Environmental Assessment

Use of Row Crop Farming and Genetically-modified,

Glyphosate-tolerant Corn and Soybeans

on

National Wildlife Refuges and Wetland Management Districts

Lead Agency: United State Fish and Wildlife Service

Midwest Region

March 2011


ii
iii

Environmental Assessment for the Use of Row Crop Farming and Genetically-modified, 

Glyphosate-tolerant Corn and Soybeans on National Wildlife Refuges and Wetland 

Management Districts in the Midwest Region

Abstract: The Midwest Region of the U.S. Fish and Wildlife Service uses row crop farming on 

lands within the National Wildlife Refuge System to achieve a variety of management 

objectives. This environmental assessment evaluates the effects of the use of geneticallymodified, glyphosate-tolerant (GMGT) corn and soybeans and the use of farming as a 

management tool for multiple objectives on National Wildlife Refuge System lands. The 

evaluation is based on the issues and concerns identified during the planning process. Initially

four alternatives were evaluated: continue farming for multiple objectives with GMGT corn and 

soybeans allowed (no action); farming for habitat restoration objectives only, GMGT corn and 

soybeans allowed; farming for multiple objectives, GMGT corn and soybeans not allowed; 

limited row crop farming, GMGT corn and soybeans not allowed. Upon completion of a public 

review period, comments were evaluated and as a result of this process a fifth alternative was 

developed and selected; continue farming for multiple objectives, GMGT corn and soybeans 

allowed for habitat restoration only. The evaluation of this new alternative is also included in the 

document. The purpose of the proposed action is to administer a farming program that 

contributes to achieving the establishing purposes for lands of the National Wildlife Refuge 

System or the mission of the National Wildlife Refuge System.

Responsible Agency and Official:

Tom Melius, Regional Director 

U.S. Fish & Wildlife Service

Bishop Henry Whipple Building 

1 Federal Drive

Fort Snelling, MN 55111

Contacts for additional information about this project:

Richard Speer

U.S. Fish & Wildlife Service

NWRS

Bishop Henry Whipple Building 

1 Federal Drive

Ft. Snelling, MN 55111
iv
v

U.S. Fish and Wildlife Service 

National Wildlife Refuge System

Midwest Region

Environmental Assessment 

Use of Row Crop Farming and Genetically-modified, Glyphosate-tolerant Corn and Soybeans on National Wildlife 

Refuges and Wetland Management Districts 

Chapter 1: Purpose and Need.................................................................................................................................1 

1.1. Purpose .................................................................................................................................................................1 

1.2. Need for Action ....................................................................................................................................................1 

1.3. Decision Framework ............................................................................................................................................1 

1.4. Background ..........................................................................................................................................................3

1.4.1. HabitatRestoration...............................................................................................................................4

1.4.2. Habitat Management ...........................................................................................................................4

1.4.3. Supplemental Food for Wildlife .........................................................................................................4

1.4.4. Attracting Wildlife for Viewing and Photography .............................................................................5

1.5. Authority, Legal Compliance, and Compatibility ................................................................................................5

1.6. Coordination with Other Regions and Agencies ..................................................................................................5

1.7. Public Outreach ....................................................................................................................................................5

1.7.1. Wildlife Issues ....................................................................................................................................6

1.7.2. Habitat Issues ......................................................................................................................................6

1.7.3. Socioeconomic Issues .........................................................................................................................6

1.8. Issues Beyond the Scope of This EA ...................................................................................................................7

Chapter 2: Description of the Alternatives ............................................................................................................8

2.1. Formulation of Alternatives .................................................................................................................................8

2.2. Alternatives Considered but Not Developed ........................................................................................................8

2.2.1. No Farming .........................................................................................................................................8

2.2.2. Unmanaged Succession .......................................................................................................................9

2.3. Elements Common to All Alternatives .................................................................................................................9

of Agriculture ...................................................................................................................................9

Wildlife Refuge System Improvement Act of 1997 .......................................................................10

2.3.3. Adherence to FWS Appropriate Use and Compatibility Policies ..........................................10

2.3.4. Agricultural Lands Will Decrease on Refuge System Lands .............................................................11

2.3.5. Procedures and Limits on Herbicide Use ...........................................................................................12

2.3.6. Integrated Pest Management ..............................................................................................................12

2.3.7. Adherence to Midwest Region Refuge System Farming ...................................................................12

2.4. Alternatives Considered .....................................................................................................................................13

2.4.1. Alternative A: Continue Farming for Multiple Objectives 

Soybeans (No Action) ......................................................................................................................13

2.4.2. Alternative B: Farming Only for Habitat Restoration Objectives, With th
vi

Soybeans ..........................................................................................................................................14

2.4.3. Alternative C: Farming for Multiple Objectives, GMGT Corn and Soybeans Not Allowed ..........15

2.4.4. Alternative D: Limited Row Crop Farming, No GMGT Corn and Soybeans .................................16 

2.4.5. Alternative E: Continue Farming for Multiple Objectives, GMGT Corn and Soybeans Allowed for 

Habitat Restoration Only (Selected Alternative)..........................................................17

Chapter 3: Physical and Social Environment .........................................................................................................19

3.1. Introduction ..........................................................................................................................................................19

3.2. Habitat ..................................................................................................................................................................19

3.3. Existing Management of Refuge System Lands ...................................................................................................23

3.4. Wildlife .................................................................................................................................................................23

3.5. Threatened and Endangered Species ....................................................................................................................24

3.6. Invasive Species ....................................................................................................................................................25

3.7. Socioeconomic ......................................................................................................................................................25

3.8. Cultural Resources ................................................................................................................................................25

Chapter 4: Environmental Consequences ..............................................................................................................26

4.1. Effects Common to All Alternatives .....................................................................................................................26

4.1.1. Endangered and Threatened Species ...................................................................................................26

4.1.2. Cultural Resources ...............................................................................................................................27

4.1.3. Organic Soybeans ................................................................................................................................27

4.2. Effects of Management Alternatives ....................................................................................................................28

s, GMGT Corn and Soybeans Allowed (No 

Action)...............................................................................................................................................29

4.2.1.1. Summary of Alternative A Effects ......................................................................................29

4.2.1.2. Wildlife Issues .......................................................................................................................29

4.2.1.3. Habitat Issues .........................................................................................................................32

4.2.1.4. Socio-economic Issues ....................................................................................................34

4.2.2. Alternative B: Farming for Habitat Restoration Objectives Only, GMGT Corn and Soybeans 

Allowed ............................................................................................................................................35

4.2.2.1. Summary of Alternative B Effects .......................................................................................35

4.2.2.2. Wildlife Issues .......................................................................................................................36

