Portfolio 21 the Case Against GMOs

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The Case Against GMOsAn Environmental Investor’s View of theThreat to our Global Food Systems

Continued on next page . . .

Introduction

Genetically modied (GM) crops have been surrounded by controversy since their rst deploymentnearly twenty years ago, but have still become the fastest-adopted crop technology in recent history.In 2012, GM crops were planted on over 420 million acres, and for the rst time over half of this areawas in developing countries.

To give a sense of the scale of this area, all of the 2012

GM crop elds would cover nearly all of the state ofAlaska. Over the course of the twenty years since theywere introduced, GM crops have been planted on acumulative 4 billion acres of land, an area roughly the sizeof Russia.1

The steady upward trend of global GM crop adoption is welldocumented by the International Service for the Acquisitionof Agri-biotech Applications (ISAAA), an industry tradegroup, in its yearly research brief “Global Status ofCommercialized Biotech/GM Crops” however, ISAAA

denied our request to publish their data in this report.2

ContentsIntroduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1Industrialized Agriculture as the Foundation forG e n e t i c M o d i c a t i o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4The First GMO . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6Genetically Modied Crops . . . . . . . . . . . . . . . . . . . . . . . . 7GM Crops in the United States . . . . . . . . . . . . . . . . . . . .8

The Regulatory Environment . . . . . . . . . . . . . . . . . . . . . 9The United States: Friends in High Places . . . . . . . . .9American Research Institutions: In Search ofObjectivity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10The European Approach . . . . . . . . . . . . . . . . . . . . . . . . .12

Targeting Developing Markets . . . . . . . . . . . . . . . . . . .13South America: The United Republic of Soy. . . . . . .13India . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .15Africa. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .16

Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .17Disclosures. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .17Endnotes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .18

September 2014

Environmental Investing through Fundamental ResearchBased in Portland, Oregon, Portfolio 21 is a boutique investment management rm andpioneer in combining environmental, social, and governance analysis with fundamentalinvestment research.

www.portfolio21.com

Copyright©2014 Portfolio 21 Investments, Inc.



2 The Case Against GMOs

The adoption rate of these crops is astounding.Tens of thousands of farmers are now reliant on theagricultural biotechnology companies responsible forthe sale and development of GM seeds. The GM foodproduced reaches hundreds of millions of consumers.And production impacts almost every part of the globalfood system, from small, independent farmers in South

America to the regulatory bodies of the European Union.

The question remains, what exactly are these impacts?Purveyors of transgenic products claim that GM farmingboosts yields and farming incomes by saving on fossilfuels, pesticides, and labor. Another claim arising from thisassumption is that GM farming represents a step towardenvironmental sustainability by decreasing emissionsand the use of agricultural chemicals. GM advocatesalso maintain that these products pose no health risks toeither the farmers or consumers.

None of these arguments have held up over extendedperiods of use or in the face of independent testing.Pesticide and herbicide-resistant crops (by far the mostwidely used GM varieties) actually lead to an increase inpesticide and herbicide use over time horizons of as littleas four years.3

Financial gains, which farmers make through increasedyields, are offset by increased spending on patentedseeds, fertilizer, and herbicides or pesticides, leading to a

net decrease in income for all but the largest mega-farms.These higher input costs are especially damaging whensmall, more marginal farmers experience crop failure.Elevated levels of bankruptcy and consolidation havefrequently occurred following the deployment of GMcrops.

Perhaps the most pervasive argument for GM crops iscentered on the message that these crops are neededto “feed the world.” The underlying assumptions of thisargument, however, are simply incorrect. At current levels

of global production, there is enough food for everyperson on earth to have 3,000 calories per day.4

The problem lies with distribution, income, and food waste.GM crops can actually exacerbate hunger issues bypressuring farmers in marginal areas to grow cash cropsfor export or extensive processing. Farmers who makethe switch to GM products usually get an initial increase

in their yields, but this can be attributed to the varietiesused as a base for the commercially available transgenicvarieties. Furthermore, in repeated tests, conventionalbreeding has been just as or more successful at delivering“climate-ready” crops that incorporate drought or oodresistance.

For environmental, social, and governance (ESG) focusedinvestment strategies, agricultural biotech representsan unacceptable level of risk across a wide range offactors. The problem lies less with individual companies orproducts, but rather with how GM agriculture in its currentiteration jeopardizes the whole agricultural system. Just asthese risks are system-based, the consequences wouldmanifest themselves by changing the very biological,economic, and social framework of food systems.

Almost twenty years into the GM experiment, a range

of these risks (Environmental, Social, Governance/Regulatory, Reputational, and Financial) have becomeclear.

When taken together, these risks form a very clear basisfor exclusion from an ESG investment strategy. It isimportant, however, to distinguish between the systemicrisk and the risk presented by the technology of geneticengineering. Genetic engineering, in and of itself, is simplya tool. Indeed, it represents an opportunity to changethe parameters of agriculture, which could be benecial

if given the proper regulatory framework and directedtoward health and sustainability.

In the current market, however, developing geneticallymodied organisms (GMOs) demands massive invest-ments, which then drives the need for massive returns.When looking at the small number of transgenic technol-ogies in use today, it becomes apparent that the nature ofselection favors a certain set of crops that are best suitedto large-scale, mechanized cultivation. This is amplied bythe leveraging of intellectual property rights over seeds,

planting materials, and tools used for genetic engineering.In its current state, the main goal of GM agriculture is toincrease the sales of seeds and certain agro-chemicals.



Portfolio 21 www.portfolio21.com 3

Environmental Risk

Genetically modied agriculturereinforces many of themost damaging aspects ofmonoculture and mechanization.These include biodiversityloss, agro-chemical use, andaccelerated soil exhaustion.Additionally, the foreign geneticmaterial can spread beyond itsintended area through cross-pol-lination and interbreeding, as

well potentially migrate acrossspecies.

Reputational Risk

Consumers are becoming increasingly educated on their eating habitsand the consequences of these choices. In addition to raising questionsconcerning the health effects of consuming GMOs, the spread of thisinformation builds up negative perceptions of the agricultural biotech

corporations and the industry as a whole.

Financial Risk

Given the information and the choice, an increasing number of consumers(and the companies that cater to them) are becoming less accepting ofGMOs. The market, especially among consumers in wealthy countries,has pushed GM crops to the low end of the market, where they are nowa cheap choice for animal feed, biofuel feedstock, and heavily processed

food. Additionally agricultural biotech companies must contend withlitigation costs, settlements, and “restructuring charges” arising fromfailed deployments.

Social Risk

The demographic shiftsthat have accompanied themarketing and adoption ofGMOs show disturbing patterns,especially in developingcountries. Small farmers oftenbecome trapped by seedlicensing fees and other risinginput costs. Furthermore, theswitch to crops that then getexported for processing can

exacerbate local food supply andquality issues.

Governance/Regulatory

Risk The intellectual property systemallowing for corporate patentson organisms opens the door fora range of ethically problematicbusiness practices. Also, agricul-tural biotech companies haverepeatedly used their undueinuence on regulators to gainproduct approval, circumventregulations, and suppress

dissenting independent studies.




The coming decades will likelysee signicant increases in foodpressures stemming from bothpopulation growth and climatechange. By 2050, the globalpopulation is expected to reach 9billion, while the amount of arable

land per person will be roughly halfwhat it was in 1990.

