Or, How Environmental Groups Need to Lose the Dogma

Last summer, I found out a coworker was the head of the local Sierra Club chapter and he suggested I get involved with some local campaigns. I admit to not being terribly involved. The major campaigns near me have emphasized stopping Washington from exporting coal to China and I just don’t have much interest¹. But earlier this summer, as I publicly expressed support for genetic engineering², I happened to check the Sierra Club’s policy. I found it absurd. The Sierra Club’s official policy was a complete moratorium on all planting of GE crops, even ones that have been approved for a decade. It even seemed to deny the possibility of significant humanitarian advances like Golden Rice ever being a good idea. The policy was also ten years old — how much has happened in that time? Friends however pointed out that you can’t agree with every policy of an organized group and the Sierra Club seems pretty effective politically, especially in the regulatory space. So I stayed.

I subscribed to the biotech mailing list, misleadingly called “Sierra Club’s Biotech Forum”. Recently I was kicked off that list seemingly for privately asking the head of the biotech committee why the biotech policy can’t be revisited. Neither the committee head nor Sierra Club’s member services have responded to my enquiries. My membership is up this month. I probably won’t be renewing.

Please see a newer post for my current thoughts.

A Timeline of My Interactions With the Sierra Club

• Summer 2011: I dip my foot into activism and specifically help out in a campaign against the state route 99 viaduct replacement project. This was essentially a last ditch effort to reject an extremely expensive deep-bore tunnel.
• September 2011: I became a paying member of the Sierra Club.
• May or June 2012: I join the misnamed “biotech forum” email list. I quickly discover that the list is one-way: short emails with links about current GE issues, often petitions.
• June 14: I sent a single email in response to a “take action” message to sign a petition to tell my senator I support Senator Bernie Sanders poor GMO labeling legislation. Since the list is moderated, it must be approved. It is not. The moderator does not separately reply as to why my message was inappropriate.
• August 6: I again try responding, only this time to a story about GMO crops and Kevlar tires which I knew probably wasn’t as simple as it was being purported. Again, my email was never posted.

At this point we get to the depressing part. On August 30, after getting an email about “Six GMO foods that may soon hit your dinner table” complete with a link to a Natural Society story which I won’t link here³, I emailed the moderator and head of the biotech community directly to ask what was specifically so harmful about the Arctic Apple (since it was on the list) and why she considered that news source reasonable. Our conversation over the next few days was brief. Ultimately I was curtly told that the policy was the policy and wasn’t going to be revisited. When I replied pointing out that the field of biotech has advanced a lot (Golden Rice!) since the policy was approved, I was independently informed by the mailing list software that I had been removed by another person. I emailed the moderator to ask if this was intentional, but have not received a response. Since I haven’t received a response, I doubt asking for permission to post private emails would be fruitful, so you’ll have to take my judgement for the tone of these messages. The moderator’s responses were dogmatic and short. The contradiction in calling the mailing list a “forum” was clearly lost.

Still, biotech really isn’t a topic the Sierra Club spends much time on, despite having a policy. So I waited a few days to see if my query about being removed from the mailing list was intentional — obviously it was intentional, but I wanted to give the moderator a chance to respond. My email traffic could hardly be called abusive: a total of two sent to the mailing list directly (neither approved) and five to the moderator (including my final query) with three responses from her.

The Club Doesn’t Respond

On Monday, I emailed member services for the Sierra Club to explain that (a) I think their biotech policy needs to be re-visited and (b) to ask if it was Club policy to remove people from one-way mailing lists. I chose member services because it seemed the best option on their contact page and because presumably someone actually reads it⁴. The email included the full email conversation that led to me being kicked off the list — since the moderator (and head of the biotech committee) was acting on behalf of the Sierra Club, I do not consider it a violation of privacy to share them with the Club. I also noted that this has made it much less likely I would renew my membership. I’ve not received any response, not even “we’ve received your email”. I can only assume they think I’m a crank and are ignoring me. Well, perhaps I am.

But I don’t think I would be so cranky if the Sierra Club and its officials showed the slightest interest in discussion. If the head of the committee had just said she doesn’t have time to discuss the policy right now but hadn’t kicked me off the list, then I could probably just accept that I should wait. But why remove me from the list? Is just knowing there’s one person on the list who doesn’t agree so damaging? Worse, the Sierra Club leadership, when informed of this, chooses to be silent.

Why Dogmatism is a Problem

I knew that the Sierra Club was dogmatic. All large environmental organizations are. That’s their choice of course, but it’s my choice to decide not to give them money for it. I can also tell my friends why I don’t support the Sierra Club. But I also think it represents a larger problem than just making me cranky: if you repeatedly tell your supporters that something just has to be stopped, then they will take a dogmatic view. Discussion of other options or trade-offs isn’t possible. Even if, behind the scenes, the Sierra Club’s lobbyists are good at arguing for “least bad” options, the perception is far different. It encourages dogmatic and unreasonable position-taking. Possible political allies can become firm opponents even if a compromise could be made. Even if a compromise is critical to actually getting anything done.

