¶
¶”We have to remember that what we observe is not nature in itself, but nature exposed ¶to our method of questioning.” – Werner Heisenberg, Nobel Prize winner in physics

¶Dear Presidential Candidate:
¶
¶Thank you for taking the time to read my thoughts on these issues. I am active in legislative and regulatory affairs in the food industry. In addition to regulatory and legislative meetings, I interact with farmers, processors, and consumers daily, and thus have had thousands of conversations regarding these and other related issues over the past several years. I am well aware of, and can successfully articulate, all points of view on genetic engineering and its associated agricultural systems. While you will indeed see a clear point of view in my comments, I implore you to consider them carefully as accurately representing a consistent and strengthening reluctance by the public to accept the current regulatory framework under the Coordinated Framework. My comments are not couched in gentle language, but they are sincere. We have created a great disconnection between the government and the people on this issue. Below I offer my thoughts on how this occurred and how, in turn, it might be fixed.
¶
¶The “Coordinated Framework” refers to the responsibility shared by the FDA, EPA, FDA, and related agencies to ensure that biotechnology, as applied to agriculture practices and food products, conforms with the requirements of statutes such as food safety, environmental pollution, and toxic substance control. Biotechnology refers to set of new innovations, such as artificial genetic mutation, which have become a key innovation with which corporate global conglomerates are broadening their reach into the food system across the globe and deepening their control – technologically, financially, politically, and socially – into the social fabric.
¶
¶In theory, the Coordinated Framework was intended to “promote public trust” in the regulatory process, biotechnology research, and commercialized crops. Even the casual observer can see that it has failed. A closer look would confirm that this intention was merely rhetorical. The legislative, executive, regulatory and industry participants continue to express genuine surprise and dismay at this outcome. Comments from the official participants rue the inability of the public to “understand the science,” assuming that if only the public were able to do so its members would reach the same conclusions and policy trajectories of those inside the process. The logic of this self-serving narrative belies the single greatest weakness of the Coordinated Framework. It appears to many public observers that the Coordinated Framework was built from the beginning to be a cooperative effort between government and industry to promote industry’s interests, the scientific and regulatory complexities of which were presumed to be the only truly significant topic within the debate, and simultaneously to lay outside the public’s ability to comprehend or weigh effectively. The institutional prejudice against public contributions to the process led official participants to disregard meaningful and thoughtful public contributions. It is no wonder that the public feels disrespected and marginalized by the results of the Coordinated Framework.
¶
¶We need a truly public forum based on both science and values
¶
¶The basic scientific truth regarding genetic engineering is not difficult for the public or anyone else to understand. Genes are intimately and complexly interrelated with each other and interact together to express different traits and behaviors in the organism of which they are a part. These traits and behaviors react and respond to their environment over time. Changes in genetic traits and behaviors, including those caused by environmental impacts, may be passed on to successive generations. Based on my personal experience, I would venture to state that the majority of Americans can articulate these factual statements when properly prompted.
¶
¶The trope of sound science
¶
¶As the public discomfort grows about the exclusion of the public’s voice, the public attempts to put up barriers to implementation of artificially mutated crop commercialization approved through the Coordinated Framework’s self-dealing processes. Internal stakeholders respond in predictable ways. The Coordinated Framework falls back on the doctrine of “sound science,” claiming that “sound science” will resolve all the problems, known and unknown, expected and unexpected, that are an inherent result of artificial genetic mutation. Artificially mutated crops, both existing and imagined, were and continue to be imbued with glowing mythological properties such as curing disease, thwarting drought, reducing pesticide use, and improving soil conservation. However, these traits remain mostly theoretical, if not disproved outright using readily available scientific evidence. This discredited scientific mythology remains today the oft-repeated rationale for agricultural systems built on artificially mutated crop varieties.
¶
¶I argue that precisely because Americans do understand “sound science” that they have lost trust in the Coordinated Framework. In essence, the Coordinated Framework has gingerly circumvented sound science because that is what it was designed for. For instance, applicants for approval of novel artificially mutated traits do not have to disclose the disadvantageous outcomes of their tens of thousands of failed attempts; nor do they have to address potential future mutations within the artificially mutated organism. The Coordinated Framework summarily dismisses consideration of potential novel interactions with other organisms in the environment or with nutrients in food. Moreover, how this technology may affect a farmer’s life, liberty and pursuit of happiness never even enters the conversation.
¶
¶A coordinated framework for a sustainable future
¶
¶When as a candidate you state that farmers need artificial genetic mutation to create drought resistant crops to feed the world, you are stumbling through pseudo-scientific gibberish your handlers have not properly vetted. It makes you sound daft. Drought tolerant traits are indeed important, but they are not germane to artificially mutated genes. Drought tolerant genes are found in nature where plants have faced drought and self-selected to meet that challenge. Rather than feeding the world, artificial mutation technology identifies those drought tolerant traits and sequesters them in proprietary genomes so they cannot be used without paying a technology fee and applying proprietary herbicides in a monoculture planting program. This is what a world experiencing climate change absolutely does not need. We need drought tolerant traits to be openly shared and bred with all manner of locally appropriate crop varieties. Your political platform misunderstands the role of drought tolerant traits. You elevate genetic engineering as a useful technology, but your example is how it reduces crop resilience and food security. Trait sequestration is an example of how artificial mutation technology can be deployed to the world’s detriment. You evangelize for it when you should call it into question.