Managing the agricultural systemin more sustainable ways is madeharder by the spread of monocul-tures and large-scale, mechanizedfarming. In the developing worldespecially, GM monoculture and theindustrial approach to agriculturehave spread hand in hand. Yields

may be higher, but they are not, inthe very long run, sustainable.

Mechanized agriculture, in some form, is likely necessaryto feed the number of people in the world today. GMagriculture is not. It has so far provided insufcient andinconsistent benets for the amount of risk it entails.Genetically modied agriculture, as it is currentlypracticed, should be far down the list of solutions forsecuring the global food supply.

Industrialized Agriculture as theFoundation for Genetic ModicationAn understanding of GM agriculture and its systemiceffects requires an understanding of the enormouschanges wrought by industrialized agriculture. Thegroundwork that industrialized agriculture laid hasbeen the framework for the development of the giantagro-chemical companies and the implementation of theirproducts.

While these systemic shifts occurred over decades in the

United States, many of the developing markets that arethe new targets for GM marketing are experiencing bothat the same time, as the GM system cannot function inmore traditional, smaller-scale and sometimes organicfarming.

Thus when these GM crops are introduced they neces-sarily come as a part of a larger system. The changescaused by the implementation of industrialized agriculture,while economically productive, are enormously disruptive.GM crops exacerbate and accentuate these disruptions,and fail to provide commensurate increases in economicor social well-being.

Through the 10,000 year history of agriculture,

starvation and famines have been a regular occurrence.Early nineteenth century English scholar ThomasMalthus provided some of the rst modern intellectualcommentary on the nature of population and food needs,originating the concept of the “Malthusian dilemma” todescribe when population overtakes food production andleads to mass starvation.

While his ideas have been extensively debated since,this commentary has provided important concepts thathave helped motivate the search for more sophisti-

cated, reliable food production. Achieving sustainableproductivity becomes even more important as farmlanddisappears to accommodate the developmental needs ofmodern society.

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Figure 1: Global Population and Arable Land Per CapitaPressure to increase productivity on existing land

Source: FAO, United Nations, PotashCorp




The beginning of the 20th centuryushered in an era of rapid populationexpansion, as well as technology,which heralded signicant changesin all parts of the economy. In theUnited States, World War I prompteda massive increase in heavy

equipment manufacture. With theencouragement of the Departmentof Agriculture and the AgriculturalExtension Service, farmers rushedto purchase this equipment for theincrease in productivity it provided.However, the consequences ofthis buying spree would be a keydriver of the economic devastationof rural America during the GreatDepression. By the early 1930s

agricultural commodity prices haddropped 60%, while prices for heavyfarm equipment dropped only 20%.5

Many farmers found themselves in debt and were forcedto sell to larger farms, leading to an increase in tenancyand migration to urban areas. While the larger economyrecovered in the wake of World War II, the furtherdeployment of technology continued this process. Insteadof just tractors and trucks, however, large farms gainedaccess to mass-produced chemicals and airplanes to

spread them. Farms consolidated even further, with thetotal number of farms in the United States halving inunder two decades.

While industrialization is often equated with the shift froman agrarian to a manufacturing economy, it encompassesmore than this. It means the establishment of a modelfor managing resources (capital, human, and natural)that seeks economic efciency through specialization,standardization, and consolidation. In the context offarming, this standardized a set of practices that can

be recognized as running counter to environmentalsustainability:

• Monoculture – The repeated cultivation of a singletype of crop on a piece of land. These crops areusually non-native and grown for processing orexport. Local ecological balances become massivelyupset, and carbon uptake in the soil is signicantly

diminished. Pests and disease spread much moreeasily without barriers provided by ecological differ-entiation. Non-native plants also usually require higheramounts of water and energy inputs.

• Pesticides/Herbicides – Instead of manual removalor planting naturally resistant varieties (which havenecessarily lower yields as the plant uses energyand nutrients for defense rather than size), industri-

alized farming employs the mass application of toxicchemicals to kill weeds and pests. Up to 99.7% ofherbicides never even contact target organisms.6 These chemicals then leech into the soil and localwater supplies.

• Fertilizer – Nitrogen is essential to plant nutrition,with a strong correlation between nitrogen levels andyield. Industrialized agriculture depletes nitrogen andother nutrient stocks in soil much faster than they canbe replaced, necessitating industrial manufacture of

nitrogen and other forms of fertilizer. However, lessthan 20% of synthetic nitrogen used in agriculturends its way into crops or animal products used byhumans.7 The rest is released into the surroundingenvironment, sometimes with cascading effectson water systems such as “dead zones” caused bynitrogen-fueled algae blooms.

Figure 2: Farms, land in farms, and average acres per farm

Source: USDA, Economic Research service using data from USDA, National AgriculturalStatistics Service, Census of Agriculture.




• Fossil fuel reliance – while allsectors of the modern economydepend on fossil fuels at somelevel, the industrialization ofagriculture has a particularlytransformative effect on energyinputs. In 1940, the agricultural

system was able to make 2.3calories of food for every calorieof fossil fuel energy, while as of2008 more than 10 calories offossil fuels are used for a singlecalorie of food.8 Industrializedagriculture operations leveragecheap fossil fuels to mechanizeas many phases of the cultivationprocess as possible.

These issues may seem a smallprice to pay for the health andgrowth of human society, but there are much moresustainable ways to grow food. Between 1910 and 1983,corn yields in the US increased by 346% on a per areabasis. However, the energy inputs for corn over this sametime period increased by 810%.9 Beyond this, millionsof tons of agricultural chemicals are released into theenvironment every year. In the long term, the destructiveexternalities of these practices will be felt. When GMcrops are added to this process, many of these effects

are amplied without providing increases in food supply.Additionally, GM products come with a whole new set ofissues, including genetic contamination and health risks tothe end consumer.

The First GMOThe development of an industrialized genetic modicationprocess began not with crops, but with livestock. Whilethe gene transmission mechanism was slightly different,it formed the scientic basis for later ventures intotransgenic research. Perhaps more notably, it laid the

groundwork for the manipulation of the regulatory system,which has since become a hallmark of corporate agricul-tural biotech practices.

Somatropin is a growth hormone that is naturallyproduced in abundance in cows following calving. Itstimulates lactation by allowing the cow’s body to usereserve energy stored in tissues for milk production.

Since discovery in the 1930s, numerous laboratories andagricultural businesses attempted to nd a method formass production of the substance. Early attempts wereunsuccessful, requiring the slaughter of twenty cows toproduce enough hormone for a single effective dose forone animal. A breakthrough was made when researchersfunded by the chemical corporation Monsanto were ableto use genetic manipulation to introduce the hormoneinto E. coli, a bacteria found in the lower intestine. The

bacteria multiply tremendously quickly, allowing for rapidmanufacture of the somatropin proteins. The extractedhormone was named recombinant bovine somatropin(rBST), also known as recombinant bovine growthhormone (rBGH).

Serious questions remained, however, as to the fullrange of effects stemming from elevated levels of thehormone. Initially, the Food and Drug Administration (FDA)was concerned about this as well. All of the availableresearch had been conducted by the chemical companies

themselves, and the FDA scientists harbored seriousdoubts as to the accuracy and scientic rigor presentin the reports. As Dr. Michael Burroughs, a veterinarianwith toxicology training assigned to the product said,“I very quickly understood that the data were intendedonly to demonstrate that rBGH effectively boosted milkproduction. The scientists working for Monsanto hadpaid no attention to the crucial questions.”10 After raising

Figure 3: Wheat Comparison“Wild” wheat “Improved” wheat

Source: Journal of Energy & Environment.“Fossil Energy and Food Security.”Volume 12. 2001.




the issue to his superiors and detailing his concerns toMonsanto, Dr. Burroughs found himself pulled off thestudy, ostracized, and eventually red. He sued and wonthe appeal, but ended up resigning because he felt theagency willfully closed its eyes in its desire to protect thecompany’s interests.

