Washington, DC, USA
October 3, 2017

The Information Technology and Innovation Foundation (ITIF), one of the world’s top science and technology think tanks, along with a group of independent scientists, yesterday submitted a letter to Interior Secretary Ryan Zinke calling on the department to reverse a Fish and Wildlife Service policy that phased out the use of genetically modified (GM) seeds. The letter, spearheaded by ITIF, argues that the policy was improperly adopted three years ago and stands at odds with the conservation objectives of the Fish and Wildlife Service.

According to the group, the ban against use of GM seeds is “arbitrary and capricious,” as genetically modified crops are shown to be the most modern, precise, efficient and effective methods of seed improvement. Additionally, the policy should have been adopted through a notice-and-comment rulemaking process under the Administrative Procedure Act.

The group writes, “The prohibition of ‘genetically modified’ crops is a wrong-headed and anti-environmental policy, and the conceit that it is being advanced out of respect for a ‘land ethic’ is indefensible.”

The letter also calls on the Interior department to rescind the ban on the use of neonicotinoid pesticides. Instead, the group calls for a case by case evaluation that would allow for their use except where they pose a credible threat to endangered species.

ITIF senior fellow Val Giddings said, “Labeling crops as ‘genetically modified’ stigmatizes their use, when in reality their safety is proven and their benefits are significant. They are shown to produce maximum sustainable yields with minimum environmental impact. The Interior department should reverse these policies and get back to the conservation mission of the Fish and Wildlife Service.”

The text of the letter is below.

October 3, 2017

The Honorable Ryan Zinke, Secretary

Department of the Interior
1849 C Street, N.W.
Washington DC 20240

Dear Secretary Zinke,

We are a group of independent scientists joining with the Information Technology and Innovation Foundation, an independent think tank focused on innovation and public policy, writing to bring your attention to, and to ask you to reverse, a policy improperly adopted by the Fish and Wildlife Service three years ago that runs counter to its mission.[1]

On July 17, 2014, the Chief of the National Wildlife Refuge System (NWRS) made public a memo through which the use of “genetically modified” seeds to raise crops to feed wildlife was to be phased out as of January, 2016, as well as any use of neonicotinoid pesticides.[2]

While this action has been criticized by scientists who specialize in this field, it has not been widely noted.[3] It would appear to be a major federal action that should have been adopted through a notice-and-comment rulemaking process under the Administrative Procedure Act.[4] But even setting aside this apparent procedural irregularity, the policy is at odds with the conservation objectives of the NWRS, which has a long and praiseworthy history of welcoming innovation in management practices for the betterment of wildlife and the environment.[5] It should be reversed.

The optimal methods of agricultural production on refuge lands devoted to that purpose are those that produce the maximum sustainable yields with the minimum environmental impact. Obsolete production methods, no matter how innovative they might have been thousands of years ago, are not, today, “green” in any sense.[6] They produce vastly less than modern techniques, requiring much more land to produce the same harvest, thus consuming far more space that could otherwise be directly allocated for wildlife habitat than modern varieties. The superiority of modern crop varieties (e.g., genetically modified organisms or GMOs) in this regard has been demonstrated time and time again.[7] The prohibition of “genetically modified” crops is a wrong-headed and anti-environmental policy, and the conceit that it is being advanced out of respect for a “land ethic” is indefensible.

That the use of “genetically modified” has been forbidden by the NWRS chief is arbitrary and capricious on several grounds, starting with the fact that all seeds are genetically modified, both through historical processes of domestication and crop improvement, to say nothing of the universal process of descent with genetic change that is the sine qua non of all life on earth. The term “GMO” is inaccurately and wrongly used to stigmatize a subset of seeds produced with the most modern, precise, efficient and effective methods of seed improvement. This is inconsistent with the scientific consensus.[8] The Chief’s proscription of the use of such seeds appears to be based on an unsupported assumption of potential negative consequences to wildlife conservation and biodiversity that is robustly contradicted by data and experience.[9] As numerous expert bodies have found, and as has been corroborated by vast experience, the safety of these seeds is clear and the beneficial impacts on agricultural sustainability significant.[10]

As for the Chief’s arbitrary ban on the use of neonicotinoid pesticides, if the purpose of growing a crop is to produce a harvest sufficient directly to nourish, for example, migratory waterfowl, then their use to optimize productivity of seeds treated with pesticides that are less toxic than their predecessors or alternatives would seem to be logical, praiseworthy, and essential good stewardship of the land. The NWRS Chief cited concerns over potential impacts on non-target species, so let us consider that. We know neonics are kinder to birds and vertebrates than the alternatives. But what about endangered insects?

Some have made the argument that neonics may be contributing to declines in some threatened native prairie butterfly populations in the Great Lakes region. This argument is made in a webinar featuring Lisa Williams, the Branch Chief for Environmental Contaminants in the East Lansing Field Office of the U.S. Fish and Wildlife Service.[11] Dr. Williams sees a correlation between areas of neonic use and the habitat distribution and declining numbers over time of the Poweshiek Skipperling and the Dakota Skipper, both candidates for listing as endangered species. She argues from this correlation that neonics should thus be banned from use throughout the NWRS.

As Williams herself admits, this is an argument from correlation, and better data are needed to establish cause and effect. But even if we suppose such data exist, or can be produced, they could not justify a system-wide ban. The National Wildlife Refuge system is vast, involving all 50 states and territories. The butterflies of interest, though once more widespread, are now limited to relics of prairie habitat in a small portion of the country, the remainder of which is outside the historical range of the species of concern and throughout which very different conditions apply. A blanket neonic ban makes no sense, and cannot be justified.

We therefore ask that the Department of Interior vacate the NWRS Chief’s policy decision to prohibit the use of “GM” seeds on refuge lands and instead to use them wherever improved agricultural productivity and sustainability would contribute to the Agency’s conservation mission. We ask also that the blanket ban on neonicotinoid treated seed be rescinded, and a case by case evaluation be instituted that would allow for their use except where they pose a credible threat to endangered species.

Sincerely,

L. Val Giddings, Ph.D.
Senior Fellow

Robert D. Atkinson, Ph.D.
President and Founder, The Information Technology and Innovation Foundation

Kent Bradford, Ph.D.
University of California, Davis
Davis, CA

Bruce M. Chassy, Ph.D.,  
Professor Emeritus
University of Illinois at Urbana-Champaign
Champaign, IL

Nina Fedoroff, Ph.D.
Evan Pugh Professor Emerita
Pennsylvania State University

Drew L. Kershen
Earl Sneed Centennial Professor Emeritus
University of Oklahoma, College of Law
Norman, OK

Prof Alan McHughen, Ph.D.
University of California
Riverside, CA

Wayne Parrott, Ph.D.
Professor of Crop Science
University of Georgia
Athens, GA

Channa S. Prakash, Ph.D
Dean, College of Arts and Sciences
Professor, Genetics and Biotechnology
Tuskegee University 
Tuskegee, AL

Peter H. Raven, Ph.D.,
President Emeritus, Missouri Botanical Garden
St. Louis, MO

Rob Wager, M.Sc.
Vancouver Island University
Nanaimo, BC, Canada

Identification of signatories from organizations other than ITIF is for informational purposes only and does not indicate any institutional endorsement.

The Information Technology and Innovation Foundation (ITIF) is an independent, nonpartisan research and educational institute focusing on the intersection of technological innovation and public policy. Recognized as one of the world’s leading science and technology think tanks, ITIF’s mission is to formulate and promote policy solutions that accelerate innovation and boost productivity to spur growth, opportunity, and progress. Learn more at itif.org.