¶
¶Similarly, the world needs to be fed, but by and large other countries need to find appropriate ways to feed themselves. Their growing dependence on imported food from petroleum-dependent crop systems is not sustainable or desirable. When as a candidate you represent these corporate talking points as scientific imperatives, and lazily incorporate them into your policy platform, you lose the confidence of voters. Biotech industry handlers at your campaign event smile smugly while standing along the back wall of the senior center. They pat you on the back and say, “Great job, Chief. Very presidential,” then dial their handlers and approve another PAC payment to your campaign. But your place in the history of democratic public policy settles lower, and lower, and lower.
¶
¶Democratic values still matter
¶
¶The most important challenge to better understanding the Coordinated Framework is to recognize that it will continue to fail to promote the public trust if it continues to fail to address the values of our citizens. The Declaration of Independence does not refer to an “inalienable right to economic benefit from scientific innovation at any expense to society.” The Declaration enjoins our government and citizenry to ensure life, liberty, and the pursuit of happiness for everyone. Basing the Coordinated Framework solely on whether the “science” is “sound” is a fundamental misreading of our government’s charter. Science is notorious for being wrong, for being manipulated and suppressed, and most importantly, for being poorly equipped to measure whether a particular technological outcome supports the pursuit of happiness. On the contrary, the scientific record shows a long history of inventions and discoveries that may have created economic activity and wealth for their corporate sponsors, but at far greater long-term cost to the public good. Leaded paint and gasoline, PCBs, DDT, Tobacco, and Agent Orange were (and sometimes still are) stridently defended as safe by persons purporting to use “sound science.” Sound science driving the pharmaceutical industry results in over 100,000 deaths each year from properly approved, prescribed, and administered drugs. Sound Science promulgated without transparent democratic evaluation of the consequences of a technology may be science, but it is not sound.
¶
¶Reversing the course of industrial chemical agriculture
¶
¶The Coordinated Framework fails as an instrument of government intervention in the social economy because it fails to address broader considerations such as equitable access to economic opportunity, rural development and vitality, conservation, and ecological sustainability. The Coordinated Framework is able to dismiss this line of thought because it lies outside of the statutory or regulatory purview of the participating agencies and the directives they received from Congress and the administration. We cannot, however, prioritize the promotion of the public trust without also addressing how artificially mutated crops, in tandem with an institutional preference for centralization and industrial efficiency, continue to undermine the health and resilience of our national community.
¶
¶In the recent US Senate hearings on GMO labeling, this misguided framework culminated in a mockery of science. The heads of the FDA, EPA, and USDA each ended their testimony by turning their mouths down to one side, the classic face of someone whose real thoughts have been left unspoken. The hearing was orchestrated to create the illusion of public trust by presenting only points of view that support GMO technology and would prefer to ban GMO food labeling. Erroneous information was stated as fact. Opinions were stated as scientific conclusions. Complexity was presented as simplicity. The values of the public were specifically marginalized under the false rubric of “sound science.”
¶
¶So, you want to feed the world?
¶
¶The depth of the stakeholder’s unquestioned ideological position is best represented by the doctrine that food will solve the impending population growth crisis. One would be hard pressed to find a respected expert in population growth to endorse the idea that doubling food production will address all the problems resulting from the doubling of the world population. Typically, population experts point to land reform, urbanization, public health and epidemics, wealth distribution, access to water, climate change and various other factors. Food is rarely mentioned as a key limiting factor in and of itself. Yet, inside stakeholders supporting the Coordinated Framework consistently bring up the specter of dangerous and hungry dark-skinned people and summarily state that genetic engineering is the only agricultural cropping method up to the task of feeding them (and implying, presumably, keeping them out of North America).
¶
¶The usefulness of employing the mythology that artificially mutated food will solve world hunger is particularly suspect because private investments in artificial mutation technology have never been intended to increase yields. A review of statements by entities such as the National Academy of Science demonstrates a consensus that artificially mutated cropping systems do not necessarily increase yields compared to other methods of plant breeding and cultivation. To the observant public, this prevailing consensus regarding the limited yield benefits of artificially mutated crops is self-apparent because the science is straightforward: plant growth is constrained by the availability of soil nutrients, water, and sunlight. Artificially mutated cropping systems use crop varieties that are dependent on and responsive to predetermined amounts of required inputs of fertilizer and water. Thus coddled, artificially mutated plants may produce well, but they produce no better than other crops with locality-specific genetic responses planted in healthy soils using natural pest controls. To the observing public employing the facts and logic of the scientific method, the cost/benefits trade-offs are clear. We can grow cloned artificially mutated crops in carefully controlled environments using chemical amendments and herbicide weed control, or we can grow naturally bred site-specific crop varieties that do not require dependence on non-renewable fossil fuels and toxic chemical applications. That the policies resulting from the Coordinated Framework reject this science exposes the possibility that the Coordinated Framework in its present form was constructed intentionally to circumvent and suppress it.
¶
¶Similarly, the technological ideology underpinning the Coordinated Framework reflexively affirms that artificially mutated crop systems will solve public health challenges, improve soil conservation, reduce toxic chemical use, and hold assorted other magical powers. Each of these claims can at least be debated using the scientific historical record. Yet, the ideology has established the idea of a “scientific consensus” among insider stakeholders. While there is no reason to question the sincerity of this particular belief, it remains merely a belief. Facts are few, evidence is thin, and propaganda abounds. From the perspective of the observing public, the ideology of artificial mutation raises a simple question. If we have natural and organic agricultural systems that are known to protect health, reduce fossil fuel consumption and eliminate toxic substances altogether, why are we investing so heavily in a novel crop system that clearly fails to deliver on these critical measures?
