risk of disease in fish by

amplifying parasites damage to weakened vertebrates. They conclude that regulations on

acceptable glyphosate levels are not strick enough to prevent deleterious effects to aquatic

ecosystems. Another observation of the study was that application of glyphosate is often applied

in the spring. This coincides with fish larvae development - a time when the organisms are

vulnerable to environmental stress and parasitism (Kelly et al. 2010).

Habitat fragmentation

Changes in biotechnology with the adoption of GMOs has permitted farmers to manage

larger acreage with equivalent amount of labor. The trend in the North Country is fewer farms

with larger areas. Owners of farms in the dairy industry are expanding production of genetically

modified crops in order to meet their demand for grain. As the farms grow in size, smaller

parcels of land are purchased and consolidated into single large tracts planting a single crop, or

monocrops, which are easier and more efficient to manage on a large-scale. Intense forms of

agriculture that include monocropping, GM use and large chemicals inputs cause a loss of

biodiversity at every level (Groom et. al 2006). Similar management of soy monoculture in the

United States average 16 tons of soil cover loss per hectare (Altieri 2009).

Smaller farms with limited amounts of land are left to grow the same crops year after

year. In the case of corn or soy, this type of production encourages pest establishment and can

result in herbicide-resistant weeds (2011 personal communication Bryan, Bourdeau Brothers and

Stephen Canner).

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Biotechnology increases the stress on agroecological systems by increasing the intensity

of cultivation on the land. In the past decade intensity of seeds per acre has increased. Where

farmers would plant 25,000 seeds per acre, they are now planting 40,000 seeds per acre (2011

personal communication Bryan). Since 1996, the use of GM crops has increased in intensity for

GM corn, cotton and soybeans in the United States (USDA; Figure 5). In St. Lawrence County,

the number of farms for soy, corn silage and soy grain have decreased since 1987 (Figure 2), but

the amount of soy and corn acreage and crops harvested increased (Figure 3; Figure 4). More

crops with less farms means that agriculture practices have become more large scale, intense, and

reliant on the same crops. This increase in intensity may cause nutrients to be taken up and

washed away faster than it is replenished.

Weed and pest resistance

In April 2010, the US National Academy of the Sciences (NAS) reported that several

weeds are becoming resistant to commonly used herbicides. Resistance has increased as

genetically modified, herbicide-tolerant crops have become more widely used. Herbicide-

resistant weeds are occurring in the same areas where herbicide-tolerant crops are plants. One

hundred and twenty species worldwide have developed a resistance to herbicides used with

herbicide-tolerant crops (Fresco 2001, GM Science Review Panel). In 2000 the first glyphosate-

resistant weed, horseweed (Conyza canadensis) was reported. Since then, eight different weed

species have been confirmed as having a resistance to glyphosate (Waltz 2010). There is

controversy over the consequences of resistant pests or plants in the wild. However, most

scientists agree that some resistance will develop, and resistance management strategies must be

implemented.

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Weeds that are suspected to have begun developing herbicide resistance (to Roundup and

others) in St. Lawrence County include lambsquarters (Chenopodium album), ragweed

(Ambrosia artemisiifolia), and water hemp (Amaranthus rudis). Many farmers report that

herbicide resistance is not a large problem here yet, but the potential exists for it to become an

issue. With the development of stacked genes, crops can be tolerant of several herbicides,

allowing farmers to use multiple herbicides and counteract herbicide resistance in weeds.

Farmers combine Roundup with other herbicides to prevent the development of a resistant. This

strategy maintains the reliance on herbicides that may have negative impacts on nearby

ecological systems.

Effect on non-target species

Herbicides and pesticides often have secondary unintended effects on species that are not

being targeted. These non-target species may be in the same or different location and can suffer

from extremely low exposed of chemicals far distances from origin. For instance, residual toxins

can leach into nearby ecosystems and harm resident species. 0.1ppb of atrazine showed negative

effects on north leopard frogs (Rana pipiens) and African clawed frogs (Xenopus laevis) in areas

far from the source. Other deleterious effects of pesticides include Bt-toxin on pollinators, and Bt

toxin to aquatic invertebrates. In some cases, GM crops have reduced abundance of weeds that

some birds rely on for seeds during winter (Assouline and Stockelova 2005). The effect of GM

crops extends beyond the target pest species and may harm other species in nearby habitats.

Potential effect on Monarchs eating Bt pollen

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Although chemical application has decreased with Bt corn technologies, the effect of Bt

technologies themselves has come into question. According to research, the threat of Bt pollen on

Monarch butterflies (Danaus plexippus) is significant. Monarchs feed exclusively on milkweed,

which commonly grows in and around corn fields (Yenish et al. 1997). The Monarch larvae feed

on milkweed from late June to mid-August, the same period during which the corn will shed its

pollen for 8-10 days. Corn pollen is dispersed over at least 60 meters by the wind and can be

consumed by insects feeding on nearby plants (Yenish et al. 1997). A study found that Monarch

butterflies that had consumed milkweed (Asclepias curassavica) leaves with Bt corn pollen “ate

less, grew more slowly and suffered higher mortality” (Losey et al. 1999). Pollen from N4640-

Bt corn and a different untransformed hybrid were fed to larvae. No larvae died from eating

leaves dusted with untransformed pollen, implying that that all mortality on Bt pollen leaves was

due to the Bt pollen. There was also a two-fold decrease in consumption with Bt pollen compared

to leaves with untransformed pollen.