Beyond signaling the problematic relationship betweencorporate interests and the FDA, the controversial approvalof rBGH products signaled an important shift in FDApolicy. This transgenic hormone is not designed to treat anysort of disease or provide health benets, but is insteada product with a strictly economic purpose. Indeed, it isdetrimental to the health of both the animals (as evidencedby numerous studies citing uterine disorders, ovarian cysts,reduced fertility, and mastitis)11 and to humans (mastitisincreases the amount of white blood cells in milk, i.e., pus).Additionally, milk from treated cows has up to 75% higher

levels of IGF-1 (insulin-like growth factor 1), a hormonalsubstance produced in the pituitary gland, and has beenlinked to higher levels of the hormone in humans whoconsume it.12 This substance plays an important functionin cell growth, development, and division. Elevated levelshave been found to link strongly to lung, breast, colon, andprostate cancer. In Europe, which consumes more milk percapita than the U.S., rBST is banned.

Despite these concerns, the FDA proceeded withapproval, and the substance was soon marketed and sold

all over the country. Uptake was swift, with Monsantoembarking on a campaign of misinformation and intimi-dation of scientists and journalists who voiced criticism.Suppression through the courts and close ties withregulatory bodies proved to be an effective strategy andwould be repeated for later products.

Genetically Modied CropsBovine growth hormone proved to be an informative rststep in the application of genetic manipulation to foodproduction. The next time these efforts would go beyond

the manipulation of bacteria as a vehicle for chemicalproduction, and venture into the creation of new specieswith specic genetic modications.

The work the biotechnology companies poured intogenetic research was extensive and in many casesimpressive. However, the projects turned from moretraditionally scientic pursuits and toward corporate

interests. This research, while groundbreaking, wasshaped most clearly by the commercial demands of largebiotechnology companies. With their success at manipu-lating the regulatory process in the U.S., agribusiness settheir sights on the largest crops in the U.S. at the time,corn and soy.

While biotechnology promoters would argue otherwise,the mechanisms used for creating transgenic organismsare entirely different from the agronomic techniquesemployed since the advent of human agriculture.Historically, seeds from the best harvested plants weresaved and then planted in an attempt to induce cross-breeding. The most favorable, survivable traits are thenpassed on from one generation to the next throughsexual selection. Transgenic modication, however,requires the integration of foreign DNA into anotherorganism’s genetic code. Unfortunately for the transgenic

researchers, the genetic material lies in the nucleus ofthe cell and is extensively protected with mechanismspreventing the intrusion of foreign bodies.

Monsanto had been selling an herbicide under the nameRoundup with an active ingredient called glyphosatesince 1974. This chemical works by inhibiting the EPSP(5-enolpyruvylshikimate-3-phosphate) synthase enzyme,which is essential to cell growth in all plants. Initially, itwas used to spray down elds before planting, as itsbroad spectrum of effectiveness caused it to kill any

plants growing in the eld in a matter of days. The deadplant matter could then be tilled under, as the glyphosatebecomes essentially inert, not affecting germinatingseeds. While this technique was effective, creating aglyphosate-resistant plant would allow farmers to spraythe chemical even while the crops were growing, greatlyincreasing the versatility of the product. This became oneof Monsanto’s goals for the next decade.

Despite very well-funded research and development(R&D) efforts, scientists were unable to produce a

resistant plant. In 1984, a new CEO refocused theresearch division, putting an end to more open-endedprojects and pouring all resources into creating a viableglyphosate resistant soybean. Researchers tried a varietyof solutions, for the most part abandoning their usualcareful experiments in favor of wild home-run attemptswhere dozens of variables were changed at a time. Asolution was nally found in 1987, in one of the polluted




ponds located in close proximity to the company’sglyphosate factory in Missouri. Scientists were able toidentify the genes in the surviving type of bacterium thatblocked the chemical pathways upon which glyphosateoperated.

After two more years of searching for an effective

delivery mechanism, success was achieved using thenew “gene gun,” developed by the biotech companyAcracetus, which was acquired by Monsanto in 1996.Gene guns work by attaching genetic fragments tomicroscopic tungsten or gold “bullets” and shooting themen masse into an embryonic cell culture. Because thistechnique inserted the genes completely randomly, tensof thousands of trials were needed to come up with afew dozen plants. Another three years of eld testing andbreeding occurred before they came up with a single lineof viable, glyphosate-resistant soybean plants. In 1994,

the company felt the product was ready to market, andled for approval with the FDA.

At the heart of their push for approval was the conceptof Substantial Equivalence. Essentially, the argument putforth was that GM plants are roughly equivalent to theirnatural or conventionally bred counterparts. The enzymesand proteins produced by the plant are close enough tothe ones that humans have beeningesting for tens of thousands ofyears.

This allows these products toescape categorization as articialfood additives, which must undergotoxicological testing. Instead, theyare labeled as “generally recognizedas safe,” which is reserved for foodproducts in use before January 12,1958 (when the Food Additive Actwas passed) or because “scienticprocedures” have demonstrated that

there is no health risk.

What Monsanto argued, wasthat humans have a long historyof consuming DNA (indeed it isin everything we eat) and thattherefore the DNA inserted intotransgenic organisms wouldn’t

pose a health risk. Despite the patent absurdity of thisargument, the FDA went ahead with approval of thetransgenic soybeans, and established a precedent thatallowed for the future deployment of a number of GMcrops. The regulatory mechanisms behind this will bediscussed in more depth in the next section, but thisdevelopment illustrates the dangerous level of inuence

that large agricultural biotech companies had (and stillhave) on the regulatory process. While the FDA’s statedmission is to ensure safety for consumers, on the subjectof GMOs it has acted more like a promotional organi-zation for its large corporate sponsors.

GM Crops in the United States The enormous inuence and aggressive tactics ofagricultural biotechnology companies have drasticallychanged the composition and quality of American crops.While this change has been limited to the corn, cotton,

and soybean crops, well over half of all acreage for theseproducts is being cultivated with GM varieties. Thesecrops are also the most common ingredients in processedfoods, which has led to over 70% of processed foodsfound in supermarkets containing GM products.13 This,along with restrictions on GM labeling have made ittremendously difcult for American consumers to choosenon-GM alternatives.

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HT soybeans

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Figure 4: Adoption of genetically engineered crops

in the United States, 1996-2014

Data for each crop category include varieties with both HT and Bt (stacked) traits.Sources: USDA, Economic Research Service using data from Fernandez-Cornejo and McBride(2002) for the years 1996-99 and USDA, National Agricultural Statistics Service, June Agricul tural Survey for the years 2000-14.




Herbicide resistance is the deningtrait of some of the most popularGM products, but a 2008 studyby the Center for Food Safetyshows that herbicide resistant soy,corn, and cotton have actually led

to a 122-million-pound increasein pesticide use since 1996.Glyphosate usage has increasedover 15-fold since the introductionof Roundup-Ready crops in 1996.