¶
¶Curtailing our future prospects?
¶
¶Moreover, the design, requirements and implementation of GE cropping systems often involve practices and technologies that will permanently end our ability to use existing natural systems. Herbicide tolerant artificially mutated alfalfa is just one salient example. As a self-propagating and environmentally competitive plant, it is likely to overtake and permanently contaminate all natural varieties of alfalfa. Likewise, genetic drift from other artificially mutated plants is known to contaminate nearby similar domestic and wild crops. Furthermore, over-spray and drift from herbicide application is a constant threat to non-mutated crops. The disruption and de-funding of non-mutated seed trait research prevents conventional and organic crop growers from improving their own systems. These problems may have been discovered in the bright light of “sound science” but to the skeptical public they seem very dark indeed.
¶
¶As public disappointment grows with the results of the current Coordinated Framework (as demonstrated by state and national efforts to protect non-artificially mutated crops from encroachment by artificially mutated genomes and efforts at all levels to require labeling of artificially mutated foods) the Coordinated Framework inside operatives appear bewildered that their ideology is not universally accepted and admired by the public. Because the Coordinated Framework is ideologically biased, rather than scientifically founded, these same internal stakeholders have responded with seemingly religious fervor to defend their beliefs. The biotechnology lobby has proselytized the media, regulators, legislators, and members of academia. Non-believers in genetic engineering are heretics to be converted or excoriated as anti-science fear mongers.
¶
¶Our strange national obsession with innovation
¶
¶In more general terms, the ideology of innovation championed by the Coordinated Framework accepts as sacrosanct the idea that novel technologies are better than existing technologies — until proven otherwise. The burden of proof is not on the innovator. Those negatively affected by the technology must both disprove its value and its potential for harm. Internal stakeholders working within the Coordinated Framework should take heed that not all technologies result in public good or are even proven useful.
¶
¶Alfred Nobel is a prime example of classical scientific inventor whose technology, nitroglycerin, proved both extraordinarily helpful and disastrously harmful to humankind. Observing how his explosive introduced new horrors and degradations during the Great War, he spent his fortune and the greater part of his life attempting to elevate mankind’s memory of his contributions towards the positive and uplifting. When ideologies are publicly criticized, as is the case with the faith in the benefits of genetic engineering, true believers often create ever greater Golden Age mythologies. Artificial mutation is our salvation! These tragic narratives set up the innovation ideologue as the victim, thwarted by the ignorant public. Citizens become villains who are preventing Science from attaining its Glorious Progress. Unfortunately, progress through science is rarely glorious. The scientific method is haphazard and full of blind alleys in the best case. In the worst case, discoveries are rushed to market outside of proper regulatory oversight to great public harm.
¶
¶Strangely enough, the consequence of the surrender to innovation and profit that underpins the Coordinated Framework on biotechnology parallels the history of an earlier technology: nitroglycerine. Governments and corporations used high explosives to build global political and economic empires through war and capture of key resources like oil and water. It should not be surprising that it is often the same exact corporations that profited from the global arms race that are today deploying artificial mutation technology to achieve similar nefarious ends.
¶
¶The public, observing the results so far of the Coordinated Framework, have a number of other disturbing parallel historical examples to draw from. Poisonous lead used in gasoline, paint and industrial processes was allowed in commerce for one hundred years despite vocal opposition from individual scientists within the federal regulatory bodies since the early 1900’s. Indeed, not until 2008 did the federal government finally outlaw lead in children’s toys. DDT, PCBs, and other novel chemicals were recognized as safe by federal regulators for decades before public interest groups forced their removal from the market. Notoriously, as recently as 1998 Congress continued to invite testimony from scientific witnesses who stated that tobacco was safe, and that smoking did not promote cancer.
¶
¶Regulatory theater?
¶
¶The makeup of the witness panel and the content of the testimony of the recent US Congress’s GMO labeling hearings raised the specter of lead, tobacco, DDT, Agent Orange, and other substances for the American public. The only reasonable conclusion to be reached by the observing public is that the other shoe will drop on artificial mutation sooner rather than later. It was telling that nearly simultaneously to the testimony in the US Senate, the World Health Organization and the State of California officially declared glyphosate a potential carcinogen. So, the question posed by the Senate Agriculture Committee to the administrators of the FDA, USDA and EPA was painstakingly phrased: Do you know of any safety concerns raised by the National Academy? The physical discomfort displayed by the highly respected but grimacing respondents while they dutifully mouthed the word “No” was, indeed, painful to watch.
¶
¶While the EPA claims to address the environmental consequences of the use of artificially mutated crop varieties in agriculture, the record of the consequences of its approvals demonstrates that the agency does not exercise an effective regulatory framework to protect the common good or promote public trust. Without exception, artificially mutated crops approved for commercialization by the EPA have created significant, long term measurable adverse effects on human, animal, and plant populations. To promote the public trust in genetically engineered plant products, the Coordinated Framework must adequately address these complicated issues.