Another study measured the effects of Cry1AB-expressing corn (Bt corn) on Monarch

butterfly larvae (Dively et al. 2004). Scientists found that 23.7% fewer Monarch butterfly larvae

reached the adult stage after feeding on milkweeds covered with Bt pollen. Overall weights of

pupae and adults were also reduced by 5.5% in monarchs exposed to Bt pollen. The portion of

Monarch population exposed to Bt corn pollen is likely to be low, however because of the

percentage of larvae present during corn pollen shed and the sub-threshold level of toxicity

surrounding cornfields, there is a significant threat to Monarchs (Oberhauser et al. 2001,

Pleasants et al. 2001).

The presence of Bt pollen may deter feeding by Monarch larvae (Prasifka et al. 2007).

Movement by Monarch larvae on milkweed with Cry1Ab0 expressing corn anthers was

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significantly lower than movement on milkweed leaf disks without anthers or with non-Bt

anthers (Prasifka et al. 2007). These behavioral changes as a result of exposure to Bt pollen

suggest that ingestion may not be the only effect of Bt pollen on non-target species (Prasifka et

al. 2007).

In a review of 20 different peer-reviewed articles studying the effects of Bt-maize on

larvae of non-target species of Lepidoptera, 52% of the 16 laboratory studies showed negative

effects of Bt pollen on caterpillars (Lang and Otto 2010). In the review, the authors concluded

that hazard characterization of Bt corn cannot be made. Laboratory results have been made under

ecologically unrealistic assumptions and other limitations are great: inadequate data and lack of

publications and over-representation of North American species.

Furthermore, the Food and Agriculture Organization (FAO) summarizes findings from

the Proceedings of the National Academy of Sciences of the United States of America. According

to FAO report, several studies agreed with Losey et al. (1999) about the toxicity of Bt corn in

laboratory levels. However, other studies showed fields of Bt toxin have negligible effects on

Monarch larvae. The report stated that the overlap of corn flowering period and Monarch feeding

period is small and the amount of pollen contains low levels of Bt and will not be heavily

consumed by monarchs (Fresco 2001).

Over three hundred studies on Bt corn pollen and Monarchs show a wide range of results

with no major conclusion one way or another. The number of studies on the topic and the

inconsistency with results suggests that more research needs to be done in order to be certain that

the threat to monarchs is insignificant. Furthermore GMOs expressing Bt toxin potentially have

negative effects on other non-target species.

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Potential effects on aquatic invertebrates

Bt corn pollen and detritus was shown to enter nearby stream systems and negatively

impact non-target aquatic invertebrates (Rosi-Marshall et al. 2007). Corn pollen can be

transported by wind and water 20-60m from the source and leaves and cobs can be transported

.38 to 180m from the source (Rosi-Marshall et al. 2007). Corn pollen is released in July and lasts

for a period of 5-10 days (Rosi-Marshall et al. 2007). Streams located within 500m of a field in

which Bt corn was planted the year before are likely to contain Bt detritus (Tank et al. 2010).

Bt δ-endotoxin is designed to target lepidopteron (butterflies and moths), dipterans (true

flies) and coleopteran (beetles) invertebrates (Rosi-Marshall et al. 2007). One study attempted to

quantify the effects of Bt corn pollen and debris on non-target aquatic trichopterans (caddisflies).

Caddisflies were chosen because they are common in aquatic ecosystems and are closely related

to the lepidopteron Bt target pest. Lepidostoma liba, the shredding caddisfly had 50% lower

growth rates when fed Bt corn leaves than when fed non-Bt foliage such as maple leaves

(Rosi-Marshall et al. 2007). In laboratory tests measuring the effects of Bt pollen on

Helicopsyche borealis, the scraping caddisfly, mortality increased by 24% and growth rates

decreased when pollen concentration were twice as high as their observed maximum aerial input

rates in the field (Rosi-Marshall et al. 2007).

Another study found that individuals of Lepidostoma liba were negatively affected by

feeding on Bt corn debris in laboratory feeding trials (Chambers et al. 2010). Although in situ

results did not coincide with their laboratory results – i.e. there were no significant differences in

diversity, biomass, and structure of trichopterans in Bt and non-Bt streams - inconsistencies were

attributed to high anthropogenic degradation of study steams. Within an already stressed

ecosystem, the effect of a single “stressor” would be difficult to distinguish.

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Streams, wetlands or other aquatic ecosystems that are near GM farms can also be

directly affected by run-off. A study testing streams near Bt modified corn fields, found Cry1Ab

protein (compound inserted in GM corn) in 13% of stream-channels and 23% of sites in the

water column (Tank et al. 2010). The study also found that 82% of the stream sites were within

Bt corn fields making them vulnerable to pollution (Tank et al. 2010). Using GIS the study also

found at all of the sites where Cry1Ab was found was also within 500m of GM planted corn

(Tank et al. 2010). It is possible that toxins such as Cry1Ab are polluting water sources in St.

Lawrence County since there are many aquatic systems within 500m of agriculture farms (Figure

6).

Reduced growth and increased mortality were consequences of laboratory tests for

invertebrates fed Bt corn byproducts. Because of Bt corn’s effect on these low trophic

invertebrates and its ability to permeate nearby aquatic ecosystems, researchers conclude Bt corn

may have negative ecosystem-wide effects. There is insufficient data on the occurrence and

effect of Cry1Ab proteins in aquatic systems such as headwater channels. Scientists involved in

the above studies recommend more research be done on the effects of non-target aquatic species

that may suffer from Bt corn byproducts (Rosi-Marshall et al. 2007; Tank et al. 2010)

Hybridization

Genetically modified plants can cross-pollinate and hybridize with wild relatives.