As early as 1998, only two yearsafter these products were intro-duced, glyphosate-resistant weedsbegan to appear. The instances ofthese “super-weeds” has increased

quickly, with more than 65 varietiesidentied by the end of 2010. Farmsdeal with this by either increasingthe number of glyphosate applications, or turning tohigher-toxicity herbicides. This puts farmers in a compro-mising nancial situation as well, as nding resistantweeds on a farmer’s land can reduce its value by anaverage of 17% per acre.14

Furthermore, in a four-year long study from 2001 carriedout by researchers from the University of Nebraska,

soybean yields were shown to decline 5% when conven-tional varieties were replaced with transgenics. This “yielddrag” was caused by multiple factors. Another studycarried out at the University of Arkansas demonstratedthat the use of glyphosate impedes the rhizobiumbacteria, which are present in the roots of soybeans, andafx atmospheric nitrogen into the soil. Without additionalarticial fertilizer added, the yield of the plants wasaffected by up to 25% during dry periods. Additionally,both GM soy and corn crops have been shown to havereduced resistances to a variety of diseases.15

The usage of GM crops imposes a wide variety ofnegative effects, not just on the farmers that chooseto use them, but on the entire agricultural systemand on consumers. The accompanying increase inagro-chemical use is good for the large corporations thatsell the GM seeds and herbicides/pesticides, but doesunnecessary damage to the rest of the agrarian model.

The positive economic and environmental effects thathave been claimed have not stood up in the face ofindependent testing. They have further entrenchedspending on agricultural subsidies, which end updepressing food prices and ultimately nding their wayto the large corporate interests, which then continue thecycle through spending these resources to gain moreregulatory favors.

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Figure 5: Glyphosate and Super-weedsCorn, Soy, & Cotton

Source: Farmwars.info. . GMO Crops Increase Pesticide Use, September 2013.




The Regulatory EnvironmentThe United States: Friends in High PlacesWhile GM crops have become an inescapable part ofthe American food system, they are almost impossible tond in Europe, either growing on farms or in consumer

products. The difference in regulatory responses indeedillustrates disparate political climates, while also showingthe abilities of large corporations with long-term strat-egies and the right political connections to compromiseregulatory practices. Chemistry and biology may beobjective processes, but the exposure and use of testingin these elds can be subject to extensive manipulation.The large agricultural biotech companies that develop GMcrops and organisms have consistently employed a rangeof such tactics in the pursuit of unfettered market accessand higher margins.

This special relationship with U.S. regulators has beentaking shape since the Vietnam War, but it was duringthe 1980s that these agricultural biotech interests reallysolidied their ties to the federal government, all theway up to the Reagan administration. U.S. research andtechnology enterprises were, at the time, feeling risingpressure from foreign companies, particularly the largeJapanese industrial conglomerates. Genetic engineeringwas considered the forefront of agriculture, whereAmerican companies had enjoyed a position of global

leadership for decades.

This threat tied into two important policy planks of theReagan and Bush administrations, promoting corporateinterests and strengthening America’s global presence.These directives appear to have left limited room forconsumer safety or environmental considerations. In fact,FDA representatives wrote in a 1993 document that, inaccordance with government policy, their purpose wasnot to ensure consumer safety, but to “promote” the U.S.biotechnology industry at home and abroad.16

Attaining this power over regulators and lawmakersrequired not only nancial contributions, but an extensivenetwork of people across multiple agencies with personalconnections to the industry. Here, Monsanto and othercompanies have done an impressive job. The industry hasput former higher-ups in positions of real power in theFDA, United States Department of Agriculture (USDA),

Department of Justice, Environmental Protection Agency(EPA), and every presidential administration since JimmyCarter. Supreme Court Justice Clarence Thomas, formerSecretary of Defense Donald Rumsfeld, and even former

Secretary of State Hillary Clinton all spent time workingfor Monsanto or its subsidiaries.17 These friends in highplaces, helped by lobbying spending of over $70 milliona year,18 have allowed agricultural biotech corporationsa truly remarkable amount of access and input to theregulatory process in the U.S.

Patent law is an important starting point for examiningthis undue inuence. While living organisms were onceexpressly prevented from being patented, a series ofcongressional acts and Supreme Court decisions beginning

in 1970 have made it possible to obtain multiple kinds ofpatent protection for GM plants.19 The power and scope ofthese patents has grown with the industry, and is a criticalpiece of the industry model. Agricultural biotech companieshave taken a severe approach to patent enforcement,actively seeking out violations and rigorously prosecuting.

The main focus of these actions is “brown baggers,” orfarmers who save seeds from previous crops and replantthem. While this has been standard practice since theinception of agriculture, under the standard contracts

for GM seeds this is no longer allowed. The seeds areessentially classied as intellectual property, and thus“reproducing” them for prot constitutes a violation.Hundreds of such cases are brought up every year, with thevast majority of them ending in out-of-court settlements.Farmers have little chance of ghting these large multina-tional corporations, and those that run afoul publicly oftennd themselves isolated and professionally ruined.20

Interestingly, granting these patents at all is contradictoryto the argument of Substantial Equivalence, which has

been a central tenet of the industry’s arguments for lesstesting and regulation. Monsanto, for example, made theclaim that Roundup Ready soybeans needed no additionaleld testing because they were essentially the same asnon-GM soybeans. Their effects on both consumers andthe environment would therefore be “substantially equiv-alent.”21 At the same time, they claimed that the special




properties of the GM organism render it unique enough towarrant a patent.

This substantial equivalence argument forms the basisfor the FDA’s policy of allowing GM products withoutpremarket approval. An approval process still exists,but is not mandatory or standardized, and is instead

voluntary and consultative in nature. The USDA does havea premarket approval process, but allows companies toconduct and submit their own research. These companieshave worked to mitigate the appearance of this obviousconict of interests by collaborating with universities,think-tanks, and third-party laboratories.

American Research Institutions:In Search of ObjectivityHere the relationship between corporate interests andresearch institutions plays a key role. In 2005, almost

a third of all agricultural scientists reported consultingfor private industry. Beyond this, many universities grantcorporate afliate status in return for donations. In someextreme cases, university leadership and corporate boardsmay overlap, as in 2009 when South Dakota State’spresident was given a seat on the board of directorsfor Monsanto and a six-gure paycheck.22 Agriculturalresearch appears particularly beholden to corporateinuence. Private industry funding accounted for only 6%of total university R&D funding in 2010, while it providedover 60% for land grant university agricultural research.

This undue inuence on research has a number ofserious policy implications. Finding experts in the eldwithout bias becomes next to impossible as scientistsand researchers must toe the corporate line or risktheir livelihoods. Over the last couple of decades, theselarge multinational biotech companies have repeatedlyretaliated in a vicious way to any independent researchthat contradicts their assertions. Instead of refuting theirclaims through the scientic method, dissenting voicesusually nd themselves under attack personally and

professionally, often ending up jobless.

Manuela Malatesta, a university professor who experi-enced this states, “…research on GMOs is now taboo. Youcan’t nd money for it. We tried everything to nd morenancing, but we were told that because there are nodata in the scientic literature proving that GMOs causeproblem, there was no point in working on it.”23 Private

companies have effectively been able to monopolize“legitimate” research on their own products.

A particularly telling episode occurred in 1996; the autho-rized level of glyphosate residue allowed on soybeans wasincreased from 6 parts per million (ppm) to 20 ppm, justweeks before the release of Roundup Ready soybeans.

When asked for comment, the EPA’s toxicologist statedthat the change had been made because of studiesprovided by Monsanto.24 These studies were revisitedin 2003 for independent testing, several red ags wereraised. Monsanto refused to provide any of the raw datafrom these studies, claiming that it was “business con-dential” information.