¶
¶The known consequence of repeated use of broad-spectrum herbicides is the development of resistance by unwanted plant species. Agricultural research identified this process nearly a hundred years ago when the first chemical herbicides entered widespread use. Typically, herbicide tolerance occurs within ten years. After only twenty years of widespread use of the herbicides for which the current generation of artificially mutated crops are tolerant, the USDA estimates that over half of US cropland contains herbicide resistant unwanted plant varieties. As has occurred repeatedly in the chemical era, industry response has always been to increase the potency of new pesticides. In the case of genetically engineered crops, those crops have also been artificially mutated to express tolerance to the new more toxic herbicides. Because the time and expense of developing new herbicides and new herbicide resistant traits, research is currently underway to identify the next three to five generations of toxic chemical escalation reaching into the next 30 to 50 years.
¶
¶It is difficult for the informed public to accept that the best public policy regarding agricultural practices is to fully engage in this chemical-tolerance one-upmanship. DDT, atrazine, organophosphates, glyphosate, dicamba and 2,4d are not friendly chemicals. It can be confusing to the American public why the USDA, FDA, and EPA continue to overwhelmingly support an agriculture system that effectively guarantees that these and other toxic chemicals will be added to the litany of substances in a long historical saga of applying ever more potent and toxic substances to food crops.
¶
¶Citizen science and public health
¶
¶From the public’s perspective, there are troubling increases in diseases that appear to be connected to environmental exposure to novel substances. Confronted with a significant increase in childhood asthma, allergies, diabetes, hyperactivity and cancer, the public are practicing basic science by asking what might cause these increases. Coincidentally, the increased number of people suffering these disease conditions matches the increase in the use of agricultural chemicals, particularly those associated with artificially mutated crop growing systems and artificial ingredients present in food and medicines. In analyzing this data for correlation, the public is focused on the effects of chemical exposure primarily during pregnancy and childhood. This theory of too much chemical exposure, especially at the wrong time, could possibly explain the generational aspect of the sudden increases in these diseases. The medical research community generally attributes the increase to the overall toxic burden of small amounts of multiple chemicals, especially during sensitive gestational and post-natal developmental growth periods, and possibly aggravated by epi-genetic damage previously suffered by and passed on from parents or grandparents.
¶
¶Psst. Let’s not talk about glyphosate
¶
¶One of the most salient characteristics of the Coordinated Framework is that it does not address in any significant way the legitimate public health concerns related to the chemicals associated with the growing systems that support artificially mutated crops. In cooperation with the biotech industry, and despite significant opposition from the scientific community, the FDA adopted the doctrine of “substantial equivalence” based on two suspect platforms: first, that individual genes express themselves independently and predictably within a genome; and second, that the measureable traits and behaviors of the plant variant resulting from artificial mutation accurately and completely represented the differences from the non-mutated parent genome.
¶
¶Glyphosate has been studied for decades by qualified scientists at private and land grant universities. Its systemic effects on soil health are what one would expect from a toxic herbicide. Its use results in a significant decrease in biological activity of animals, bacteria, insects, and fungus. The reduced soil health harms the ability of the soil to accumulate and release nutrients when needed. Glyphosate-treated soils become dependent on chemical fertilizers. As public policy, promoting the dependence on herbicides and co-dependence on chemical fertilizers does not appeal to the public. Our national dependence on depleting the non-renewable energy sources required to create these agricultural inputs is legitimate cause for public concern. The toxicity of these chemicals in the air and water and as residues on food is also a problem recognized by public health authorities. Yet, the Coordinated Framework remains silent on these issues.
¶
¶There are other reasons that the doctrine of substantial equivalence cannot be valid. Artificially mutated crops only provided adequate growing yields and producer profit as massively scale. Large scale farming is based on clone monoculture crops of standardized characteristics as dictated by the food, fuel, and animal feed conglomerates, which in turn depend on large scale government regulation, research and subsidies scaled up to support only large operations. For artificially mutated crops to be “substantially equivalent” to conventional and organic varieties, they would have to demonstrate their ability to promote smaller scale biodiverse family farms that provide access to economic opportunity and a choice of agricultural systems. In fact, the disparities between outcomes from regular and genetically engineered seeds are not only substantial, but they are also fundamental. Genetically modified agricultural systems depend on and contribute to corporate dominance of our economy and political system. Natural and organic growing systems grow many things: democracy, independence, opportunity, and resilience through robust rural communities. You can leave the current generation of farmers of artificially mutated to their own devices, but you cannot let their corporate dominators limit access to natural and organic systems by capturing research, regulation, and public land use solely for themselves.
¶
¶An elephant in the room?
¶
¶The Coordinated Framework only acknowledges the importance of immediately measurable traits, so only immediately measurable traits must be presented as part of the application process. After approval and commercialization, there is no systematic review and surveillance of other novel traits and behaviors that were not immediately measurable at the time of approval. In addition, the applicant is solely responsible for deciding which immediately measurable traits are disclosed on the application, so regulators may not be aware of potentially unwanted traits and behaviors that should be kept track of. For traits and behaviors that are not measurable using current technology, this lack of public health and environmental oversight is particularly disconcerting to the public. The doctrine of substantial equivalence may be perceived by the public as the doctrine of passing the buck in hope that someone else will (or will not) take responsibility down the road. The observing public may rightly feel like unwilling subjects in a frightening experiment.