According to the FAO report (Fresco 2001), there is not a significant concern with this

hybridization because wild relatives that have inherited transgenes that are not likely to have any

competitive advantage over other native species. No species inheriting modified genes have been

reported to become invasive in the UK (Fresco 2001; GM Science Review Panel, 2003).

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Nonetheless, most scientists are split on whether or not hybridization and the release of

transgenes into the environment will have negative effects on local ecosystems. Most of the

inheritable genes such as herbicide resistance offer advantages in agricultural systems, but not

ecological systems. However, weeds which inherit an herbicide resistance from a closely related

transgenic crop do pose a threat to growers. The International Council for Science (ICSU)

acknowledges that more research is needed to determine if this is or will become a problem

(Fresco 2001).

Gene escape

Recent research in the United States has shown that GM crops may be able to “escape”

and thrive in the wild for decades. The study found that 80% of the wild canola surveyed had

transgenes from GM crops (Black 2010; First Wild Canola Plants With Modified Genes Found in

United States). These finding have spurred a discussion about how herbicide resistance genes

might affect wild weeds. The research team found both RoundUp Ready and LibertyLink

varieties in the wild as well as two wild individual plants with both transgenes, suggesting that

two GM plants had cross-pollinated with wild plants and escaped. Although GM rapeseed has

been reported in other parts of the world, this is the first report of large groups of GM plants have

been found in the wild. There are concerns that the build-up of herbicide resistant traits in wild

weed species of canola and field mustard may make these plants difficult to manage.

Risk of new technology failure

In October of 2010 after Monsanto released its newest SmartStax corn, the company’s

stock dropped by 40% (Pollack 2010). Yields from the newly engineered variety containing eight

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inserted genes provided yields equal to less expensive varieties with only three genes. A current

anti-trust investigation has been brought against Monsanto and includes issues such as offering

farmers seeds with traits they don’t need (Pollack 2010). Farmers often have to buy seed with a

gene that protects against rootworm even when that pest is not a problem in the area. Recently

many varieties of the Roundup Ready-2 have come out, but yield is affected more by the variety

than the trait: “the yield of a crop is mainly determined by the seed’s intrinsic properties, not the

inserted genes” (Pollack 2010). Many farmers have been forced into buying seed with several

traits because they are the only seeds offered by companies to buy. The cost of the technology

failure rests primarily on the farmers.

Why is it important

Little information about the potential effects of GMOs on biodiversity has reached

farmers. Many farmers have heard something about the effects of Bt corn on Monarch butterflies

and the development of herbicide and pesticide resistance, but none of these issues seem to have

any particular merit. The common perception is that no conclusive evidence on negative effects

of GMOs has emerged. Although this has some validity, it is concerning that the potential

impacts on biodiversity were not more thoroughly understood.

Few people in the region who were questioned about genetically modified crops brought

up biodiversity without being specifically asked for information. Access to information and

sources of information are the dominant factors influencing perception of farmers. Ken Hill

(2011 personal communication) said he learns about GMOs on the Farm Show or at conferences

where herbicide, pesticide and seed companies present information on their products. Often these

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conferences are sponsored by these same biotech companies. Information is also received

through Cornell Cooperative Extension and word of mouth.

One farmer understands genetic modification as a process of speeding up the already

naturally occurring hybridization. This perception however, seems mislead. Although

hybridization does occur naturally, genetic information from drastically different organisms such

as a corn and a Baccillus bacteria is high unlikely to occur without human intervention.

Biodiversity is thought to be effected by the implementation of GM crops as well as the

secondary effects that come with cultivation of GM crops. Some of the effects on biodiversity

could have negative and long-term effects on agricultural systems. There needs to be more

knowledge of the impact of GM crops in order to avoid large-scale issues.

III. Identification of Stakeholders

The genetically modified crops industry spans many stakeholders that are affected in

some form by the modification of crops. Large producers and distributors are the structure of the

movement, while farmers and producers adhere to the system, in some cases benefiting and in

other cases becoming victims. Consumers are a stakeholder because they rely heavily on GM

crops as food to survive. There have been many speculations and studies about possible human

health effects related to GM crops. Consumers are unaware of what foods are or are not

genetically modified and therefore are at risk to possible health effects. Nature itself is also a

stakeholder in the paradigm shift towards genetic modification; however, there is no voice for

which it can speak. As a result, nature, or the modification and decline of it, is expressed through

the general public.

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In the North Country there are two main seed distributors that distribute mostly seeds of

herbicide tolerant crops and insect resistant crops: BourdeauBrothers and Dekalb Seed. They

typically buy from Monsanto, Dupont and Dow. Farmers in the North Country are growing

mostly corn and soy. The majority of these crops are harvested and used for feed for cows on

dairy farms in the form of grain or silage. Some farmers only grow the crop and sell it to feed

retail stores, while others are dairy farmers that grow their own feed corn or soy. Agriculture in

the North Country has seen a significant shift since the introduction of GM crops which affects

many different parties involved.