While this condentiality argument is often made forresearch data, denying access to raw data is highly unusual.For the data and lab reports they were able to access, the

professors undertaking this examination noted a variety ofinconsistencies and suspect science. In one of the studiesusing rats, they only used older lab rats, which are widelyknown to be much less sensitive to harmful dietary effects.In several more of the lings, organ inspection appearsto have been carried out entirely by eyeballing, not evenincorporating a microscope, much less actual toxicologytests. Despite all of these issues, the initial approval wasnever ofcially revisited.

Figure 6: Sources of

University & College R&D Funding

Source: New Atlantis, National Science Foundation .The Sources and Uses of U.S. Science Funding, 2012.




Large agricultural biotech companiesare not opposed to all forms ofregulation though. When it suitsthem, they have used their closerelationships with various governmentagencies to pursue legal means ofensuring their products get to market.

A clear illustration of this are theactions taken by large agro-corporateinterests to keep consumers fromknowing which foods contain GMproducts. The ban on labeling rBST/rBGH milk was to keep it from beingstigmatized in the marketplace. Labelswere technically allowed, as long asthey stated that no difference hadbeen found between rBGH and thenaturally occurring cow hormone.

Clearly the aim of this regulation was not consumer safety,but promoting agribusiness and biotechnology. The manwho wrote these guidelines, announced in February of1994, was Michael Taylor, the FDA’s deputy commis-sioner. Taylor had represented Monsanto for more thanseven years prior to his appointment, and has spent hissubsequent career bouncing between upper managementat Monsanto and top positions at the FDA and USDA.While these regulations are being challenged withballot measures and in the courts, this blatant corporate

protectionism has succeeded in withholding informationfrom consumers for over a decade.

The European ApproachThe rollout of GM crops did not go as smoothly inEurope. The large agricultural biotech companies werestill well-funded, but had nowhere near the inuence onscientic and regulatory bodies they enjoyed in the U.S.In the U.S., the biotech companies were able to use theirfunding and favors to control research publication, andhad an arsenal of legal, nancial, and media tools they

used to control the greater narrative of GM agriculture.In Europe, they had to work within the system, insteadof dictating the system from the ground up. While thesecompanies spared no expense in trying to take controlof the process, they were ultimately unable to withstandthe pushback that came with independent testing and askeptical European public.

The regulatory protocol for GMOs in Europe was adopted

in April of 1990 by the European Community (nowEuropean Union). Under this model, companies mustpresent a technical dossier on the desired product to amember state’s relevant commission. The member statethen takes what steps it feels necessary to assess therisk. Following this, the commission sends this dossierto all of the other states, who have sixty days to requestmore information. After all member states are satisedwith the amount of data provided, the commission canthen authorize importation.

Roundup Ready soybeans, as well as a variety ofpest-resistant corn, managed to gain approval throughthis process in December of 1996, using researchdata provided by the sponsoring companies. In 1998, anew breed of aphid-resistant potato was submitted forapproval. This time, the Scottish Agriculture, Environment,and Fisheries ministry directed Dr. Arpad Pusztai, aworld-renowned biochemist to conduct independenttesting. Pusztai had examined the Monsanto-backedstudies on glyphosate-resistant soybeans publishedin 1996. He thought it was “very bad science,” but

considered himself a supporter of biotechnology and setout to give the credibility of his name and research toshow that GMOs were harmless.25

The results of his experiments informed him differently.The protein (lectin) that the modied organisms producedvaried signicantly between trials. Furthermore, the rat’sdigestive systems did not appear to be processing the GM

$0

$150

$300

$450

$600

$750

$900

1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010

: I

Industry FundingUSDA Funding

: I

Figure 7: Funding of Land Grant Agricultural Research(In Millions of 2010 Dollars)

Source: FoodandWaterWatch.org. Public Research, Private Gain: Corporate Inuence OverUniversity Agricultural Research, April 2012.




potato like conventional ones. Brains, livers, and testeswere less developed, while there was a proliferation ofstomach cells, which can facilitate the development oftumors. The immune system response suggested that themodied potatoes were being treated as foreign bodies.This was especially disturbing because the lectin genetested safely in its natural state. The unexplained effects

were therefore likely caused by the genetic insertiontechnique, which is in direct contradiction to what theparent companies and U.S. FDA had claimed.

Pusztai took his concerns back to the U.K. regulators, andexpressed them again in an interview segment on Britishtelevision. Initially the Rowett Institute, his employer, washappy for the attention, but things quickly took a turn. Twodays after the interview was broadcast, Pusztai’s contractwas suspended, his team dissolved, and all of his researchconscated. He was threatened with prosecution if he

spoke to the press. The head of the institute immediatelyembarked upon a media campaign aimed at discreditingthe GM trials and Pusztai himself. The institute alsoformed an audit committee, which reviewed the exper-iment and had Pusztai’s statements declared “unfounded.”

The media coverage was extensive, and the controversycaught the attention of the British House of Commons.They asked for testimony from Pusztai, forcing the RowettInstitute to give him the research data back. Pusztai thensent the data to twenty scientists around the world, who

agreed to prepare a report comparing the data to whathad been presented in the audit. The results, put on thefront page of one of Britain’s leading newspapers, werenot attering to the Rowett Institute. They showed thatsignicant results had been entirely ignored, and thatthe Rowett Institute’s treatment of Pusztai had beenunfounded and disturbingly harsh. They questioned theobjectivity of the institute, calling attention to the factthat in February of that year, the Rowett Institute signed acontract with Monsanto, which pledged 1% of the insti-tute’s annual budget.

This turned out to be a media relations nightmare for GMproponents, setting the stage for defeat on a continentalscale. British public opinion polls saw a rapid declinein approval ratings for the new technology. The issuegained a degree of political toxicity as politicians lookedto distance themselves from the unpopular Americanbiotech rms and their GM products.

Many of the largest food vendors in the U.K., includingTesco, Nestle, and McDonald’s, made pledges to notinclude any GM ingredients in their products.26 Whileattitudes vary across European countries and regions,political momentum built to such a point that in June 1999the European Commission reversed its decision to allowimportation of GM crops. By 2001, American corn exports

to Europe had declined 99.4% from their 1996 levels,slamming American farmers who had been promisedextra prots from the new technology.27

The fundamental feature separating biotechnology policyin the United States and the European Union concernsthe requirement to undergo testing. The E.U. processqualies products for testing through their method ofcreation alone (genetic engineering), while the U.S.policy species that only those organisms that couldpose a threat to the environment need to be tested. This

approach by U.S. authorities is predicated on the conceptthat organisms with genetic modication are no morerisky than new organisms bred with traditional means.

The European approach on the other hand adheres tothe Precautionary Principle, which states that when anactivity raises threats of harm to the environment orhuman health, precautionary measures should be takeneven if some cause and effect relationships are not fullyestablished scientically.28 While U.S. policy allows forpost-market testing (when obvious environmental or

health risks arise), European policymakers have insistedon independent science-based assurances beforeallowing GM products on the market. As of 2014 only twoGM crops can be cultivated in Europe, and neither areused for human consumption.




Targeting Developing MarketsSouth America: The United Republic of SoyEven before the 1994 approval of GM soybeans in theU.S., GM seed producers were making moves to deploytheir products in the next soybean hotspot, a rough cone

of extremely productive cropland covering Paraguay, andparts of Argentina, Brazil, and Bolivia. Regional cultivationof the crop began in the early 1980s, and has sincegrown to over 45 million hectares, an area roughly thesize of Sweden.29 This area recently overtook the UnitedStates in soy exports, earning the nickname “The UnitedRepublic of Soy.”