¶
¶There is an ancient parable that may serve us here. Six government ministers, gathered in a dark room, attempt to describe an elephant only by touch, and fail miserably. The parable lives on in every culture because it demonstrates a frustrating part of human nature. We reach conclusions based on what we can observe, or touch, and we can be lead astray if we depend on limited (or intentionally selected) information. The parable also speaks to what we choose to obsessively observe (or touch) and what we conveniently ignore. We are often not aware of traits that we could observe, and measure were we not entirely ignorant of them. In the parable, the blinded man who feels the smooth hard ivory tusk believes the elephant to be something entirely different from the one who feels its flat broad rough-skinned ear. A spear! A purse! A tree! A rope! And as millennia of philosophers have pointed out, even after sharing all their measurements and piecing together a shared idea of what an elephant is physically, none could correctly conceive of its entirety — or accept how the feel of their single touch was at odds with the others’. Often the elephant’s place within the natural world – or how the elephant felt about being groped in the dark — is always left unacknowledged.
¶
¶Trying to know an elephant by one touch in the dark: such is the shortcoming of the Coordinated Framework on Biotechnology Regulation. We take a few convenient measures of an artificially mutated corn and determine it is just like any other corn. The geneticist identifies its new gene structures. The allergist measures levels of new proteins. The agronomist measures growth rates and nutrient uptake. The entomologist measures the presence of worm-killing Bt toxin in the root system. The economist counts the yield that results from perfectly controlled conditions. The accountant tallies the farmers’ technology fees. The food processor tests for sugar, water, and protein in the kernels. Together they reach the conclusion that it is, indeed, substantially equivalent, if not better than, regular corn.
¶
¶A coordinated fairy tale?
¶
¶For many Americans, the Coordinated Framework is merely a coordinated fairytale. It is no better than six men in the dark discussing a few disparate aspects of the food system and passing judgement in isolation from the whole. And as in the parable, each man in the dark fails to perceive the limits of his experience or how the reality is far more complicated – and dissimilar – than he can comprehend.
¶
¶For families with children affected by the upsurge in new cases of asthma, allergies, autism, diabetes, hyperactivity and cancer, the Coordinated Framework’s lack of attention to their public health emergency is impossible to condone. The department of health and human services is directly charged with protecting and promoting public health. Yet its regulatory arm, the Food and Drug Administration, has effectively recused itself from responsibility for the potential negative effects of artificial gene mutation and the chemical inputs that support this agricultural system. And its public health surveillance and response arm at the National Institutes of Health is reluctant to undertake substantial research on these issues. Similarly, the USDA is charged with oversight of livestock and plant industries, but it defers to the EPA on pesticide and fertilizer dangers. The EPA itself appears unable to act to prevent the use of dangerous materials until their harm is so pervasive that the public outcry or court orders force them to act. Of 60,000 toxic chemicals in use, only six have been removed from the market by the EPA.
¶
¶There are dozens of other ways to observe, measure and value artificially mutated crop systems that do not fit into the experience and measurement capabilities of the regulators responsible for the coordinated framework. Monarch butterflies migrate to a particular forest in Mexico each winter. From a high population of one billion butterflies in 1996, the population has dwindled to a few hundred thousand today. These insects feed and lay eggs on common milkweed that grows in the same areas where glyphosate tolerant corn and soy is grown in the upper central United States. There, milkweed habitat for monarch butterflies has been destroyed by expanded monocultures and herbicide use. The remaining butterflies have less and less habitat as they move north each summer. One must value this species to bother measuring it, and one must acknowledge the possibility that glyphosate-based monoculture crop systems contribute to the species’ demise, before it can be used to evaluate the technology. The coordinated framework, by design, does neither.
¶
¶For whom do we govern?
¶
¶Worse still, the combined efforts of these agencies to systematically denigrate, marginalize and dismiss the public’s concerns severely undermine these same agencies’ ability to promote public trust in them. It is as if the elephant’s rider tells the blinded men to reconsider, but none will amend their point of view because if conflicts with their area of expertise. For proof of this statement, we need only review the video of the recent US Senate hearings on GMO labeling, where senior representatives of these agencies each denied the existence of safety concerns with genetically modified crops. All decried public ignorance as the cause of public suspicion. These statements occurred within days of official announcements by the World Health Organization and State of California that glyphosate should be considered a carcinogen. When our government fails to fulfill its basic duties to ensure life, liberty and the pursuit of happiness, the public will undertake them privately on their own behalf. The Coordinated Framework is risking this failure in the eyes of the public when it passes the buck on challenging public health issues and disenfranchises minority opinions.
¶
¶There is a broad spectrum of motivations and expectations among practitioners of artificial genetic mutation. It is clear to anyone who follows and studies the various kinds of scientific, marketing, and trade group communication that these expectations and motivations are often not consistent, occasionally in conflict, and sometimes not acknowledged as important or relevant to the conversation. For instance, the global chemical companies have monetized their investment in artificial genetic mutation by selling seeds of glyphosate-tolerant crop varieties, associated technology agreements, and glyphosate itself. Monsanto in particular has stated publicly it intends to use its technology to control the world’s food supply. This corporatist arrogance forms part of the rationale behind consumer mistrust and resulting push-back against artificially mutated foods.
¶
¶Yet, this possibility of inappropriate corporatism appears to be completely disregarded by the academic scientists and researchers, including those working under non-profit foundation grants to help poor small holders in Africa eek out additional food from drought-parched land or sodden rice paddies. From them comes the rallying cry, “if only the public could understand the importance of these techniques, they would embrace them.” These same researchers also point out, quite stridently, that the economic, social, and environmental consequences of genetic engineering are very poorly studied and poorly understood. Their focus is often narrowly on increased yields through localized disease resistance, but anecdotally they describe the toll that artificially mutated crop systems, even at the micro-enterprise level, have on familial, community and regional economic relationships. And they categorically state that the resistance to adoption of the technology cannot be overcome until true safety studies are completed — funding for which is impossible to come by. Those with the money do not want to know. Those who want to know do not have the money. In the end, the unintended consequences remain unknown. But not a word about the broader corporate agenda.