Producers and Distributors

The three main producers and distributors of genetically modified seed in the United

States are Monsanto, Dow and Dupont. Dow and Monsanto both participate in research and

design to create new genetically modified seed; however, Dupont buys seed directly from

Monsanto and acts as a distribution company; nonetheless, Dupont is still highly competitive

with Monsanto (2011 personal communication Scott Walker). Monsanto spends millions of

dollars every year on research to design the next genetically modified technology (2011 personal

communication Scott Walker). Other GM traits being studied are insect resistant apples, bananas

resistant to viruses from worm parasites, coffee with lower caffeine content, caterpillar resistant

cabbage, melons that will have a longer shelf life and sunflowers that will produce oil containing

a lower amount of saturated fat (Sakko 2002).

Large producers of GM seed in the United States are often more involved in the entire

system of the U.S. government and regulations than many people may know. Recently,

Monsanto and the United States Department of Agriculture (USDA) have been conversing over

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the implementation of GM alfalfa. Over 200,000 people submitted letters to the USDA

expressing concern about the new GM alfalfa crop, but the USDA still allowed the introduction

of GM alfalfa (Ludwig 2011). The USDA must write an environmental assessment (EA) for

each GM crops that is introduced in order to determine that the environmental effects are not too

large. Monsanto and the USDA were in such close contact about the EA for GM alfalfa that the

USDA simply accepted Monsanto research and pasted parts of emails Monsanto had sent to

USDA representatives into the EA report (Ludwig 2011). In addition, big companies such as

Monsanto will heavily support politicians that are going to support the market for GM crops; in

1999 the top 50 companies with agriculture or food patents spent over $572 million in political

campaign efforts (Ludwig 2011). With political support and USDA backing, biotechnology

companies have been able to take over seed market, as is evident in the North Country.

After communicating with some local distributors in Canton about seed distribution in the

North Country, it became clear that GM seed and crops dominate the crop production in the

North Country. Wight and Patterson, a feed producer and distributor for the St. Lawrence County

based in Canton, NY, described how they cannot buy corn that isn’t GM because it is simply

hard to find now (2011 personal communication Ellie Stripp). Many farmers have also expressed

that the transition to GM seed has become the new way of agriculture in the North Country;

some even suggest that in the next couple years 90% of at least the corn found in the North

Country will be GM (2011 personal communication Ken Hill).

Farmers

Genetically modified crops have revolutionized the way farmers perform agriculture and

how they manage their businesses. Although GM seed is generally more expensive for farmers to

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buy, conventional or non-GM seed it is harder to find. In many cases, even if a farmer truly

wanted to use conventional seed, it would be very hard to find it (2011 personal communication

Ellie Stripp). In the North Country, most farmers plant GM crops to sell to feed distributors or to

use for their cows in the dairy business (2011 personal communication Ellie Stripp). GM seed is

typically more expensive for farmers. One bag of Roundup Ready seed is typically $250 while

one bag of conventional seed is about $200 (2011 personal communication Steven Canner). GM

crops are more expensive because companies producing the seeds and creating the traits for GM

crops need skilled personnel and advanced technology to create new and update biotechnology

(Sakko 2002). The process of creating one traited plant can cost approximately $100 million

(2011 Scott Walker personal communication).

Most farmers using GM seed are willing to pay the extra cost because they believe it will

save them money somewhere else. Farmers see savings by using less insecticide or herbicide use

or the biotechnology will produce a higher yield and increase their profits (2011 personal

communication Steven Canner). Some farmers have seen a 4-11% increase in their yields, a

factor of 10 more bushels per acre (2011 personal communication Scott Walker). Ken Hill, of

Farmer to Farmer Feed, said that he has seen an increase in yield during some harvests once he

started planting GM crops (2011 personal communication Ken Hill). Ken also said that GM

crops have done better than conventional crops during large weather event years (2011 personal

communication Ken Hill). Crop yield can be unpredictable independent of the seed planted,

making the benefit of GM crops uncertain on a continuous basis (Hillyer 1999). Some farmers do

wonder if the cost of GM seed is worth it since yields can vary in any given year and it may not

be a result of planting GM seed (Hillyer 1999). Additionally farmers are concerned about weed

and insect resistance and consequential rapid decrease in yields (Hillyer 1999).

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GM crops have cause both positive and negative changes in chemical usage;

theoretically, technologies like Bt require less pesticide use therefore reducing exposure to toxic

chemicals and decreasing energy and labor costs with fewer trips to the field. GM crops have

decreased the use of insecticides by a total of 64.2 million pounds since their widespread

distribution in 1996 (Natural Biotechnology 2010). Decreased pesticide often means practices

are more environmentally friendly (Hillyer 1999) and ultimately better for farmer and farm

health. While decreasing trends in insecticide use seem significant, an opposite trend was true

with herbicides: there was an increase in herbicide use of 383 million pounds since 1996

(Natural Biotechnology 2010). Most of the new biotechnology is also easy and convenient to use

because farmers have used herbicides such as Roundup before and know what to expect with

weed resistance (Hillyer 1999). The widespread use of large quantities of Roundup may set the

stage for possible weed resistance or super weed development. Weed resistance and the need for

an increase in more herbicide spray (Natural Biotechnology 2010) would be costly to farmers.

There are other aspects of GM crops that many farmers are continuing to question. For

plant pesticides GM crops it is hard to predict how heavy insects will be each year; buying GM

crops with insect resistance could be an added expense if it isn’t something they truly need

(Hillyer 1999). It is also hard for farmers to find GM crops specific to what they need. Most GM

seeds are stacked with other traits that may not be relevant for the farmers’ region, environment,

or needs (Hillyer 1999).