The rst point of entry was in Argentina. The governmentof Carlos Menem, ascending to power in 1989, wasenthusiastically pursuing deregulation and looking

to remove barriers to trade and foreign investment.Monsanto seized its opening in 1991, gaining an inu-ential spot on the National Advisory Commission onAgricultural Biotechnology (Conabia). Unsurprisingly,the body adopted the regulatory models that wereworking well for GM companies in North America. Noapproval or independent testing was required, and thecommittee spent many of its resources promoting the newtechnology in the media.30

The southern region of Argentina,

known as the Pampas, has been akey resource for Argentina since itssettlement. The pastureland waslegendary, supporting hundreds ofthousands of cows, both beef anddairy. Farmers grew corn, wheat,sorghum, peanuts, sunowers,soybeans, and a range of fruits andvegetables. The arrival of GM soycompletely changed the landscape.By that time in the mid-1990s, soil

fertility had been dropping andserious productivity concerns hadspread to many of the region’sfarmers.

Agricultural biotech companiesleveraged this opportunity, sellingseeds at one-third of the North

American prices, and packaging them with technicaladvice, including direct planting techniques. The initialboost in yields from these techniques was notable, andthe GM seed companies made sure to associate thiswith the new seeds. Due to the higher yields, prots wereup and farmers began ocking to the new technology,planting more and more of their elds with the new “magic

30000

35000

)

Others

Sun o wer

Wheat

So ybean

10000

15000

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A r e a

( t h o u s a n

d h a ze

0

5000

1991 1993 1995 1997 1999 2001 2003 2005 2007 2009

Figure 9: Field crops at ArgentinaArea, production, and grain yields from 1990 to 2010

Source: International Plant Nutrition Institute. Agriculture and nutrient Agriculture andnutrient management in the Southern Cone of Latin America, November 2011.

Figure 8: The United Republic of Soy

Source: Syngenta




seeds.”31 It was not long before other farmers in neigh-boring Brazil and Paraguay took notice.

In the U.S. and Argentina, large agricultural biotech corpo-rations brought their GM products to market by becomingso intertwined with the respective countries’ regulatoryprocesses that they ended up all but dictating the rules.

In Brazil, they took a very different, but similarly effectiveapproach, by essentially ignoring the regulatory authoritiesaltogether. They recognized that the Brazilian government,while noted for its environmental policies and advocacy,often comes up short when it comes to enforcement.Parallels can be drawn to the struggle over deforestation,where despite ofcial regulations, thousands of acres ofAmazon jungle are illegally cleared every year.

The Brazilian government’s initial GMO policy was rootedin a 1993 biodiversity agreement, which established

the Precautionary Principle as the guiding policy forbiotechnology, requiring before-market testing for any“genetically enhanced” organisms. However, by 1996 GMsoy was ooding across the border, and thousands of newacres were being planted every month.

Regulators realized that preventing this spread waslogistically impossible, and in the interest of gaining somelevel of regulatory sway, tentatively approved the crop in1998. While opponents managed to pass a labeling lawin 2003, successive “provisional measures” gave large

agricultural biotech companies the regulatory environmentthey wanted with regards to the seed market.

Once the legal framework was in place, the GM seedcompanies commenced squeezing their customers foradditional revenue. They had forced their way into themarket with aggressive pricing and by foregoing the

usual seed contracts, a wise strategy considering theirproducts were technically illegal. Following approval theybegan using the standard purchase agreements, whichmade saving seeds illegal, and then gradually moved toratchet up prices. Farmers who had bought into the GMagriculture system often found themselves unable toswitch back after sinking money into multi-year contractsfor seeds and agro-chemicals.

The transition to GM soy instigated momentous economicand demographic changes all across the region. Foreign

capital and local enthusiasm caused land prices to triplewithin a year in some places, leading to rapid and extensiveconsolidation. Every other major crop experienceddecreases in cultivation.32 The wide variety of foods tradi-tionally grown on these fertile plains turned into endlesselds of soybean monoculture. The social upheavals havebeen particularly acute in Paraguay, where each year, halfa million hectares are turned into soy elds, forcing theeviction of 9,000 rural families. Just 2% of the populationnow controls 85% of Paraguay’s farmland.33

Soy farming has turned Paraguay from an exporterof food to a net importer, despiteagriculture accounting for nearly aquarter of gross domestic product(GDP). Chronic malnutrition affects14% of children in the country, andmany more lack access to cleandrinking water.34 While Paraguay’seconomy has expanded with theGM soy boom, an enormous amountof added value is taken out of the

country. An estimated 50-80% ofproduction is controlled by Brazilianinterests, and more than 70% ofprocessing takes place after export.More than half of Paraguay’s soy issent to Argentina, where it is turnedinto cattle feed or biodiesel to fuelEuropean cars.35

1400

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o n n e s )

S K P N

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800

u t r e i n t c o n s

( t h o u s a n

d t

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400 N

0

1993 1995 1997 1999 2001 2003 2005 2007 2009

Figure 10: Fertilizer consumption in Argentina1993-2010

Source: International Plant Nutrition Institute. Agriculture and nutrient Agriculture andnutrient management in the Southern Cone of Latin America, November 2011.




This lack of economic diversication also leaves the regionexposed to price shocks. Even relatively minor uctua-tions in soy prices can drive entire farms out of business,prompting yet more consolidation. Planting so muchcontiguous land with a single variety also leaves the entireregion highly vulnerable to crop diseases. Large, densepopulations combined with low genetic variety is a recipe

for the evolution and rapid spread of pests and pathogens.

Repeated planting of a single crop also has well-docu-mented detrimental effects on soil productivity, whichhas re-emerged as a serious concern a decade afterbeginning this transition to GM soy. This soil degradationis further compounded by the overuse of agro-chemicals.Since the introduction of GM soy, glyphosate use inArgentina has grown from 1 million liters annually toover 150 million liters. The repeated spraying of thesechemical compounds renders the soil inert, unable to

support the bacteria that are fundamental to the decom-position process.36 To make up for this, farmers must usemore and more fertilizer, further raising input costs. From1997-2010, fertilizer consumption in Argentina almosttripled, while total crop production rose around 50%.37

The indiscriminate application of agro-chemicals has beenan insidious threat to public health. Local advertising forglyphosate conveys that it is “good for the environment”and “biodegradable.” While it may be less toxic than2,4-Dichlorophenoxyacetic acid, commonly called 2,4-D

(an active ingredient in the new generation of herbicides),growing pest populations and lax spraying regulationshave made the chemical omnipresent. Overall, Argentinefarmers use 4.3 pounds of agro-chemical concentrate peracre, more than double what U.S. farmers use.

In the Chaco province, birth defects quadrupled in thedecade following the introduction of GM farming, andin nearby Santa Fe, cancer rates are two to four timeshigher than national averages. Nearly 80% of the childrenin the region carried traces of the pesticide in their

blood.38 While many would think this warrants a newapproach to agro-chemical use, the national conversationhas been dominated by the GM companies and theircaptive regulatory bodies insisting on the necessity andsafety of these products.

IndiaThe negative impacts of the GM system have also beenfelt in India. Familiar issues, such as regulatory tampering,played a factor, but it was a combination of aggressivemarketing techniques and disregard for local growingconditions that proved especially destructive. Cottonhas long been an important crop in India, but is highly

vulnerable to insects and pests, commanding 55% ofall pesticide use while occupying only 5% of cropland.39 In 2002, Indian regulators approved pest-resistantcotton (known as Bt cotton for the Bacillus thuringiensisbacterium that has been added to it), swayed by claimsthat it would reduce the need for toxic chemicals, whileboosting yields and prots for farmers.