¶
¶
¶Addressing the global system of corporate/government control
¶
¶These same problems that are writ large in the US and other countries such as Brazil. The independent bio-diverse family farm is virtually extinct. In its place are farms owned by individuals who are wholly dependent on artificial mutation technology, toxic herbicides, and a centralized industrial food system. They do not grow food; they grow inputs for the food processing system. Thus, the consumers and food activists put to the GMO research community a corresponding challenge: If the Coordinated Framework had to recognize and measure the havoc wrecked by glyphosate tolerant and Bt producing crops, would participants proceed more cautiously with how you evaluate the technology? In essence, each side is telling the other to practice the scientific rigor it preaches but coming from completely different points of view.
¶
¶Propaganda
¶
¶The biotech lobby — coordinated, heavily funded, global active and deeply experienced in manipulating public and regulatory opinion — inserts itself into the honest public conversation with intentionally confusing and confrontational sound bites. We are all familiar with the trope: “Anti-science, fear mongering, anti-GMO activists are scaring the ignorant public.” But let us be clear. The typical consumer is very much pro-science, exercises due caution, and is rarely activist about anything. The stereotype used to discredit the public’s very defensible concern and opposition is simply the opposite of the truth.
¶
¶Listen to the scientists who testified on the same topic:
¶
• “We don’t know enough about the consequences of these applications of these technologies.”
• “Organizations driven solely by the profit motive are moving too fast.”
•“We need proper intervention from governments to ensure the application of this technology benefits everyone and harms no one.”
• “We have not done any research in these areas.”
• “Our technology is inadequate to measure those types of risks.”
• “Twenty years is far too short a time to understand unintended consequences of GMOs.”
• ¶We do not understand what these novel proteins are, how we will react to them, or how they will combine with nutrients and affect health over the long term.”
¶
¶Anti-science, fear mongering anti-GMO activists, indeed!
¶
¶An inalienable right to profit from novel innovations?
¶
¶The coordinated framework was created ostensibly with a key conceptual strength that, it turns out, is its fatal flaw. The admonition that only sound scientific evidence motivates, informs, and guides the Coordinated Framework has crippled it from the outset. A public policy process free of value judgements is by definition not a public policy process. On the contrary, it begins as finished policy at the outset. The Declaration of Independence declares man’s right to life, liberty, and the pursuit of happiness. Notice, definitively, that our nation’s founders did not write how they were risking revolution and loss of limb and life to fulfill a divine directive to create corporate profits from novel innovations. In establishing commerce and profit as the de facto primary directive of the Coordinated Framework, the founders of the Coordinated Framework have forsaken the core tenets of our democracy.
¶
¶As we have seen, the costs and benefits of scientific innovation are not immediately obvious, automatic, or calculable. They are certainly not to be measured solely by corporate balance sheets. Many of the technological advances of our nation’s agricultural development have resulted in great wealth for some at the expense of the viability of rural communities, choice and opportunity for family farms, massive contamination from chemical applications, and mass urbanization due to rural unemployment. Yet, if you asked members of the American public if they value robust rural economics, independent smallholder farms, chemical free agriculture the answer is always yes, I value that. By removing American values from consideration within the Coordinated Framework, the process and outcome betrays our fundamental American values in exchange for short term profit. Yet the Consolidate Framework claims to promote public understanding and trust as its outcome. Under the current circumstances, which is unlikely, at best.
¶
¶Preventing choice, opportunity, and self-reliance
¶
¶One particular subset of the disillusioned public deserves special note. Farm families who value non-conventional and organic agriculture are finding it more and more difficult to succeed at farming. The inequities in the system that favors large scale monoculture and chemical intensive production methods put conventional and organic operations at risk. All the supporting businesses, in turn, are also at risk. In short, the Coordinated Framework has, inadvertently or by diligent design, chosen a single winner among all systems and discounted the value of other viable systems. As artificially mutated commodity crops monopolize research dollars, subsidies and other resources, producers of conventional and organic crops suffer from lack of subsidies, research, data collection, and protection from encroachment by artificially mutated genes. The USDA maintains token levels of funding for rural development, conservation, new farmers and the like, but the totality of these funding amounts to little more than a talking point in a footnote of the Coordinated Framework that drives US agriculture policy. Access to local harvesting, transportation, processing storage and manufacturing for conventional and organic producers is often non-existent.
¶
¶The great experiment with centralization and consolidation is a dangerous experiment with just how little food resilience and security a local economy can tolerate before it collapses during a crisis. The next oil shock is just around the historical corner. Climate change is now evident daily. Irrigation water is no longer available in many places. Yet, US agricultural policy and the Coordinated Framework continue to believe — against all scientific facts and logic — that input-heavy artificially mutated commodity agriculture is the way of the future.