Each GM crop that contains traits has been patented by the biotechnology company that

created it. Farmers therefore are no longer allowed to save their seed after the harvesting season

(2011 personal communication Steve Canner). This is an additional cost for farmers who must

buy new seed every season in order to avoid lawsuits (2011 personal communication Steve

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Canner). There are examples of these sorts of lawsuits in many Canada and the United States,

where farmers are at the mercy of large biotechnology companies.

Although there are no known law suits in the North Country against farmers for patent

infringement, the risk of violation does exist. Farmers using GM seed are not permitted to save

seed for the following year, even if they pay for the patent (2011 personal communication Scott

Walker). The 35 U.S.C. 163 Grant (United States Patent and Trademark Office ) allows

developers of hybrids and biotechnology “the right to exclude others from asexually reproducing

the plant, and from using, offering for sale, or selling the plant so reproduced, or any of its

parts.” Growers of patented sees must buy new seeds each year, if they save seed and re-grow it

the following year they can be sued by biotechnology companies (2011 personal communication

Ken Hill).

It is uncommon for farmers to save corn seed because most all of the corn on the market

is an F1 hybrid variety. However, farmers in the North Country have still saved soybean and

canola seed in the past decade. But, because most of the soybean grown in the region is

genetically modified seed savings is rarely practiced. Farmers must sign an agreement with the

biotech companies pledging to not violate patent rights by saving the seed. The individual

farmers have lost sovereignty as continue to patent seed. Large biotech companies have taken

several steps to ensure farmers do not save seed. Along with legal actions, Monsanto has had

large campaigns to purchase seed cleaners to make the tools necessary to save seeds unavailable

(2011 personal communication Bryan, Bourdeau Brothers). A local farmer and seed salesman

put it, “Who controls the seed controls the power” (2011 personal communication Bryan,

Bourdeau Brothers).

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The risk of genetically modified crops contaminating conventional crops is great. This

can have practical and legal implications. In Ogdensburg, a 15 acre organic corn field was

situated between two Roundup Ready corn fields owned by another farmer. The application of

Roundup by the commercial sprayer was accidentally administered to all three fields.

Surprisingly over 40% of the organic corn survived the potent defoliant spray (2011 personal

communication Ellie Stripp).These unexpected results suggest the organic corn had crossed with

Roundup Ready variety and acquired some of its herbicide-resistance. If the farmer was actually

growing a Roundup Ready corn without having purchased the patented seed, he was in violation

of patent rights and liable to the biotech. company for patent infringement. Additionally the

farmer’s organic crop was contaminated with the cross-pollination of a genetically modified

variety. This contamination would void any attempts for the corn to be sold as organic. Clearly

there are many complex forces that affect farmers as a stakeholder in the issues surrounding

genetically modified crops.

Consumers

Consumers of food made from GM crops are also an important stakeholder in the

production of GM crops. Currently, 60% of the food in US grocery stores contains GM crops

(Sakko 2002). In addition, GM food in grocery stores is not labeled and there are no laws or

regulations about labeling in stores (Konig 2004 and see below). Genetically modified crops

have been incorporated into the diet of all people without them knowing and without

understanding the possible effects of this change. The negative effects of GM crops may not only

be limited to the environment, but also affect the health of humans consuming them.

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In 2009 the American Academy of Environmental Medicine (AAEM) released a report

outlining its position on genetically modified crops. It reads: “GM foods pose a serious health

risk in the areas of toxicology, allergy and immune function, reproductive health, and metabolic,

physiologic and genetic health” (Dean and Armstrong 2009). A study done on the effects of three

types of GM crops on rats, found a significant decrease in kidney and liver functions (Spiroux de

Vendomois et al. 2009). The kidney and liver are both organs that facilitate detoxification in the

body; reduced function of these organs could have harmful effects on the human body (Spiroux

de Vendomois et al. 2009). The effect of GM crops on rats varied according to the GM crop, the

sex of the rat, and the dose of the GM crop (Spiroux de Vendomois et al. 2009). Effects of GM

crops NK 603, MON 810 and MON 863 (Bt resistant) were more prevalent in males than

females, but significant physiological effects were found for all three GM crops (NK 603, MON

810 and MON 863) for both sexes (Spiroux de Vendomois et al. 2009). Each of the crops tested

was genetically modified to resist a different herbicide.

In females, MON 810 was found to the affect blood cells, adrenal gland, increased kidney

weight, increased spleen weight, and increased blood urea nitrogen (Spiroux de Vendomois et al.

2009). Mon 863 created a significant increase in glucose and triglycerides, an increase live and

overall body weight, increased creatinine, blood, urea nitrogen and urine chloride in females;

some of the effects were up to 40% (Spiroux de Vendomois et al. 2009). Creatinine is a waste

molecule created by muscles throughout the body and is filtered out by the kidneys; creatinine is

often used an indicator to detect kidney health. Increasing levels of creatinine in the blood

means that the kidneys are failing or malfunctioning.

In males, similar physiological disturbances occurred with each of the GM crops. The

largest significance of effects were recorded in male kidney changes including a decrease in

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kidney weight, a decrease of blood creatinine and a decrease of blood urea nitrogen (Spiroux de

Vendomois et al. 2009). A decrease in blood creatinine can be attributed to muscle problems,

which if persists can affect the heart (Spiroux de Vendomois et al. 2009). This is a sign of renal

leakage, which may be a result of residue herbicides on crops eaten by humans (Spiroux de

Vendomois et al. 2009). Previous studies have shown that herbicide, such as Roundup are

extremely toxic to humans even at low concentrations and target the kidney cells (Spiroux de

Vendomois et al. 2009).