4.2.2.3. Habitat Issues .......................................................................................................................38

4.2.2.4. Socio-economic Issues ..........................................................................................................40

4.2.3. Alternative C: Farming for Multiple Refuge System Purpose

Allowed ............................................................................................................................................41

4.2.3.1. Summary of Alternative C effects ........................................................................................41

4.2.3.2. Wildlife Issues.........................................................................................................................42

4.2.3.3. Habitat Issues ........................................................................................................................45

4.2.3.4. Socioeconomic Issues ...........................................................................................................46

4.2.4. Alternative D: Limited Row Crop Farming, No GMGT Corn and Soybeans .....................................47

4.2.4.1. Summary of Alternative D Effects ........................................................................................47

4.2.4.2. Wildlife Issues ........................................................................................................................47

4.2.4.3. Habitat Issues ........................................................................................................................50

4.2.4.4. Socio-economic Issues .........................................................................................................52

4.2.5. Alternative E: Continue Farming for Multiple Objectives, GMGT Corn and Soybeans Allowed for 

Habitat Restoration Only (Selected Alternative)..........................................................53

4.2.5.1. Summary of Alternative E Effects ........................................................................................53

4.2.5.2. Wildlife Issues ........................................................................................................................53
vii

4.2.5.3. Habitat Issues ...................................................................................................................57

4.2.5.4. Socio-economic Issues .........................................................................................................58

4.3. Environmental Justice..........................................................................................................................................61

4.4. Cumulative Impacts Analysis ..............................................................................................................................61

4.4.1. Alternative A: tives, GMGT Corn and Soybeans Allowed (No 

Action)..............................................................................................................................................62

4.4.1.1. Wildlife Issues ......................................................................................................................62

4.4.1.2. Habitat Issues ........................................................................................................................62

4.4.1.3. Socio-economic Issues ..........................................................................................................63

4.4.2. Alternative B: Farmi Habitat Restoration Objectives Only, GMGT Corn and Soybeans 

Allowed ............................................................................................................................................63

4.4.2.1. Wildlife Issues ........................................................................................................................63

4.4.2.2. Habitat Issues ........................................................................................................................64

4.4.2.3. Socio-economic Issues ..........................................................................................................64

4.4.3. Alternative C: Farming for Multiple Objectives, No GMGT Corn and Soybeans .............................64

4.4.3.1. Wildlife Issues .......................................................................................................................64

4.4.3.2. Habitat Issues .......................................................................................................................65

4.4.3.3. Socio-economic Issues ..........................................................................................................65

4.4.4. Alternative D: Limited Row Crop Farming, No GMGT Corn and Soybeans ....................................66

4.4.4.1. Wildlife Issues .......................................................................................................................66

4.4.4.2. Habitat Issues .......................................................................................................................66

4.4.4.3. Socio-economic Issues ..........................................................................................................66

4.4.5. Alternative E: Continue Farming for Multiple Objectives, GMGT Corn and Soybeans Allowed for 

Habitat Restoration Only (Selected Alternative) .....................................................................67

4.4.5.1. Wildlife Issues .......................................................................................................................67

4.4.5.2. Habitat Issues ......................................................................................................................68

4.4.5.3. Socio-economic Issues .........................................................................................................69

Chapter 5: Consultation and Coordination ...........................................................................................................69

5.1. Planning Team and Contributors .......................................................................................................................69

5.2. Agencies Consulted ...........................................................................................................................................69

 5.3. Public Comments on Draft Environmental Assessment................................................................69

Appendix A: Midwest Region Farming Information ............................................................................................70

Appendix B: Threatened and Endangered Species of the Midwest Region ........................................................74

Appendix C: References ...........................................................................................................................................78

Appendix D: Glossary................................................................................................................................................81

Appendix E: Eligibility Questionnaire........................................................................................83

Appendix F: Response to Public Comments.................................................................................88
viii

Figure 1: National Wildlife Refuge System U.S. Fish and Wildlife Service ..............2 

Figure 2: Potential Historic Natural Habitats in the Midwest Region .......................................................................20

Figure 3: Current Land Cover in the Midwest Region of the FWS ............................................................................22

Figure 4: Agriculture on Refuge System Lands in the Midwest Region ....................................................................24

Table 1: Wetland Loss, FWS Midwest Region ..........................................................................................................21

Table 2: Land Cover Within Inholdings, Midwest Region Refuge System Lands .....................................................23

Table 3: Comparison of Impacts by Issue ..................................................................................................................59
ix

Summary

Managed by the U.S. Fish and Wildlife Service (Service), the National Wildlife Refuge System 

includes more than 150 million acres of public lands and waters dedicated to habitat and wildlife 

conservation. The Refuge System includes 553 national wildlife refuges and 38 wetland 

management districts throughout the United States. The mission of the National Wildlife Refuge 

System is: 

...To administer a national network of land and waters for the conservation, management 

and where appropriate restoration of the fish, wildlife and plant resources and their 

habitats for the benefit of present and future generations of Americans.

The Midwest Region of the Fish and Wildlife Service includes: Illinois, Iowa, Indiana, 

Michigan, Minnesota, Missouri, Ohio and Wisconsin. There are 54 national wildlife refuges and 

12 wetland management districts in the Midwest Region. 

Although Service policy is to use the most natural means available to meet Refuge or District 

purposes and wildlife objectives, policy allows the use of cropland management in situations 

where objectives cannot be met through maintenance of more natural ecosystems (USFWS 

1985). Service policy stipulates that only the minimum acreage required to meet objectives 

should be devoted to croplands. In the Midwest Region, row crops on Refuge System lands 

cover 20,418 acres, or 1.6 percent of Refuge System lands. 

Row crops have been farmed on national wildlife refuges and wetland management districts for 

decades, however changes in Service policies and the development of genetically modified 

crops, specifically glyphosate-tolerant corn and soybeans, have prompted the Service to review 

crop farming as a land management tool. This Environmental Assessment (EA) evaluates the use 

of farming and the use of genetically modified, glyphosate-tolerant (GMGT) corn and soybeans 

on Refuge System lands within the Midwest Region.

Chapter 1 describes the purpose and need for an EA, provides background on the Midwest 

Region’s farming program, summarizes applicable laws and policies, describes public outreach 

efforts for this EA, and describes the issues that were identified during the scoping process.

Chapter 2 describes the alternatives that are evaluated in this EA and also describes alternatives 

that were considered but not evaluated. Chapter 3 describes the Midwest Region’s physical 

environment and socioeconomic character. Chapter 4 includes an evaluation of the alternatives. 

Chapter 5 lists the Service staff who prepared this EA.