Due to the monsoons, the soil during planting seasonis often saturated. While this is how regional agricultureworked for the last 5,000 years, the companies selling

GM cotton seeds neglected to account for this. In thisextremely wet soil, the GM seeds were simply not viable.This did not stop the dealers from marketing the products.In addition to being more than four times the price of localseeds, buying the seeds necessitated buying into thewhole GM system, requiring new equipment, chemicals,and repurchasing seeds every year. Predatory lendingis rampant, and failing crops and falling cotton pricestriggered waves of bankruptcy across rural India.40

A popular narrative concerning GM cotton in India blames

its deployment for the suicides of over 250,000 farmers.While media outlets have found plenty of cases whereGM cotton seemed to be a leading factor, suicide ratesfor farmers did not actually increase after the 2002deployment of the crop, and remain lower than theoverall suicide rate.41 Nonetheless, this narrative reectsstrengthening negative public sentiment, which seems tohave spurred ofcial action by the country’s courts andregulators. The eld trials for GM rice have encounteredresistance in the Indian Supreme Court, which acknowl-edged that the current regulations governing GMOs are

inadequate to ensure public health and safety.

AfricaOver the last 15 years, rising global food prices and fallingforeign investment barriers have fueled a signicant rushfor agricultural land, headed up by large multinationalcorporations. Africa, with the largest remaining reservesof arable land, has become a major destination for




such investment. While foreign direct investment canbe protable for both sides, these relationships mustbe managed carefully to prevent exploitative practices.This heightened focus on agricultural land use has alsoserved to intensify the debate over GM crops. While someclaim that GM agriculture is Africa’s path to stability andprosperity, a signicant collection of corporations, govern-

ments, and non-governmental organizations are workingto promote organic farming as a more sustainable future.

Currently, the African Congress is neutral on the issue,with commercial use of GM crops allowed only in SouthAfrica, Egypt, Sudan, and Burkina Faso. South Africa hasembraced GM crops most enthusiastically, cultivatingalmost 5 million acres of GM corn, soybeans, and cottonin 2013.42 This stands in sharp contrast to countries suchas Malawi, Mozambique, Zambia, and Zimbabwe, whichhave all rejected food aid from the United States because

it included GM corn, even in the face of famine thataffected millions.43

Enormous upheavals would follow the implementationof GM agriculture. In sub-Saharan Africa, agricultureprovides 30% of GDP and almost 70% of employment.Just as in South America, the implementation of GMcrop systems would very likely lead to land consolidationand unemployment. Nearly one in every four people insub-Saharan Africa struggle with food insecurity, whichGM agriculture would exacerbate.44 GM proponents

repeatedly assert that their crops will bring higher yields,which will in turn be benecial to everyone. Even if theseassertions held up consistently under independent testing(they don’t45), yield is a misleading indicator of success.Aggregate global food production could already provide3,000 calories per person per day. Food scarcity occurs

because of poverty, waste, and problems with food distri-bution.46 Simply growing more food is not a satisfactorysolution, especially when it jeopardizes future health andproductivity.

Dependence on large multinational corporations is alsoa growing concern. In September of 2013 the Council

of Ministers of the Common Market for Eastern andSouthern Africa (COMESA) ruled that only standardized,certied seeds may be commercially sold among the 19member states. This essentially prevents small farmersfrom jointly collecting and selling seeds, a widespreadpractice in many regions. As large corporations are theonly ones with the resources to adhere to the testing andcertication requirements, this makes them the only legalsource for seed purchases.

The dependency trap the GM system relies on would put

further strain on already precarious economies. GM cropswould also jeopardize agricultural exports to Europe,Africa’s largest trading partner. While proponents arguethat organic and traditional farming will still be options,trade incidents with the U.S. have demonstrated that anyrisk of GM contamination can be grounds for completelycutting off food shipments to European markets.Furthermore, the tremendous biodiversity that is one ofthe continent’s greatest assets would be threatened bycreeping monoculture and genetic contamination.



ConclusionThe arguments made in favor of the current generationof GM products simply fail to hold up to extended timeperiods or independent testing. Instead, GM corporationsmanipulate regulators, research institutions, and media

outlets. These companies have been exposed for thesepractices time and time again, but still insist that they havethe customer’s best interests at heart. Monsanto’s recentrefusal to release data regarding the effects of theirpesticides and GM crops on bee populations is indicativeof their myopia and disinterest in any well-being beyondtheir sales revenues.47

Furthermore, the traits that the organisms are geneticallymanipulated to express have not delivered the promisedbenets. In an analysis of 77 studies conducted in eight

countries, a team of U.S. and French scientists found thatnearly half of major pest species had become resistantto Bt cotton or corn plants.48 Herbicide tolerant (HT)varieties have fared little better, with new varieties ofglyphosate-resistant ”superweeds” being discovered onan almost monthly basis.

Of the several thousand GM crop eld trials conductedsince 1987, over 650 have named higher yields astheir genetically targeted trait. Yet, none of these have

made it to commercialization, indicating the failure ofGM technology to be more effective than conventionalbreeding. The higher reported yields that follow theintroduction of GM crops is in large part due to changing

farming techniques, and increasing inputs such asfertilizer and agro-chemicals. A recent study conductedby the USDA’s Economic Research Service concludedthat the average per-acre cost of soybean and corn seedincreased 325% and 259%, respectively, between 1995and 2011. This is also the time period when plantedacreage of GM corn and soy grew from less than 20% tomore than 80-90%.49

All things considered, the risks associated with GMagriculture outweigh the benets. While genetic modi-

cation as a tool is neither inherently negative nor positive,the history of its use indicates that the GM product islargely deployed to increase short-term prots for agricul-tural biotech corporations at the expense of consumers,small farmers, and the environment. Industrializedagriculture is enough of a sustainability challenge on itsown, and examples from across the globe illustrate theextra level of distress that comes with adding geneticallymodied organisms into this system.

Disclosures

The information in this report represents the opinionsand estimates of its authors as of September 30, 2014and are subject to change without notice. Portfolio 21undertakes no obligation to notify any recipient of thisreport of any such change. It should not be assumed thatany of the securities transactions or holdings discussedwere or will prove to be protable, or that the investment

recommendations or decisions we make in the future willbe protable or will equal the investment performance ofthe securities discussed herein.

While the information presented, including statistics,third-party internet links, and articles were obtained fromsources believed to be reliable, Portfolio 21 does notguarantee its accuracy, completeness, or timeliness. It is

not to be construed as nancial or investment advice tomeet the particular needs of any individual or institutionalinvestor.

Past performance is not a guarantee of future returns.

© 2014 Portfolio 21 Investments, Inc. All rights reserved.