Studies on the effects of GM on mammalian health have only been done for three months

or less and there have been significant physiological effects on vital organs and changes in the

natural bodily processes. If negative effects are shown after short term ingestion of GM crops,

there may be an even larger effect with long-term ingestion of GM crops. Overall, studies have

shown significant effects on kidney and liver function due to GM crops and some effects on

heart, adrenal, spleen and blood cells have also been noted (Spiroux de Vendomois et al. 2009).

There are few studies on the effect of GM crops on mammalian health, but the studies

that have been done show serious risk. There may be other harmful effects of GM crops to

human health that have not been discovered yet. Overall, there is little known on the health

effects of GM crops; consumers may be unknowingly ingesting foods that will have long-term

detrimental effects on their health.

IV. Governmental Issues

The three main governmental organizations responsible for regulating the use of

genetically modified agricultural products in the United States are the U.S. Department of

Agriculture's Animal and Plant Health Inspection Service (USDA-APHIS), the U.S.

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Environmental Protection Agency (EPA), and the Department of Health and Human Services'

Food and Drug Administration (FDA).

In 1986 the US Federal government developed a “Coordinated Framework for Regulation

of Biotechnology” based on health and science measures, to guide national regulation and policy

(U.S. Regulatory Agencies Unified Biotechnology Website). Within the one hundred and

twenty-three page report there is not mention of weed resistance or biodiversity (Coordinated

Framework for Regulation of Biotechnology). Although the framework mentions unanticipated

environmental risks and consequences, it ultimately strived to “achieve a balance between

regulation adequate to ensure health and environmental safety, while maintaining sufficient

regulatory flexibility to avoid impeding the growth of an infant industry” (Coordinated

Framework for Regulation of Biotechnology). The priorities of the framework seemed to lie

more in protecting the growing industry than in limiting risk.

The working group responsible for the report concluded that current regulation on already

existing genetic modification techniques, such as hybridization (and not gene insertion) would

often be sufficient to address concerns; the group encouraged the three agencies charged with

regulating GMOs to take this perspective (Marden 2003). Overall, the framework reflected a

product-based approach which outlined the ability for existing policies to suffice in regulation of

genetically modified crops. The framework emphasized a risk-based approach rather than a

precautionary approach (Marden 2003). The principles of the framework - which are reflected in

the actions of the USDA, EPA, and FDA- encourage management that may have serious

implications for protections of biodiversity in agro-ecological systems.

The Food and Drug Administration (FDA)

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The Food and Drug Administration (FDA) monitors the safety of all domestic and imported

food as well as monitoring for EPA-regulated pesticide levels. In 1999, James Maryanski, the

Biotechnology Coordinator for the FDA testified to the Subcommittee on Basic Research and

House Committee on Science regarding the FDA’s regulation of genetically modified foods.

According to Maryanski, GMOs had to “adhere” to the same FDA standards as conventional

foods (Maryanski 1999). Because there was no significant evidence that genetically modified

foods were harmful to the consumer, the FDA deemed current regulations of conventional

varieties appropriate.

In 1992, the FDA released a “Statement of Policy: Food derived from new plant varieties” in

which it concluded that labeling of genetically modified foods was not necessary unless the

composition of the food was changed significantly or the GM food contained a potential allergen

(Marden 2003). Because GM foods subscribe to neither of these conditions, they have remained

unlabeled and the FDA considers them Generally Recommended As Safe (GRAS). Furthermore,

the FDA prohibits any labeling that would mislead consumers to believe a product is something

that it is not (FDA Plant Biotechnology for Food and Feed). For this reason, the agency along

with many biotechnology companies have prevented labeling of genetically modified foods that

might indicate to the consumer that the food poses a health risk. Voluntary labeling of GMOs is

permitted in the United States, but cannot suggest that GMOs are any different or pose a health

hazard. For the FDA, the hazard must not outweight the cost of restricting GMOS.

Some scientists and doctors disagree with this claim and believe there should be an

immediate moratorium on GMOs (see Stakeholders; Dean and Armstrong 2009). If the FDA

were to decide genetically modified foods was harmful to consumers, it has the power under the

adulteration section of 402 (a) (1) of the Federal Food, Drug, and Cosmetic act to remove the

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food (FDA Plant Biotechnology for Food and Feed). Already, “pre-market clearance is required

if there is scientific uncertainty about the safety of food derived from bioengineered plants”

(Maryanski 1999); but there is no indication of how uncertainty is determined. Estimates of risk

are left up to the agencies to decide under existing criterion.

Environmental Protection Agency

In accordance with the Coordinated Framework, the EPA decided that existing regulatory

policy of the Federal Insecticide, Fungicide, and Rodenticide Act (“FIFRA”) was sufficient for

GMOs (Marden 2003). Bt corn, for instance, was treated like any pesticides and required

registration. The registering party must show that widespread use will not cause harm to humans

or the environment. The agency requires a pre-market test which is limited to use in the field and

does not require testing for long-term potential ecological effects (Marden 2003). In these cases,

the registering parties are the companies developing the biotechnology and have a tremendous

amount of resources to fund research (2011 personal communication Scott Walker). If

companies are applying for registration they will clearly do everything in their control to show it

is safe. As a result the EPA has truly embodied the risk-based approach rather than a pre-

cautionary one (Marden 2003).