In the Draft EA, Alternative A: Continue Farming for Multiple Objectives, GMGT Corn and 

Soybeans Allowed (No Action) was the preferred alternative. However, upon completion of a 

public review period of the Draft EA, comments were evaluated and as a result of this process a 

fifth alternative was developed and ultimately selected. Alternative E: Continue Farming for 

Multiple Objectives, GMGT Corn and Soybeans Allowed for Habitat Restoration Only is the 

selected alternative. This alternative would allow the continued use of farming as a management 

practice, but would only allow the use of GMGT corn and soybeans for habitat restoration 
x

purposes. The alternative was identified as the selected alternative based on benefits to the 

natural resources and the desire to have the least impact to the environment.
1

Chapter 1: Purpose and Need

1.1 Purpose 

The U.S. Fish and Wildlife Service (Service) is the primary federal agency responsible for the 

conservation of habitat and wildlife. The Midwest Region of the U.S. Fish and Wildlife Service 

includes Illinois, Indiana, Iowa, Michigan, Minnesota, Missouri, Ohio and Wisconsin. The 

Service manages the National Wildlife Refuge System, which is the largest system of lands 

managed primarily for wildlife conservation in the world. The Refuge System’s mission is:

“...to administer a national network of lands and waters for the conservation, 

management, and where appropriate, restoration of the fish, wildlife, and plant resources 

and their habitats within the United States for the benefit of present and future 

generations of Americans.”

The purpose of this Environmental Assessment (EA) is to review and evaluate current and 

alternative actions that use farming as a habitat management tool to support establishing 

purposes of Refuge System lands or the Refuge System’s mission, including the use of 

genetically modified, glyphosate-tolerant (GMGT) corn and soybeans on National Wildlife 

Refuge System lands in the Midwest Region (Figure 1), and to then select an alternative. Each 

alternative is evaluated based on the environmental consequences, including biological and 

socioeconomic impacts, in accordance with the National Environmental Policy Act (NEPA). 

Alternatives are also evaluated based on how effectively they support the purposes for which 

Refuge System lands were established and the mission of the Refuge System.

1.2 Need for Action

The increased use of GMGT corn and soybean crops and revised Service policies regarding 

farming and genetically modified organisms warrant a reevaluation of farming as a tool for 

wildlife and habitat management and the use of GMGT corn and soybeans on Refuge System 

lands in the Midwest Region. 

1.3 Decision Framework

The Regional Director for the Midwest Region will make two decisions based on this EA: 

select an alternative regarding farming on Refuge System lands in the Midwest Region.

determine if the selected alternative is a major federal action significantly affecting the 

quality of the human environment, thus requiring preparation of an Environmental Impact 

Statement. 

Alternative E: Continue Farming for Multiple Objectives, GMGT Corn and Soybeans Allowed 

for Habitat Restoration Only is the selected alternative. This alternative would allow the 

continued use of farming as a management practice, but would only allow the use of GMGT corn 

and soybeans for habitat restoration purposes. The alternative was identified as the selected 
2

alternative based on benefits to the natural resources and the desire to have the least impact to the 

environment.

Figure 1: National Wildlife Refuge System Lands, Midwest Region of the U.S. Fish and Wildlife 

Service
3

Alternative A: Continue Farming for Multiple Objectives, GMGT Corn and Soybeans Allowed 

(No Action) was the initial preferred alternative. However, upon completion of a public review 

period of the Draft EA, comments were evaluated and as a result of this process a fifth 

alternative (Alternative E) was developed and ultimately selected. 

1.4 Background

Thirty-one refuges and wetland management districts out of a total of 66 in the Midwest Region 

currently use farming as one method of managing wildlife habitat. In 2010, 20,418 acres of 

Refuge System lands were farmed in the Midwest Region, which is 1.6 percent of the Region’s 

total of 1.2 million acres. Refuge farmland accounts for 0.02 percent of the total 116 million 

harvested farming acreage in the eight-state Region (USDA 2009). A large portion of Refuge 

System lands in the Midwest Region were farmland when the Service acquired them, and it is 

estimated that 40 percent of land acquired in the future will be farmland prior to acquisition by 

the Fish and Wildlife Service. The majority of Refuge System units use farming as part of the 

process of restoring native habitat. 

The general trend on all Refuge System lands in the Midwest Region has been to convert 

farmland to natural habitat because natural habitats have greater value for wildlife (Tilman et al. 

2001). 

The use of genetically-engineered organisms in American agriculture has increased substantially 

over the past decade. Genetically-modified, herbicide-tolerant crops were planted on 92 percent 

of the United States soybean acres and 80 percent of the corn acres in 2008 (Brookes 2010). 

Agriculture will likely play a part in management of Refuge System lands indefinitely. For all 

but a handful of urban refuges in the Midwest Region, row crops border existing Refuge System 

lands and frequently occur on lands adjacent to refuges and wetland management districts. 

Existing plans call for most agricultural areas on Midwest Region Refuge System lands to be 

restored to natural habitats. Successful habitat restoration requires planning, site preparation, 

planting materials, equipment, and staffing. Current budget levels make it unlikely that the 

Service could immediately address all of the Refuge System lands that require restoration to 

natural habitat. In comparison to the cost of restoring land, agriculture is a less expensive method 

of preparing sites for restoration and managing invasive or unwanted plant species until 

restoration can begin. 

Farming as a management tool is conducted in one of several ways. The most common method is

to work with neighboring farmers, referred to as “cooperators,” to plant a crop using their seed, 

labor, equipment, and other supplies in exchange for a portion of the crop. Another method is to 

charge a rental rate for farming with the entire crop harvested by the renter. This method is most 

commonly used when the objective is to prepare a tract for restoration to native habitat or to 

control weeds. Refuge staff also plant crops for wildlife, which requires the Refuge to have 

equipment, an operator, and supplies.
4

Farming is used as a management tool in four primary categories: 

habitat restoration

habitat management

supplemental food for wildlife 

attracting wildlife for viewing and photography 

1.4.1 Habitat Restoration

Farming is used on Refuge System lands to maximize the destruction of seeds and unwanted 

plant parts from invasive or unwanted plant species and to create less competition and purer 

stands of native species. Some seeds remain in the soil for a long time. If new plants are 

continually set back by farming activities and herbicide, the number of seeds left in the soil is 

eventually reduced. Farming row crops also helps eliminate weeds and stubble that make it 

difficult to get equipment such as tree planters or native grass no-till drills into a field. After a 

new parcel is acquired, it is typically farmed for the next 3 to 5 years. Typically cooperators use 

glyphosate-tolerant corn then glyphosate-tolerant soybeans during the last two years of farming. 