¶
¶One choice for all time
¶
¶The example of artificially mutated alfalfa may be instructive. Alfalfa is used primarily as feed for livestock. In artificially mutated crop systems, all plants in the fields are killed off using herbicides prior to planting the alfalfa seed. The artificially mutated alfalfa is tolerant of glyphosate herbicide spray and its residue in the soil. Existing weed pressure is reduced by the application of glyphosate while existing alfalfa plants are not harmed. However, alfalfa is far less domesticated than corn and soy. Alfalfa can re-seed itself from season to season without human intervention. Its ten-to-fifteen-foot tap root ensures it will compete successfully with other plants, and its pollen can travel for miles. When artificially mutated herbicide-tolerant alfalfa was commercialized and widely planted, it effectively began the process of permanently eliminating the existence of conventional alfalfa. The consequences of this decision are unclear and will remain so for decades to come. The decision is permanent for all future generations. Accordingly, consumers who are concerned with fairness, transparency and cautionary public policy decisions are likely to express an increase in trust in the Coordinated Framework. The corporation that profits from these technologies acts from very different motivations and beliefs than a village elder in Africa or the organic farmer in rural Vermont.
¶
¶There are many costs that result from the GE crop system which are not accounted for in the price paid for the resulting commodities. Some of these costs are measurable, while others are values-based and thus subjective in nature. For instance, just twenty years ago the US was home to about five hundred independent seed companies that bred, harvested, cleaned, stored, and marketed seeds with varying traits. Typically, these seeds were classified in minute detail regarding their preference for differing types of soil, climate, amendments, pest tolerances, etc. There was a robust local, regional, national, and international market for unique varieties, with intense market competition driving innovation and diversity. Since then, controlling interest in nearly all of these seed companies as been acquired by a small number of larger companies. In fact, the six chemical companies closely tied to the market for genetically modified crops now control the seed market in one way or another. The individual seed companies may remain in business, but their research and development priorities are centrally directed. The focus is often primarily on the development of novel genomes that are tolerant to the proprietary herbicides produced and sold by the chemical companies.
¶
¶While these private initiatives would seem to reflect a healthy functioning free market, within this closed system we see problematic anti-competitive actions and dangerous public policy challenges. Competition is discouraged when seed development is not conducted to compile traits except in proprietary artificially mutated, herbicide-tolerant varieties, leaving the conventional and organic seed market with fewer options. Some naturally occurring traits, such as drought tolerance in grains, have been successfully captured in some crop varieties, but then sequestered in artificially mutated varieties so they can only be purchased as part of a proprietary herbicide-tolerant version. Clearly it is shortsighted to stop development of quality food traits. In the long run, the more traits available to American farmers will allow them to respond to pest, water, fertility and climate challenges successfully. On the international arena, the United States runs the risk of falling far behind other nations in improving its strategic germ plasm resources.
¶
¶Similarly, basic agronomic research into traditional, alternative, and conventional growing systems is no longer a priority within the land grant college system. Corporate sponsorship of faculty appointments and research institutes has realigned the focus of these public institutions away from broad based research and development for the free use of the American public toward work that is primarily intended to create protected intellectual property to be commercialized by the benefactors. The school may benefit financially from these patents, but it loses its academic independence. In most areas of the country, the longtime focus on artificially mutated commodity crops has resulted in ever greater consolidation of farms and farming practices. The responsibility for farm consulting has shifted from the longstanding land grant college extension service to the technician sent by the chemical company and paid for through “technology license” fees paid by farmers of artificially mutated crops. The US extension service is often so desperate to find someone to provide services to that they are opening urban organic gardening outreach programs in metropolitan areas. Again, this may appear to be the workings of the free market. But in case the United States needs to revisit smaller scale, low chemical, and regenerative farming practices, we may not have the expertise available and in place to do so.
¶
¶Borrowing from our kids?
¶
¶One of the suggested advantages of crop systems using artificially mutated genomes that tolerate herbicides is reducing on-farm costs, particularly labor. Pre- and post-planting applications of herbicide may eliminate the need for additional weed control measures. Uniform cloned crops help ensure consistent height, pollination and harvesting schedules. However, these systems have increased the application of agricultural pesticides to nearly one billion pounds per year. In turn, the reduced ability of the soil to properly create and release nutrients to the roots of growing plants causes increased dependence on fertilizer applications. Many farmers now describe glyphosate-treated dirt as a growing medium whose role is to secure roots and receive applications of commercial fertilizers as needed. In healthy soil, nutrients are constantly regenerated by the activities of beneficial insects, bacteria, fungus, and burrowing animals. Humus made from dead roots and other plant matter increases the moisture retained in the soil and in and of itself sequesters carbon from the atmosphere. Again, here we have an agricultural policy explicitly supported by the Coordinated Framework that works in direct opposition to key national policy priorities related to climate change, drought, water quality, and energy independence. Eventually we will need to revive the ninety million acres of deadened GE cropland so it can be used to mitigate these challenges rather than contribute to them.
¶
¶Another gilded age of corporate control
¶
¶The Coordinated Framework originally included cooperation between the FDA, USDA, EPA, and their respective agencies. This formal framework does not recognize another key participant, without whom the promotion of biotechnology would have failed: the US Justice Department, coupled with suspect federal court rulings and abetted by the US Patent and Trademark office.
¶
¶To promote public trust in the Coordinated Framework process, we should not assume that the fundamental changes to the patent system and liability doctrines are acceptable even as fait accompli. The decision to grant ownership of naturally occurring genetic traits to corporations does not make sense to most people. The decision to require land grant institutions to seek patent opportunities in conjunction with private enterprise is hard to swallow. The decision to force aggrieved farmers to protect their crops from genetic contamination from nearby artificially mutated crops is incomprehensible. Make no mistake that these changes are perceived as unjust and continue to undermine public trust in the Coordinated Framework. The most we can hope for is public resignation and acquiescence to a system that has been fixed to favor the global corporations. We cannot ask the public to agree that those transfers of the commonwealth were necessary to the common good or accomplished in good faith. Distrust abounds.