From previous posts you might get the impression that I think concerns about the pesticide clothianidin are small and not important. But almost every single conventional corn seed in the United States gets pesticide¹ coatings, usually including a neonicotinoid and a fungicide. It’s unlikely that every field actually needs that neonicotinoid seed coating to maintain yields. Leaving aside impacts on bees, that kind of use could drive pest resistance quickly. Unlike Bt traits in most of those same corn kernels, there’s no requirement to have refuges for pesticides. So, I do actually care about pesticide use but the conversation is so broken it’s hard to be “in the middle”. Overuse of pesticides isn’t limited to clothianidin. If we restricted clothianidin, there are other pesticides available … which would also be over-used.

Those advocating for bans concentrate on single pesticides when the larger problem is that we don’t have enough research to tell us when and how to use many pesticides most effectively. Farmers depend on under-funded federal and regional government and academic institutions as well as industry — that many non-farmers don’t trust. We need more research and more education so the public trusts the process and understands it — pesticides are absolutely necessary to support our population. However the choice isn’t between “none” and “whatever industry wants”, as the conversation is currently presented.

The petition I’ve been writing about is specifically about a single pesticide, clothianidin, a member of the neonicotinoid family. The rapid adoption of this pesticide has probably led to reductions in other pesticide applications (if someone has research on this I’d love to see it — I’ve only seen one small table in a perspective-style article). But that it so quickly gained such huge market share makes it a good target. What else could explain bee die-offs? It’s so convenient.

But the evidence just doesn’t look that clear to many researchers. In writing this article, I spent some time re-reviewing the introductions to many recent papers on the subject and it’s pretty clear to me that colony collapse disorder is just not well understood yet. It’s certainly not so clear that we can say “if we just stopped using clothianidin everything would be better”. But if you read the propaganda from anti-pesticide groups, you could be forgiven for thinking that was the case. For one, there are plenty of other pesticides that act similarly to clothianidin — and there isn’t any outstanding action to ban those. Nor would an attempt to ban all neonicotinoids entirely get anywhere in the current regulatory system.

Our regulatory system in the current environment seems compromised. It has no teeth to really monitor or punish misuse of pesticides, except when the misuse is high profile (e.g. poisons or affects a lot of people). Agencies are underfunded and dependent on industry for a lot of important research. Public research itself is underfunded. Big questions on how to use pesticides effectively to maintain yields isn’t being done². But if you’re going to restrict a useful tool, you have to demonstrate to farmers it’s either unnecessary in many circumstances or so actively harmful that there’s no question. Neither of these has really been done from what I can see, at least for clothianidin.

The conversation is broken. Information going into the conversation is missing or misused. PANNA’s report given to the EPA to support the dangers of clothianidin is a mish-mash of studies, many not even studying clothianidin (or related pesticides) and even sometimes pesticides intentionally applied to hives. How can the EPA use that to make a convincing case that clothianidin use should be restricted that will hold up in court? I haven’t read Bayer’s submission for this petition yet, but likely it’s misleading, only in other ways. But PANNA’s case will look convincing to many and makes a clear argument. The public, which in general fears pesticides and “chemicals”³, may agree and think the EPA is biased and not protecting them. Meanwhile, industry and (some) farmers thinks the EPA over-emphasizes risks to the detriment of enterprise.

What I’m not seeing is wide-spread interest in actually doing research to find out how to best use pesticides. In strawberry fields in Florida, they are now using a system that predicts when to apply fungicide. For corn seed coating it would have to be more complicated: what do you measure during the previous season and during over-wintering to decide whether or not to coat a seed (and with what)? But many of the foes of pesticides don’t really believe they can be used responsibly, so they don’t advocate for more research, they advocate for bans …. which of course industry (and farmers) are going to dig in and resist. And we sit in the middle wondering why the EPA isn’t protecting us. But in my opinion, they are doing a remarkable job in a poisoned political environment to balance public and environmental safety with effective and efficient business.

If we want to know why the EPA isn’t protecting the bees, then we should get the federal government funding more research and more educational outreach to explain the results. They are already doing some — the EPA’s response letter mentions several projects in combination with states — but no doubt they could do more. Perhaps the EPA could re-do certain experiments their response letter criticizes as being done poorly. Instead of waiting for more research to come in (or claiming that the current research is good enough to make decisions either way), why not pay for lots more research now? Of course, the government funds so little science at the best of times … but I can dream. Write your congress-person: scientific research may drive economic innovation, but we can actually use it to make good decisions too!

The most “meaty” part of the EPA response to the emergency petition to ban clothianidin is the support documents to the main response letter. The EPA’s supporting document takes each argument and citation given in the petitioners’ State of the Science report writtten by PANNA (Pesticide Action Network North America) and classifies how important the EPA considers each study for making a decision.

In this document, the EPA is trying to judge the usefulness of the evidence presented by the petitioners. First, is it a relevant piece of research? That is, are the experiments in a study related to >clothianidin (or a closely related neonicotinoid)? Does the experiment represent how clothianidin is used in the field? Secondly, the EPA needs to know if the result given is a strong result. Did it have good study design? Are there good controls? Were statistics used appropriately? But that’s not how PANNA chose to provide their evidence. PANNA and the EPA differ quite a bit on how they use scientific evidence.