Glyphosate is a broad-spectrum, non-selective herbicide. It is probably the most widely used 

herbicide wordwide and is generally considered to be highly effective, but toxicologically and 

environmentally safe (Duke and Powles 2008).

1.4.2 Habitat Management 

In some cases, land managers use farming to set back succession and remove invasive or even 

native plants and woody vegetation from wetlands, including wetlands managed for wildlife food 

production. While Service policy is to restore land to native habitat, natural succession isn’t 

always the best route to achieving wildlife and habitat objectives given that the natural system 

has been greatly disrupted by human uses. Refuge and wetland management district managers 

manage habitat via soil disruption and flooding to maintain preferred habitats such as wetlands, 

which are a vital habitat to diverse species of wildlife.

1.4.3 Supplemental Food for Wildlife 

The Service has used crops to supplement wildlife diets for decades. The availability of native 

foods decreased in the past century as land was converted to farming, and the loss of habitat 

continues as land is converted to housing developments and other human uses. In an effort to 

meet waterfowl population objectives established by various agencies and organizations, the 

Service planted row crops on Refuge System lands as an additional source of food during 

migration and wintering periods, when waterfowl have a greater need for high energy foods.

Leaving crops standing for wildlife has also been used to help some resident wildlife species 

survive severe winters. Corn, soybeans, and winter wheat are typical crops used on NWRs.
5

1.4.4 Attracting Wildlife for Viewing and Photography

To a lesser extent than habitat restoration, habitat management and supplemental feeding, row 

crops have also been a useful tool for attracting wildlife to areas where people can view and 

photograph them. Some national wildlife refuges use a stand of row crops to create “watchable 

wildlife” areas along auto tour routes or other areas that are accessible for visitors.

1.5 Authority, Legal Compliance, and Compatibility

Refuge System lands are managed consistent with a number of federal statutes, regulations, 

policies, and other guidance. The National Wildlife Refuge System Administration Act of 1966, 

as amended (NWRS Administration Act, 16 U.S.C. 668dd-668ee) is the core statute guiding 

management of the National Wildlife Refuge System. The National Wildlife Refuge System 

Improvement Act of 1997 (P.L. 105-57) made important amendments to the NWRS 

Administration Act, one of which was the mandate that a comprehensive conservation plan be 

completed for every unit of the Refuge System. Among other things, comprehensive 

conservation planning has required field stations to assess their current farming program and 

establish objectives for the future.

More information about the National Wildlife Refuge System Act and the National Wildlife 

Refuge System Improvement Act of 1997 and a list of other laws, regulations, policies and 

executive orders that influence the Refuge System can be found on-line at: 

http://www.fws.gov/midwest/planning/FarmingEA

1.6 Coordination with Other Regions and Agencies

Preparation of this EA was coordinated with a similar effort in the Mountain-Prairie Region of 

the Fish and Wildlife Service and the Office of Science and Technology Policy in Washington, 

D.C.

1.7 Public Outreach

In April 2010, representatives of various Service programs were asked to comment on the 

Refuge System farming program. The next step was to seek comment on farming on Refuge 

System lands from the public. Service staff from the Midwest Region coordinated with staff in 

the Mountain-Prairie Region to seek public comment on the use of GMGT corn and soybeans on 

Refuge System lands in 16 states. The Mountain-Prairie Region includes the states of Colorado, 

Kansas, Montana, Nebraska, North Dakota, South Dakota, Utah and Wyoming. 

In the Midwest Region, public outreach efforts included sending news releases to more than 790 

media outlets, posting information at refuges and wetland management districts throughout the 

Midwest Region, providing information to local farming interests, and providing information to 

107 congressional staff within the eight-state Region. In addition, the Midwest Region posted 

information on a website (http://www.fws.gov/midwest/planning/farmingNEPA/index.html) 

throughout the planning process. Three public meetings were held in the two regions, a total of 
6

10 people attended. Open house events were held in Fergus Falls, Minnesota, Aberdeen, South 

Dakota, and Hartford, Kansas. Outreach efforts ended in early July 2010.

More than 30 written comments and e-mails were received from farmers participating in the 

Refuge System farming program, neighboring landowners, agricultural organizations, nongovernmental organizations and biochemical interests for the Midwest Region scoping. These 

comments are summarized into three general categories:

1.7.1 Wildlife Issues

1. Use of GMGT corn and soybeans could provide an alternative for farming with less risk to 

wildlife.

2. Agricultural herbicides may be toxic to wildlife.

3. Refuge System units need to provide high energy food for migrating and resident wildlife.

4. Refuge System units need to provide concentrated food sources to attract wildlife for wildlifedependent recreation.

5. Farming negatively impacts wildlife.

1.7.2 Habitat Issues

6. Farming and genetically modified crops (GMCs) can make habitat restoration and 

management more efficient and economical. Increased cost to the Service for restoration and 

maintenance of habitats could make it more difficult to support diverse natural habitats.

7. Farming is an effective way to control invasive plants and invasion of woody species.

8. The Service should use conservation tillage practices to minimize soil erosion on cultivated 

lands.

9. Concern exists for developing herbicide resistance by using GMCs.

1.7.3 Socioeconomic Issues

10. Non-genetically modified seeds are becoming less available in local communities.

11. Not being able to use GMCs could make farming more costly for cooperators. Local farming 

cooperators will lose income if farming is reduced or eliminated.

12. Changing farming of Refuge System lands will impact the economy.

13. Use of GMGT corn and soybeans on Refuge System lands could impact neighboring organic 

farmers due to inadvertent gene flow from GM to organic crops. 
7

Two comments were received on inadvertent crop-to-weed gene flow and possible negative 

effects of GM crops on human health and safety; they are addressed in Section 2.3.1.

1.8 Issues Beyond the Scope of This EA

This EA is focused on the use of row crop farming as a management tool, and the use of GMGT 

corn and soybeans on National Wildlife Refuge System lands. It does not evaluate other issues, 

including:

managed grazing of Refuge System lands

haying on Refuge System lands

genetically modified organisms other than GMGT corn and soybeans
8

Chapter 2: Description of the Alternatives

2.1 Formulation of Alternatives

Alternatives were developed based on a review of authorities, policies, and regulations as well as 

review of the comments received during the initial public comment period held to determine 

what issues should be addressed in this EA. This chapter describes the five alternatives: 

1. Alternative A: Continue Farming for Multiple Objectives, GMGT Corn and Soybeans 

Allowed (No Action) 

2. Alternative B: Farming for Habitat Restoration Objectives Only, GMGT Corn and Soybeans 

Allowed 

3. Alternative C: Farming for Multiple Objectives, No GMGT Corn and Soybeans 

4. Alternative D: Limited Row Crop Farming, No GMGT Corn and Soybeans

5. Alternative E: Continue Farming for Multiple Objectives, GMGT Corn and Soybeans Allowed 

for Habitat Restoration Only (Selected Alternative)

Development of the alternatives considered:

The National Wildlife Refuge System Improvement Act of 1997

Reasons for farming on Refuge System lands

Refuge or wetland management district establishing purposes

The availability and effectiveness of alternative management tools

Benefits and impacts to wildlife

Current goals and objectives identified in completed 15-year comprehensive conservation 

plans.