¶
¶The justification for promoting the consolidation of American agriculture under the biotech corporations is, of course, greater production at lower cost. Even this heady goal is problematic. Most of the cost savings, as we have seen, are only temporary and due to the failure to account for external costs to the environment, soil health and taxpayer subsidies for commodities. This amounts to unfair competition on two fronts. First, smallholders and non-GE growers are severely handicapped by the dominance of artificially mutated crop agriculture. There is no reason that conventional and organic crops should be more expensive to produce, except for the tricks of accounting and subsidies. When these crops are exported, they have no positive impact overseas. Exporting low-cost crops only undermines foreign producers. When prices or currency problems disrupt the recipient country’s ability to purchase these commodities, there is no domestic production left in place to make up the difference. If the long-term economic viability of artificially mutated crops under the Coordinated Framework depends on exports, and exports depend on continuing to pay subsidies and ignore externalized costs, there is no justification that will satisfy public suspicions about the motivations and primary beneficiaries of the government’s biotechnology doctrine.
¶
¶What are biotechnology interests so afraid of?
¶
¶
¶The recently funded biotechnology defense laboratory located at the University of Kansas is emblematic of the core source of public distrust in the Coordinated Framework. The laboratory explicitly acknowledges the likelihood of known, suspected and yet unknown negative consequences of artificial mutation. Bona fide long term scientific research exists to call into question the wisdom and long-term viability of artificially mutated monoculture. This biotech defense lab confirms it. The observing public clearly understands the science as well: monoculture planting of genetically identical crops greatly increases the likelihood of plant and animal disease epidemics. In fact, unusual regional outbreaks of rust, blight, and rootworm tolerance to Bt insecticide are accepted and acknowledged negative consequences of artificially mutated crop systems.
¶
¶The purveyors of artificially mutated seed and supporting chemical herbicides admonish their farming customers that the system is failing in general to lower costs and increase yields due to these consequences. The pressures from herbicide tolerant weeds and from root-eating worms that are tolerant of systemic insecticides produced by artificially mutated plants represent fundamental failures of the system. Conventional pesticides must again be sprayed to control rootworms, and 2,4D and dicamba herbicides are now being deployed as part of the weed control system.
¶
¶Chemical escalation was a known and unavoidable outcome, yet it has not dampened the enthusiasm of the believers. When the chemical, mining, energy, smelting, and other industries introduce heavy concentrations of toxins into our air, water, and soil, it is called a superfund site and taxpayers pick up a large part of the cost of cleanup. How does the public of the United States cleanup ninety million acres of contaminated farmland? The US biodefense lab will cost taxpayers over $2 billion to build and billions more to operate. So, taxpayers can fix the problems created by corporate-controlled agricultural practices that we know are an unfolding disaster. At very least, industry should fully fund the toxic cleanup of its technologies, and research into its dangers, and not leave the cost to American taxpayers.
¶
¶Many in the public who are following the outcomes from the Coordinated Framework also question how it prioritizes funding. For instance, the entire budget within the USDA for support and research of organic agriculture is less than one percent of the cost to construct the national biodefense facility to manage and control GE adverse events. As a simple matter of long-term public policy, it would seem prudent to invest in agricultural research to improve existing systems that do not have negative consequences, before investing in expensive fixes for an unproven and fundamentally flawed artificially mutated cropping system.
¶
¶Moreover, the entire federal policy apparatus has focused for forty years on achieving energy independence. Yet, the Coordinated Framework was put in place explicitly to promote the global expansion of a growing system that is fundamentally and inexorably dependent on depleting fossil fuels. The paradox of the ideological belief in sound science of artificial mutation is that the system is impossible to sustain on Earth. Only on pure faith can one believe in unlimited energy reserves to make the chemical fertilizers and herbicides the artificially mutated crops require. Long before the population peaks, our ability to extract affordable fossil fuels will begin to wane.
¶
¶Regulating an elephant not one of us has seen?
¶
¶The parable of the blind men and the elephant has been used to shed light on this kind of belief. Insiders undertaking to regulate artificially mutated crops under the auspices of the Coordinated Framework, take heed:
¶
¶It was six men of Indostan
To learning much inclined,
Who went to see the Elephant
(Though all of them were blind),
That each by observation
Might satisfy his mind.
¶And so these men of Indostan
Disputed loud and long,
Each in his own opinion
Exceeding stiff and strong,
Though each was partly in the right,
And all were in the wrong! ¶So, oft in theologic wars
The disputants, I ween,
Rail on in utter ignorance
Of what each other mean,
And prate about an Elephant
Not one of them has seen!
¶The parable argues that people may deny various aspects of truth; deluded by the aspects they do understand, they deny the aspects they do not understand.
¶
¶There is another parable about elephants and men, in which six elephants in a dark room attempt to describe a man by touch. After a long examination, the first elephant concludes, “Man is flat.” One after another, all the others agree.
¶
¶Just when the belief in greater food production from artificial mutation must become a technical reality, the theoretical foundation on which artificially mutated crop systems rest is crumbling. The only responsible and legitimate way to reestablish a functional Coordinated Framework is to state unequivocally that artificially mutated crop systems are a temporary measure that failed. Adequate resources must be allocated immediately to successor systems to avoid a global agricultural disaster within our lifetime. It is a sad irony that the future populations that believers in artificial mutation propose to feed, will be most gravely harmed by their inevitable failure.
¶
¶