Endnotes

1. Lee, J. (2013) “Charts: World’s GMO Crop Fields Could Cover the US 1.5 Times Over.”Mother Jones , San Francisco. http://www.motherjones.com/blue-marble/2013/02/gmo-farming-crops-more-popular-than-ever-world-charts

2. James, C. (2013) “ISAAA Brief 44-2012: Executive Summary.” International Service for the Acquisition of Agri-Biotech Applications. http://wwisaaa.org/resources/publications/briefs/44/executivesummary/default.asp

3. Fagan, J., Antoniou, M., Robinson, C . (2012) “GMO Myths and Truths.” Earth Open Source, London. ht tp://earthopensource.org/les/pdfs/GMO_Myths_and_Truths/GMO_Myths_and_Truths_1.3b.pdf

4. Mission 2014:Feeding the World (2010) “Inadequate Food Distribution Systems.” Massachusetts Institute of Technology, Cambridge MA.http://12.000.scripts.mit.edu/mission2014/problems/inadequate-food-distribution-systems

5. O’Dell, L . (1997) “Agricultural Mechanization.” Oklahoma Historical Society, Oklahoma City, OK. http://digital.library.okstate.edu/encyclopedientries/a/ag005.html

6. Robin, M. (2008) The World According to Monsanto. The New Press, New York. p.186

7. Mingle, J. (2013) “A Dangerous Fixation.”Slate, New York. http://www.slate.com/articles/health_and_science/the_efcient_planet/2013/03/nitrogen_xation_anniversary_modern_agriculture_needs_to_use_fertilizer.html

8. Mission 2014:Feeding the World (2010) “Ineffective/Inadequate Agricultural Practices.” Massachusetts Institute of Technology, Cambridge MA.http://12.000.scripts.mit.edu/mission2014/problems/ineffectiveinadequate-agricultural-practices

9. Muir, P. S. (2014) “Fossil Fuels and Agriculture.” Oregon State University, Corvallis OR. http://people.oregonstate.edu/~muirp/fossfuel.htm

10. Robin 91

11. Robin 203

12. Butler, Dr. J. (2006) “White Lies: The Health Consequences of Consuming Cow’s Milk.” Vegetarian and Vegan Foundations, Bristol, UK. http://www.vegetarian.org.uk/campaigns/whitelies/whiteliesreport.pdf

13. Tarver-Wahlquist, S . (2008) “GE Food: Precaution Advised.” Green America, Washington DC. http://www.greenamerica.org/livinggreen/gmofoods.cfm

14. Robin 221

15. Robin 222

16. Robin 15617. Hankins, J. (2014) “Exper ts, Regulation, and Food.”Journal of Responsible Innovation, London. http://www.technologybloggers.org/science/

experts-regulation-and-food/

18. Food & Water Watch, (2010) “Food and Agriculture Biotechnology Industry Spends More Than Half a Billion Dollars to Inuence Congress.”Food & Water Watch, Washington DC. http://www.foodandwaterwatch.org/briefs/food-and-agriculture-biotechnology-industry-inuence/

19. , J. (2009) “Patent Law: How Patents Grew Over Time to Include Living Organisms.” Potter Productions, Beaverton, OR. http://cookingupastorycom/patent-law-how-patents-grew-over-time-to-include-living-organisms

20. Robin 206

21. Miller ibid

22. Richardson, Jill. (2012) “How Corporations like Monsanto have Hijacked Higher Education”AlterNet, 11 May 2012. http://www.alternet.org/story/155375/how_corporations_like_monsanto_have_hijacked_higher_education

23. Robin 177

24. Robin 174

25. Robin 180

26. GM Freeze. (2012) “Food Companies Reject GM Wheat.” GM Freeze, Manchester UK. http://www.gmfreeze.org/gmwheatnothanks/food-companies-reject-gm-wheat/

27. Robin 224

28. Science & Environmental Health Network (2014) “Precautionary Principle – FAQs, “SEHN. ht tp://www.sehn.org/ppfaqs.html




29. ProForest (2010) “Soy Production in South America: Key Issues and Challenges.” ProForest, Oxford, UK. http://www.proforest.net/objects/news-objects/soy-production-in-south-america-key-issues-and-challenges

30. Robin 258

31. Robin 260

32. Lence, S.H. (2010) “The Agriculture Sector in Argentina: Major Trends and Recent Developments.”The Shifting Patterns of AgriculturalProduction Worldwide, The Midwest Agribusiness Trade Research and Information Center, Ames, IA. http://www.card.iastate.edu/books/shifting_patterns/pdfs/chapter14.pdf

33. Gateway To South America (2013) “Soya Agribusiness and Land Consolidation in South America has Increased Under Left WingGovernments.” Gateway to South America , Buenos Aires. http://www.gatewaytosouthamerica-newsblog.com/brazil/brazil-farms/soya-agribusiness-and-land-consolidation-in-south-america-has-increased-under-left-wing-goverments/

34. Associated Press (2013) “Paraguay’s Incoming leader to Expand milk Handouts to Fight Child Malnutrition and Poverty.” Associated Press, 22May 2013. http://www.foxnews.com/world/2013/05/22/paraguay-incoming-leaders-to-expand-milk-handouts-to-ght-child-malnutrition/

35. Hobbs, J. (2012) “Paraguay’s Destructive Soy Boom.” New York Times, 2 July 2012. http://www.nytimes.com/2012/07/03/opinion/paraguays-destructive-soy-boom.html

36. Robin 264

37. Duggan, M.T. (2012) “Outlook and Update on Phosphate Fertilizer Use in South America with Emphasis on Brazil andArgentina.” Fertilizer Latino-Americano Conference 2012, Buenos Aires. ht tp://www.slideshare.net/martintorresduggan/phosphate-fertilizer-use-in-brasil-and-argentina-fertilizer-latinoamericano-confernce-2012

38. Warren. M., Pisarenko, N. (2013) “As Argentina’s Pesticide Use Increases, Many Worry About Growing Health Problems.” Associated Press, 20October 2013. http://www.hufngtonpost.com/2013/10/20/argentina-pesticides-health-problems_n_4131825.html

39. Robin 295

40. Robin 298

41. Plewis, I. (2014) “Indian Farmer Suicides: Is GM Cotton to Blame?”Signicance, Vol. 11, February 2014. http://onlinelibrary.wiley.com/doi/10.1111/j.1740-9713.2014.00719.x/pdf

42. Stieber, Z. (2013) “GMOs, A Global Debate: South Africa, top GMO-Producer in Africa.”Epoch Times, 19 October 2013. http://www.theepoch-times.com/n3/323635-gmos-a-global-debate-south-africa-top-gmo-producer-in-africa/

43. DeMoss, J. (2005) “Bioengineering and the Fate of Africa: The Economics of GMOs” University of Michigan, Ann Arbor MI. http://sitemaker.umich.edu/africa.gmo/economic_issues

44. Bremner, J. (2012) “Populat ion and Food Security: Africa’s Challenge.” Population Reference Bureau, Washington DC. http: //www.prb.org/Publications/Reports/2012/population-food-security-africa-part1.aspx

45. Gurian-Sherman, D. (2009) “Failure to Yield: Evaluating the Performance of Genetically Engineered Crops.” Union of Concerned Scientists,Cambridge MA. http://www.ucsusa.org/assets/documents/food_and_agriculture/ failure-to-yield.pdf

46. Inadequate Food Distribution Systems ibid.

47. Lozanova, S. (2014) “Food Companies Rally to Protect Bees, While Pesticide Giants Dispute the Evidence.” Triple Pundit, San Francisco. http://www.triplepundit.com/2014/06/battle-bees-food-giants-support-preservation-pesticide-companies-push-back/

48. Stieber ibid.

49. Roseboro, K. (2013) “The GMO Seed Cartel.”The Organic & Non-GMO Report¸ February 2013. http://www.non-gmoreport.com/articles/february2013/the-gmo-seed-cartel.php#sthash.cyEv0iLo.dpuf





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Portfolio 21 the Case Against GMOs