2.2 Alternatives Considered but Not Developed

2.2.1 No Farming

Row crop farming will remain an issue with the management of Refuge System lands because:

About 40 percent of any new lands added to the Refuge System in the Midwest Region in 

the future will probably be row crop land. Most of these acres will need to be prepared 

for restoration to natural habitats. The Service lacks the resources to restore all of these 

acres without the use of row crop farming. Fields that are abandoned and left to undergo 

unmanaged succession are unlikely to result in desirable vegetation (see Section 2.2.2 in 

this section).
9

Immediate elimination of row crop farming was not carried forward for evaluation in this EA 

because it would not be likely to fulfill the establishing purposes of refuges and wetland 

management districts.

2.2.2 Unmanaged Succession 

Unmanaged succession occurs when land is allowed to grow back with no human land 

management. This approach to restoration takes more time when compared to active 

management methods and typically results in a stand of vegetation dominated by undesirable, 

non-native plants. This is particularly true for lands that have been farmed for many years; the 

longer a tract is farmed, the less likely it is for native plant species to remain. This strategy for 

managing land is less efficient than active restoration because native plant species are competing 

with invasive plants. Not only can unmanaged succession be unpopular with local weed boards, 

it can result in violations of local and state laws pertaining to control of noxious weeds.

Unmanaged succession was not carried forward for evaluation in this EA because its results are 

not normally adequate to fulfill the establishing purposes of refuges and wetland management 

districts.

2.3 Elements Common to All Alternatives

Several elements are common to all five alternatives evaluated in this EA. These elements are 

listed here and are discussed in more detail in the following paragraphs.

Issues Receiving Extensive Analysis During Comprehensive Assessments by the U.S. 

Department of Agriculture

Adherence to the National Wildlife Refuge System Administration Act, as Amended by 

the National Wildlife Refuge System Improvement Act of 1997

Adherence to FWS Appropriate Use and Compatibility Policies

Agricultural Lands Will Decrease on Refuge System Lands

Procedures and Limits on Herbicide Use

Integrated Pest Management

Adherence to Midwest Region Refuge System Farming Policy

2.3.1 Issues Receiving Extensive Analysis During Comprehensive Assessments by the U.S. 

Department of Agriculture

Since 1986, the U.S. Department of Agriculture (USDA), the Environmental Protection Agency 

(EPA) and Food and Drug Administration (FDA) have been the federal agencies responsible for 

assessing the safety of products of modern biotechnology. Assessments are based on the 

biological characteristics of each new organism. The USDA’s Animal and Plant Health 

Inspection Service (APHIS) has completed comprehensive assessments of GMGT corn and 

soybeans through National Environmental Policy Act (NEPA) review. This review did not find 

significant impacts regarding:

Weediness
10

Corn and soybeans have been grown throughout the world without any report that they are 

serious weeds. They are not generally persistent in undisturbed environments without human 

intervention. In the year following cultivation, they may grow as a volunteer only under specific 

conditions and can be easily controlled by herbicides or mechanical means. They do not compete 

effectively with cultivated plants or primary colonizers.

Human health and safety

The engineered proteins in GMGT corn and soybeans are not known to have any toxic properties 

and have minimal potential to be food allergens.

Non-target species

The engineered proteins in GMGT corn and soybeans are not known to have any toxic properties 

and have minimal potential to be food allergens.

Inadvertent crop-to-weed gene flow

There are no known species of weeds that are sexually compatible with corn or soybeans.

The most recent EAs by APHIS that assess GMGT corn and soybeans may be found at the 

following web addresses:

http://www.aphis.usda.gov/brs/aphisdocs2/06_17801p_com.pdf

http://www.aphis.usda.gov/brs/aphisdocs2/00_01101p_com.pdf

2.3.2 Adherence to the National Wildlife Refuge System Administration Act, as Amended by 

the National Wildlife Refuge System Improvement Act of 1997

The National Wildlife Refuge System Improvement Act of 1997 amended the National Wildlife 

Refuge System Act of 1966 and created comprehensive legislation spelling out how the Refuge 

System would be managed and how it could be used by the public. All of the alternatives 

evaluated in this EA are consistent with the main points of the Improvement Act:

Wildlife conservation comes first on national wildlife refuges.

The Service will adhere to biological integrity, diversity and environmental health of the 

Refuge System.

Compatibility determinations will guide uses of Refuge System lands.

Six wildlife-dependent recreational uses are priority public uses of the Refuge System: 

hunting, fishing, wildlife observation and photography, environmental education and 

interpretation.

A comprehensive conservation plan will be prepared for every refuge and wetland 

management district.

2.3.3 Adherence to FWS Appropriate Use and Compatibility Policies
11

All of the alternatives evaluated in this environmental assessment would adhere to two policies 

guiding decisions on activities allowed on lands managed by the National Wildlife Refuge 

System: Appropriate Use and Compatibility.

The Appropriate Refuge Uses policy describes the initial decision process a refuge or district 

manager follows when first considering whether or not to allow a proposed use on a national 

wildlife refuge or wetland management district. The manager must find a use appropriate before 

undertaking a compatibility review of the use. An appropriate use, as defined by the Appropriate 

Use Policy (603 FW 1 of the Service Manual), is a proposed or existing use on a refuge that 

meets at least one of the following four conditions:

The use is a wildlife-dependant recreational use as identified in the Improvement Act.

The use contributes to the fulfilling of the refuge purpose(s), the Refuge System mission, 

or goals or objectives described in a refuge management plan approved after October 9, 

1997, the date the Improvement Act was signed into law.

The use involves the take of fish and wildlife under State regulations.

The use has been found to be appropriate as specified in section 1.11 (603 FW 1 of the 

Service Manual).

Lands within national wildlife refuges are different from other multiple-use public lands in that 

they are closed to all public uses unless specifically and legally opened. Unlike national wildlife 

refuges, the waterfowl production areas that make up wetland management districts are 

considered open to hunting unless posted “closed.” The Improvement Act states “. . . the 

Secretary shall not initiate or permit a new use of a Refuge or expand, renew, or extend an 

existing use of a Refuge, unless the Secretary has determined that the use is a compatible use and 

that the use is not inconsistent with public safety.” The Improvement Act also states that “. . . 

compatible wildlife-dependent recreational uses (hunting, fishing, wildlife observation and 

photography, or environmental education and interpretation) are the priority general public uses 

of the System and shall receive priority consideration in Refuge planning and management.”