After receiving criticism that FIFRA did not sufficiently address GMOs, the EPA formed

the Plant-Pesticide Act in 1994 to identify the GM crops that the EPA would regulate with more

scrutiny. Under this Act, the EPA defined a plant pesticide as a “pesticidal substance that is

produced in a living plant and the genetic material necessary for the product of the pesticidal

substance, where the pesticidal substance is intended for use in the living plant” (Marden 2003).

Although this seemed to be a step toward stricter regulations, weakness stems from the Agency

allowing a long list of exemptions.

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Many critics argued that exemptions allowed by the EPA have softened their already

weak regulations and the scope of the EPA on GM plants is too narrow (Marden 2003). In the

mid-90s independent research emerged that showed hazardous effects of Bt corn on non-target

species. As a result in 1999 the Environmental Defense Fund asked the EPA to regulate a 60 foot

buffer zone to protect monarchs from Bt corn pollen (Environmental Defense Fund. 1999). The

request was denied, but in a response to growing criticism, the Agency did mandate a 20%

refuge crop requirement starting in 2000. In an attempt to mitigate effects on non-target species

and slow the development of Bt resistant insects, this mandate required farmers to plant 20%

conventional seed along with their GM crops (Marden 2003). The enforcement of refuge is

limited and in St. Lawrence County many farmers may avoid planting the refuge (2011 personal

communication Stephen Canner).

The EPA seems to recognize gaps in the understanding of threats to non-target species

but continues to allow for its widespread use. The agency is trying to research the long-term risks

of GM crops; however, “sensitive methods to evaluate exposures to non-target organisms and the

long term populations effects are lacking” (EPA 2006). In 2006, 10 years after GM crops were

commercially introduced, the EPA was recognizing the potential for threats of Bt on non-target

species and wrote, “as new varieties of Bt-crops are commercialized…the impact…on beneficial

or desirable insect species…needs to be determined” (EPA 2006). The EPA is still developing

methods for evaluating and decreasing the ecological risks of GM crops, yet the agency has

readily approved its widespread implementation over the past 15 years. This approach clearly

coincides with the coordinated framework of a risk-based rather than precautionary approach.

This approach is not proactive enough to prevent the threats to biodiversity and may allow for

longer-term, widespread ecological effects.

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New York Department of Environmental Conservation

There are state-wide agencies that can alter the EPA’s regulations to make them more

strict and tailored to state-specific problems. In New York State, the DEC regulates pesticide

use, enforces NYS pesticide laws and is responsible for assisting the public with compliance.

Pesticide products are first registered with the EPA who performs chemical reviews and

considers environmental impacts (to the extent shown above). Often times New York state’s

regulations are more restrictive (2011 personal communication NYDEC).

The DEC does not enforce any specific regulation for glyphosate or other ingredients in

Roundup products. Although recent studies have shown negative effects of glyphoste on aquatic

ecosystems (Hileman 2005, Kelly et al. 2010, Springlett and Gray 1998, Santos and Flores 1995)

glyphosate remains a non-restricted pesticide. Commercial applicators do still need to follow

general DEC rules and regulations of pesticide use, and Roundup is prohibited for use in aquatic

systems. But, there has not been a recent review of glyphosate by the DEC because it has been

registered for a long time (2011 personal communication NYDEC). Pesticides only have to be

(re-)approved for use by the DEC if they are new, if there has been a major change of labeling or

new active ingredient (Pesticide Product Registration- NYDEC). The DEC makes registration

decisions within 180 days of the request. Requesting parties have gone through this process for

Bt products – all of which has been reviewed and registered with the DEC. Along with

glyphosate, the EPA and DEC have deemed Bt products safe and they remain unrestricted for

use.

United State Department of Agriculture and Plant Health Inspection Service

The USDA’s Animal and Plant Health Inspection Service is responsible for testing new

genetically modified varieties prior to cultivation in fields. The Department has remained in line

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with the 1986 coordinated framework and decided GM crops would be regulated under existing

Plant Pest Act. The Department’s responsibility to regulate GM crops conflicts with interests of

sub-groups within the organization. The Agricultural Research Service and the Agricultural

Market Service are branches of the USDA who promote the development of biotechnology

(Marden 2003). The department should balance this promotion with caution as to protect

agricultural landscapes; however it has tended toward lenient regulation. Since 1987, the Dept.

has received 11,600 applicants, including 5,000 of which were for corn. Ninety-two percent of

the varieties -including Bt varieties- were approved (USDA Repot). During this application

process, the applying party performs field tests and clarifies that the plant meets the

Department’s safety criteria. This highlights another possible weakness in the USDA’s

regulatory policy. Basing decisions off applicant’s studies may have resulted in bias in the

registration process.

In 1992 the USDA began to allow some GM plants to be grown without permits or

notification processes. The “non-regulated” plants referred to plants that were not “plant pests”

and as a result did not need to be regulated by the USDA (Marden 2003). A 1997 modification

allowed plants of close relation to “non-regulated” species to be exempt from the permit

application process and qualified them for the abbreviated petition process (Marden 2003).

Companies applying for plant permits could then enter into an abbreviated and expedited process

if the plant applicant met all of the six criteria. Exemptions for corn, soy, and cotton – three of

the most widespread genetically modified crops – were frequent assuming they met the other

requirements (Marden 2003).