The PANNA report¹ provides as evidence a lot of studies done on pesticides other than clothianidin (and surprisingly many were studies not even on neonicotinoids!). The EPA document is thus a bit repetitive and follows a very similar pattern: summarize the study’s methods and results, note any flaws or concerns, then note the results are of “low qualitative value for use in clothianidin risk assessment”. Another set of results provided are fairly interesting behavioral results for sub-lethal exposures. Unfortunately most of these studies either weren’t actually for neonics or used exposure amounts larger than are normally seen in the field. These studies are possibly great science, but not as useful for the EPA to do appropriate (and legal) risk assessments.

Sometimes the EPA’s analysis is a little bit more interesting and assesses actual methodological flaws. I am intentionally leaving out the study authors or title to not have it be searchable² . If you want to find the underlying study, go download the source EPA document and look up the study.

Author, et. al. in a semi-field study (with 2300 bees/colony) reported no decrease in bee attendance at a feeder in the presence of 6 µ/kg imidacloprid, but that activity (defined as feeding on sucrose solution) at this concentration was decreased compared to controls during four days. Bees exposed to fipronil (2 µ/kg) were reported to exhibit both a decrease in attendance and a decrease in activity. The study used an unbalanced design with 8 controls temporally spaced prior to the experiment and one control and three treatment colonies used during the treatment. The authors then pooled the data from the 9 control plots. EFED typically recommends using only concurrently run control and treatment groups and an equal number of control and treatment groups. Of the three treatment groups, two exhibited a significant decrease in bee activity by the 4th treatment day, while one group experienced no decrease. The authors did not quantify this difference in the article other than to report it was significant. The study authors did not report food (sucrose) consumption to the feeder nor any colony parameters making the relevancy of this study on effects on full colonies under natural field conditions somewhat unclear, but the authors did use environmentally relevant concentrations of imidacloprid. This study would likely be considered of low qualitative use for clothianidin risk assessment purposes because of its unbalanced test design with only one control hive, pooling of controls with previous data prior to conducting statistical analysis, inability to define a dose-reponse given that only one treatment concentation was tested, unclear definition of “active” bees and how this parameter was observed and validated, and lack of measurement of food consumption by the bees.

Notice that this doesn’t say “we think this study isn’t very good”. Instead, it gives reasons why the study likely isn’t showing what PANNA claims it shows and probably isn’t a good one to use for risk assessment. Note that the study in question is cited elsewhere in literature — it’s not so poor that it’s been ignored by other scientists. It just has enough flaws that the EPA doesn’t consider it a very strong result. Contrast this now to how the petitioners describe the same study³:

This study investigated the sub-lethal effects of two insecticides in semi-field conditions on the foraging behavior of honey bees. Imidacloprid and fipronil were chosen because both behave systemically, were recently introduced, considered highly toxic to bees, had shown sub-lethal effects on bees in lab conditions and had been implicated in honey productivity declines in Europe. The primary aim was to address a gap in environmental assessment of systemic pesticides by improving on the methods used to quantify foraging behavior changes. Bee colonies were placed in enclosed tunnels and their feeding behavior video recorded over a period of five days, constituting a cumulative effects study much shorter than a bee or hive lifecycle study would be. With imidacloprid at 6.0 µg/kg, inactive bees those visiting the feeder, but not feeding increased over time in relation to active bees. With fipronil at 2.0 µg/kg, most bees stopped coming to the feeder by the last day, and the few that did tended to be inactive. Convulsions and paralysis were also observed in bees feeding on fipronil-contaminated sub-lethal levels 70 times below the referenced LD50s. They also concluded that their experimental protocol “provided an indispensable interface between controlled conditions in the laboratory and the field”, which suggests its adoption in regulatory testing of sub-lethal effects.

Note that PANNA notes no issues with this study. This is common in this document — studies I’ve read before are described in ways that ignore flaws, caveats or complications and emphasize results that support their position⁴. To PANNA, each study that at least partially supports their position is more evidence. That some studies are more convincing than others isn’t relevant. Noting flaws in that research or futher work that would be needed to make the case more certain doesn’t fit into that mindset. In other words, this document, though titled “Pesticides and Honey Bees: State of the Science”, is not a scientific document. I mean this in a philosophic sense: the PANNA document was not written with a scientific mindset of including all relevant issues, even if they do not fully support their policy position.

However, it looks pretty scientific to a casual reader. If you were passed a Facebook post about this petition — save the bees! — and dutifully decided to actually read some of the documents, you’d probably pick out the main “state of the science” report that the petition claims as its main evidence. While reading it, you would see all these scientific studies and think the case to ban clothianidin must be pretty straightforward. When the EPA responds denying the petition, the EPA looks like it is “ignoring the science”, even though all the EPA is doing is taking a properly critical attitude. Thus, the narrative that the EPA is in bed with industry and will always bend the science to protect them, is maintained. Hopefully something good can come out of this though: perhaps the suit will force a compromise and the EPA may regulate use to mitigate known harms (e.g. such as clothianidin-contaminated planter dust responsible for some acute bee-poisoning cases⁴).