In accordance with the Improvement Act, the Service has adopted a Compatibility Policy (603 

FW 2) that includes guidelines for determining if a use proposed on a national wildlife refuge or 

wetland management district is compatible with the purposes for which the refuge or district was 

established. A compatible use is defined in the policy as a proposed or existing wildlifedependent recreational use or any other use of National Wildlife Refuge System lands that, based 

on sound professional judgment, will not materially interfere with or detract from the fulfillment 

of the NWRS mission or the purposes of the Refuge. The policy also includes procedures for 

documentation and periodic review of existing refuge uses.

A compatibility determination evaluates a proposed use and shows whether it has been 

determined to be “compatible” or “not compatible.” The public has an opportunity to review and 

comment on draft compatibility determinations, often during the comprehensive conservation 

planning process.

2.3.4 Agricultural Lands Will Decrease on Refuge System Lands
12

Under all alternatives evaluated, the amount of Refuge System lands that are planted in row 

crops will diminish as land is restored to natural habitat. How quickly the farming program 

decreases varies with each alternative.

The Service’s Biological Integrity, Diversity and Environmental Health policy (601 FW3) 

provides direction on the use of farming (including row crops) and directs land managers to 

restore land to native habitats. Individual refuge and wetland management district farming 

programs have been reviewed in comprehensive conservation plans and in many cases are being 

greatly reduced or entirely phased out. Farming currently occurs on 1.6 percent of lands within 

the Refuge System in the Midwest Region. Over the next 15 years, we expect to reduce row crop 

farming to 0.8 percent to meet planned restoration objectives.

2.3.5 Procedures and Limits on Herbicide Use

Under all of the alternatives evaluated, protective measures will be followed to ensure the proper 

use of herbicides on Service lands. Service policy requires that land managers complete a 

Pesticide Use Proposal, or PUP, before applying herbicide on Service lands. Each PUP must be 

approved by Environmental Contaminant staff or National Wildlife Refuge staff at the field, 

regional, or national levels, depending on the pesticide being proposed for use. Requiring PUPs 

helps ensure that product label instructions are followed, that pesticides are used effectively and 

safely, that the lowest risk products are selected, and that buffers are maintained.

2.3.6 Integrated Pest Management

All alternatives considered would adhere to the Service’s Integrated Pest Management guidance.

Integrated pest management, or IPM, is “a sustainable approach to managing pests by combining 

biological, cultural, physical, and chemical tools in a way that minimizes economic, health, and 

environmental risks” (7 USC 136r-1). Integrated pest management coordinates the use of pest 

biology, environmental information, and available technology to prevent unacceptable levels of 

pest damage by the most economical means, while posing the least possible risk to people, 

property, resources, and the environment.

More information on integrated pest management is available in Service guidance issued on 

preparing and implementing IPMs: 

http://www.fws.gov/contaminants/Issues/IPM.cfm

2.3.7 Adherence to Midwest Region Refuge System Farming Policy

All of the alternatives developed in this EA would adhere to national and regional policy related 

to farming on National Wildlife Refuge System lands.

Nationally, the Fish and Wildlife Service policy related on Biological Integrity, Diversity and 

Environmental Health (601 FW 3, 2001; Amendment 1, 2006) states: 
13

We do not allow Refuge System uses or management practices that result in the maintenance of 

non-native plant communities unless we determine there is no feasible alternative for 

accomplishing refuge purposes(s). For example, where we do not require farming to accomplish 

refuge purpose(s), we cease farming and strive to restore natural habitat. Where feasible and 

consistent with refuge purpose(s), we restore degraded or modified habitats in the pursuit of 

biological integrity, diversity, and environmental health. We use native seed sources in 

ecological restoration. We do not use genetically modified organisms in refuge management 

unless we determine their use is essential to accomplishing refuge purpose(s) and the Regional 

Chief or the Assistant Manager, California/Nevada Operations Office (CNO), National Wildlife 

Refuge System, approves the use.

The Midwest Region incorporated national policy into the Region’s policy on farming in 2010:

Where feasible and consistent with Refuge purpose(s), Region 3 staff (we) restore and manage 

degraded or modified habitats in the pursuit of biological integrity, diversity, and environmental 

health. We do not allow Refuge uses or management practices that result in the maintenance of 

non-native plant communities unless we determine there is no feasible alternative for 

accomplishing the Refuge purpose(s). Where farming is not required for Refuge purpose(s), we 

cease farming and strive to restore natural habitats. We do not use genetically modified 

organisms in Refuge management unless we determine their use is essential to accomplishing 

Refuge purpose(s) and the Chief of Refuges for Region 3 approves the use. The use of 

genetically modified organisms is limited to herbicide-resistant crops only (September 24, 2010, 

Notice from Midwest Regional Refuge Chief).

2.4 Alternatives Considered

2.4.1 Alternative A: Continue Farming for Multiple Objectives, GMGT Corn and Soybeans 

Allowed (No Action)

Under Alternative A, the use of GMGT corn and soybeans on Refuge System lands in the 

Midwest Region would continue. Farming would continue to be used for multiple objectives, 

including but not limited to the following:

habitat restoration

habitat management

supplemental food for wildlife 

attracting wildlife for viewing and photography 

Currently, farming programs involve either Service staff and equipment or a third party, often 

referred to as a “cooperator,” who farms under the terms and conditions of a cooperative farming 

agreement or special use permit issued by the refuge or district manager. Refuge and District 

managers establish how long farming would be allowed on a specific tract, establish the crops 

and crop rotation that will be used, define the process of selecting cooperators, and determine 

payment rates. The terms and conditions typically include a provision for leaving some 

percentage of the crops in the field as food for wildlife, primarily migrating birds. The farming 

activities would have to be found compatible through a compatibility determination. 
14

Refuge and district staffs work with farming cooperators to use best management farming 

practices to improve soils, reduce pest issues, lessen impacts to wildlife, and to prevent sediment, 

chemical and nutrient runoff. These practices include crop rotation, cover crops, no-till planting, 

and use of herbicides with low environmental impact. Crop type is determined by the refuge and 

district staffs and is based on wildlife needs, soil types, and integrated pest management. The 

most commonly planted crops are corn, soybeans, and winter wheat.