Skepticism grew about the effectiveness of the USDA’s APHIS policies. In 2002 report by

the National Academy of the Sciences (Committee on Environmental Impacts Associated with

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Commercialization of Transgenic Plants 2002) said that the APHIS’s assessment of the effects of

GMOs on non-target organisms and pesticide resistance was “generally superficial” (Committee

on Environmental Impacts Associated with Commercialization of Transgenic Plants 2002). The

report went on to criticize the agency needs to have more rigorous tests and transparency. It

recommended that the screening process for applicant plants must be more thorough. The

agencies overseeing the regulations on GMOs have “shifted to a more risk-based

policy…[meaning] a smaller regulatory burden from companies moving forward with GM

products” (Marden 2003).

In support of genetically modified crops the USDA states “[it] is confident that

organisms altered through genetic engineering will play a major role in increased plant yield and

improved plant quality” (Coordinated Framework for Regulation of Biotechnology). The Dept.

has taken measure to ensure farmers can afford GM crops. The USDA financially supports

farmers growing field crops through its subsidy program. Both corn and dairy farmers

nationwide receive subsidies from the USDA. In St. Lawrence County from 1995-2009, 829

dairies received subsidies totaling over $23 million (Figure 1)(EWG 2009). During that same

period, 452 corn farmers received $17.5 million in subsidies (EWG 2009). In 2009

approximately 1 million dollars in subsidies was given for corn in St. Lawrence County (EWG

2009). With 70% or more of the corn grown in the County genetically modified, the USDA is

indirectly a large financial supporter of GM crops. As farmers continue to depend on subsidies

for production of GM crops, and the USDA favors GMOs as an asset to US agriculture, there are

will certainly be difficulties addressing the uncertain risk genetically modified crops pose to

biodiversity.

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V. Development of Solutions to the Problems

Parameterizing solutions

Because GM crops have only been around for a short period of time, it is hard to

understand the possible ecological and human health effects of their widespread cultivation.

Although GM has not been in production long enough to establish concrete evidence of any

positive or negative effects, there are thought to be potential risks to humans and biodiversity

through the long-term production of GM crops (Spiroux de Vendomois et al. 2009). While many

of the potential health and environmental effects of GM crops have not been widely accepted, the

speculated increased yields, benefits to farmers, and decreased chemical usage have also not

been widely accepted. The debate on genetic modification in agriculture has valid arguments for

both sides making it hard to determine what the problem and solutions are. For scientific reports

that have proven GMOs to have significant health effects in mammals, Monsanto, or other

biotech companies, have returned with equally persuading papers that determine the opposite.

The same is true for potential biological issues.

In order to determine a solution to the current status of GM agriculture in the North

Country, regulations and knowledge of GM crops needs to be more strict and widespread. Since

GM is already a widespread practice in the North Country, a successful solution must work

within the present situation of GM agriculture while applying new parameters that will start to

remedy certain problems. Ecological and human health risks must be addressed in solving the

problem. The strong influence of biotech companies and the lack of regulations of GM must also

be addressed in the solutions to the problem.

Ecological risks of GM agriculture that must be addressed to solve or reduce the

problems such as habitat fragmentation, gene escape, hybridization and effects of synthetic

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chemicals on biodiversity and ecosystem services. The social and economic factors of GM

agriculture must also be addressed in order to solve the issued surrounding GM technology

including increased costs to farmers and reliance on large biotech companies while risking

possible patent infringements. A solution must also include limiting the power of biotech

companies in order to reduce their manipulation of other stakeholders and lower their influence

in the agriculture market.

Identification and evaluation of potential solutions

1. Reduce reliance on GM crops

Genetically modified crops are already extremely widespread within the North Country

with about 70% of corn alone that is planted is GM (2011 personal communication Stephen

Canner). In the North Country, many farmers are planting GM crops that are used for feed for

cows in Dairy Farms (2011 personal communication Ellie Stripp). Farmers could switch diets

given to cows so that they are fed on grass instead of grain feed that is dependent on the

production of GM crops. Cows were not biologically constructed to metabolize and digest grain

at the rate and amount in which large scale dairy farms are feeding them; they often suffer from

health issues and do not live as long (2011 personal communication Ray Hill). Jon Greenwood,

owner of the biggest Dairy in the North Country, says that his cows have a lifespan of about 5

years (2011 personal communication Jon Greenwood); whereas, at Windy Ridge organic dairy

some of their cows live up to 15-20 years (2011 personal communication Ray Hill). If farmers in

the North Country transition cows to a grass fed diet, the dependence on GM crops will decrease

and cows will likely live longer, healthier lives.

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2. Mandate buffer zones to fields with GMOS

Research has shown that aquatic ecosystems within 500m of GM farms can be vulnerable

to toxic pollution due to runoff from chemicals, especially the Cry1Ab protein from Bt modified

corn (Tank et al. 2010). Figure 5 shows vulnerable aquatic ecosystems in St. Lawrence County.

There are many aquatic ecosystems in the North Country that are within 500m of GM crop

fields, including the Grasse River. Figure 5 shows what ecosystems are vulnerable to pollution

within 500m of GM farms. In order to protect these vulnerable ecosystems, legislation should be

implemented to create a minimum of a 500m buffer to separate farms using GM crops and

designated potentially vulnerable aquatic ecosystems. In order to avoid cross pollination and

contamination of crops on organic farms, there should all be a required 500m buffer between

GM farms and organic farms.

3. Diversify crops planted on farms

Genetically modified crops in the North Country usually mean monocultures of one

pa