Farming would continue to be allowed using either conventional farming techniques or no-till 

(conservation) farming. Using traditional farming techniques, mechanical equipment such as 

tractors, plows, disks, harrows, and seeders would typically be used on a parcel several days each 

year. Farming activities could include: soil preparation, planting, nutrient management, pest 

management, and harvesting (http://www.epa.gov/oecaagct/ag101/crop.html). 

Conditions outlined in the Service’s cooperative agreement would be followed. Many of these 

conditions relate to the Environmental Protection Agency’s CORE 4 conservation practices:

Conservation tillage

Crop nutrient management

Pest management

Conservation buffers

2.4.2 Alternative B: Farming for Habitat Restoration Objectives Only, GMGT Corn and 

Soybeans Allowed

Under Alternative B, the use of GMGT corn and soybeans on Refuge System lands in the 

Midwest Region would continue. Beginning in 2012, as Refuge and District comprehensive 

conservation plans are revised, the use of farming as a management tool would be limited to the 

restoration of native habitats only. Future newly purchased lands could be farmed for 3 years 

until being restored to native habitat. Crop farming would decrease at a greater rate than it is 

currently because it would no longer be used for habitat management, supplemental wildlife 

food, or attracting wildlife for observation and photography. As habitat restoration objectives are 

met, row crop farming would disappear from all but newly acquired lands where habitat 

restoration has not occurred. 

Like Alternative A, this alternative retains the option to use genetically-modified, glyphosatetolerant corn and soybeans as a management tool for preparing farm land for conversion to 

native habitats. Refuge and wetland management district managers would have to verify that 

farming is essential to meet refuge purposes and would obtain approval through the Midwest 

Refuge Chief.

Like Alternative A, either Service staff and equipment or a third party, often referred to as a 

“cooperator,” would plant corn and soybeans under the terms and conditions of a cooperative 

farming agreement or special use permit issued by the refuge manager. Refuge and District 

managers establish how long farming would be allowed on a specific tract, establish the crops 

and crop rotation that would be used, define the process of selecting cooperators, and determine 
15

payment. Farming activities would have to be found compatible through a compatibility 

determination. 

As in Alternative A, farming would continue to be allowed using either conventional farming 

techniques or no-till (conservation) farming. Using traditional farming techniques, mechanical 

equipment such as tractors, plows, disks, harrows, and seeders would typically be used on a 

parcel several days each year. Farming activities could include: soil preparation, planting, 

nutrient management, pest management, and harvesting 

(http://www.epa.gov/oecaagct/ag101/crop.html). 

Like Alternative A, conditions outlined in the Service’s cooperative agreement would be 

followed. Many of these conditions relate to the Environmental Protection Agency’s CORE 4 

conservation practices:

Conservation tillage

Crop nutrient management

Pest management

Conservation buffers

2.4.3 Alternative C: Farming for Multiple Objectives, No GMGT Corn and Soybeans

Two years after approval of this EA, the use of GMGT corn and soybeans would no longer be 

allowed on Refuge System lands in the Midwest Region under Alternative C. As in Alternative 

A, farming would be used for multiple management purposes, including but not limited to the 

following:

habitat restoration

habitat management

supplemental food for wildlife 

attracting wildlife for viewing and photography 

Like Alternative A, either Service staff or a third party cooperator would farm under the terms 

and conditions of a cooperative farming agreement or special use permit issued by the Refuge or 

District Manager. Refuge and District managers would establish how long farming would be 

allowed on a specific tract, establish the crops and crop rotation that would be used, define the 

process of selecting cooperators, and determine payment. Farming activities would have to be 

found compatible through a compatibility determination. 

As in Alternative A, farming would continue to be allowed using either conventional farming 

techniques or no-till (conservation) farming. Using traditional farming techniques, mechanical 

equipment such as tractors, plows, disks, harrows, and seeders would typically be used on a 

parcel several days each year. Farming activities could include: soil preparation, planting, 

nutrient management, pest management, and harvesting 

(http://www.epa.gov/oecaagct/ag101/crop.html). 
16

Like Alternative A, conditions outlined in the Service’s cooperative agreement would be 

followed. Many of these conditions relate to the Environmental Protection Agency’s CORE 4 

conservation practices:

Conservation tillage

Crop nutrient management

Pest management

Conservation buffers

2.4.4 Alternative D: Limited Row Crop Farming, No GMGT Corn and Soybeans

Two years after approval of this EA, the use of GMGT corn and soybeans would no longer be 

allowed on Refuge System lands in the Midwest Region under Alternative D. Under this 

alternative, the Fish and Wildlife Service would discontinue the use of row crop farming on 

Refuge System lands within 5 years of the approval of this EA except of the following special 

circumstances:

1. Farming could occur on newly purchased lands for no more than 3 years if those lands were 

being farmed at the time of purchase. This exception would allow the Service time to prepare for 

restoration to natural habitat, give the individual farming the land at the time of the sale a period 

for planning and transition, and could facilitate Service land purchases.

2. Farming would continue on land not owned by the Service, but managed as part of the Refuge 

System, when farming is required by the signed agreement. 

3. Farming could occur on a case-by-case basis for human health or environmental emergencies, 

for example control of serious disease vectors. Each case would require approval by the Regional 

Chief of Refuges.

Refuge and District Managers would have to verify that farming is essential to meet Refuge 

purposes and would obtain approval through the Midwest Refuge Chief.

Like Alternative A, either Service staff or a third party cooperator would farm under the terms 

and conditions of a cooperative farming agreement or special use permit issued by the Refuge 

and District Manager. Refuge and District Managers would establish how long farming would be 

allowed on a specific tract, establish the crops and crop rotation that would be used, define the 

process of selecting cooperators, and determine payment rates. All farming activity would have 

to be found compatible through a compatibility determination. 

In the limited situations in which it’s allowed, either conventional farming techniques or no-till 

(conservation) farming would occur. Using traditional farming techniques, mechanical 

equipment such as tractors, plows, disks, harrows, and seeders would typically be used on a 

parcel several days each year. Farming activities could include: soil preparation, planting, 

nutrient management, pest management, and harvesting 

(http://www.epa.gov/oecaagct/ag101/crop.html). 
17

Like Alternative A, conditions outlined in the Service’s cooperative agreement would be 

followed. Many of these conditions relate to the Environmental Protection Agency’s CORE 4 

conservation practices:

Conservation tillage

Crop nutrient management

Pest management

Conservation buffers

2.4.5 Alternative E: Continue Farming for Multiple Objectives, GMGT Corn and Soybeans 

Allowed for Habitat Restoration Only (Selected Alternative)

Under Alternative E, beginning in calendar year 2012, the use of GMGT corn and soybeans on 

Refuge System lands in the Midwest Region would continue only for the purpose of habitat 

restoration. The use of GMGT corn and soybeans would be limited to five years for any 

individual tract in preparation for habitat restoration. Farming could continue to be used as a 

management tool for achieving multiple objectives, however, it would be limited to non GMGT 

crops only for objectives other than habitat restoration. Multiple objectives include but are not 

limited to the following:

habitat restoration

habitat management

supplemental food for wildlife 

attracting wildlife for viewing and photography 

The Service’s biological integrity policy specifies that GMGT crops cannot be used on Refuge 

System lands unless they are “essential to accomplishing refuge purposes.” Habitat restoration is 

a core objective of most refuges and wetland management districts to achieve purposes, and the 

use of GMGT crops could be essential in some circumstances. However, habitat management, 

providing supplemental food, and wildlife viewing objectives can more readily be accomplished 

without the use of GMGT corn and soybeans and thus the use of GMGT crops would not be 

essential.

Refuge and Wetland Management District managers would be required to demonstrate that their 

proposed use of GMGT crops is essential for habitat restoration. The Service has established an 

approval process for the use of GMGT corn and soybeans that includes completion of an 

Eligibility Questionnaire for Genetically Modified Crops; the Questionnaire is shown in 

Appendix E. When managers propose to use GMGT corn and soybeans, they would be required 

to complete this Questionnaire as part of the approval process. The Regional Chief of Refuges, 

will review all requests for authorization to use GMGT corn and soybeans and will approve or 

deny requests based on the Questionnaire. 

Currently, farming programs involve either Service staff and equipment or a third party, often 

referred to as a “cooperator,” who farms under the terms and conditions of a cooperative farming 
18

agreement or special use permit issued by the Refuge or District manager. Refuge and District 

managers establish how long farming is allowed on a specific tract, establish the crops and crop 

rotation that will be used, define the process of selecting cooperators, and determine payment 

rates. The terms and conditions typically include a provision for leaving some percentage of the 

crops in the field as food for wildlife, primarily migrating birds. The farming activities have to be 

found compatible through a compatibility determination before they can be allowed. 

Refuge and district staffs work with farming cooperators to use best management farming 

practices to improve soils, reduce pest issues, lessen impacts to wildlife, and to prevent sediment, 

chemical and nutrient runoff. These practices include crop rotation, cover crops, no-till planting, 

and use of herbicides with low environmental impact. 

Crop type is determined by the refuge and district staffs and is based on wildlife needs, soil 

types, and integrated pest management. The most commonly planted crops are corn, soybeans, 

and winter wheat. However, under this alternative, managers would be encouraged to pursue 

additional crop options (milo, alfalfa, clover, etc,) for use in non-restoration activities.

Farming would continue to be allowed using either conventional farming techniques or no-till 

(conservation) farming. Using traditional farming techniques, mechanical equipment such as 

tractors, plows, disks, harrows, and seeders would typically be used on a parcel several days each 

year. Farming activities could include: soil preparation, planting, nutrient management, pest 

management, and harvesting (http://www.epa.gov/oecaagct/ag101/crop.html). 

Conditions outlined in the Service’s cooperative agreement would be followed. Many of these 

conditions relate to the Environmental Protection Agency’s CORE 4 conservation practices:

Conservation tillage

Crop nutrient management

Pest management

Conservation buffers
19

Chapter 3: Physical and Social Environment 

3.1 Introduction

In the Midwest Region, the National Wildlife Refuge System includes 54 national wildlife 

refuges and 12 wetland management districts. The Midwest Region is comprised of eight states:

Iowa

Illinois

Indiana

Michigan

Minnesota

Missouri

Ohio

Wisconsin

While there is some topographical variation, these states can be characterized as being flat to 

either rolling or small hills. The Great Lakes Basin, the Ozark Mountains of southern Missouri, 

the rugged topography of southern Indiana and southern Illinois, and the rolling hills of 

southwestern Wisconsin and southeastern Minnesota are all exceptions. 

The climate varies from Missouri, where the average high summer temperature is 90.5 and the 

average low winter temperature is 19.4 degrees Fahrenheit 

(http://netstate.com/states/alma/mo_alma.htm), to Minnesota, where the average high summer 

temperature is 83.4 degrees Fahrenheit and the average low winter temperature is -2.9 degrees 

Fahrenheit (http://netstate.com/states/alma/mn_alma.htm). Across the entire region, the average 

high summer temperature is 86 degrees Fahrenheit and the average low winter temperature is 

10.4 degrees Fahrenheit. Precipitation ranges from 42.2 inches a year in Missouri to 27.4 inches 

in Minnesota. The average precipitation is 36.1 inches.

This chapter will provide only general environmental information about lands within the 

Midwest Region Refuge System. More specific information on specific refuges or wetland 

management districts is available on the station’s web page:

http://www.fws.gov/midwest/refuges

Information is also available in completed comprehensive conservation plans for Midwest 

Region refuges and wetland management districts:

http://www.fws.gov/midwest/planning/completedplans.html

3.2 Habitat

Two hundred years ago, America’s Midwest was characterized by vast prairies, forests, and 

wetlands. We know this by recreating landcover from historical surveyor notes, but differing 

classifications make it difficult to summarize forest acreages, especially where woody wetlands 
20

are mixed with upland forest. Figure 2 shows estimates for historic woodland and prairie in the 

Midwest Region. Historical wetland data has been compiled for the nation using soils 

information, and Table 1 depicts the historic versus current wetland acreages in the Midwest 

Region.

Figure 2: Potential Historic Natural Habitats in the Midwest Region
21

 Table 1: Wetland Loss, FWS Midwest Region

State Size Historic Wetland Percent Loss Current 

Wetland

Illinois 36,031,296 12,000,000 90% 1,260,000

Indiana 23,296,002 5,420,000 85% 813,000

Iowa 36,004,599 3,960,000 90% 432,000

Michigan 37,054,886 11,200,000 50% 5,558,000

Minnesota 54,091,771 19,000,000 50% 9,500,000

Missouri 44,692,764 4,843,000 87% 643,000

Ohio 26,363,888 5,000,000 90% 483,000

Wisconsin 35,895,698 10,800,000 50% 5,400,000

Totals: 293,430,904 72,223,000 67% 24,089,000

Source: http://water.usgs.gov/nwsum/WSP2425/state_highlights_summary.html 1997

Today, agriculture is the dominant land use in the eight-state region (see Figure 3). At least some 

portion of all eight states of the Region is within the area known as the “corn belt;” an estimated 

50 percent of all corn grown in the U.S. comes from Iowa, Indiana, Illinois and Ohio. Cropland 

in these eight states accounts for approximately 29 percent of the nation’s cropland. 

As of 2010, the Refuge System included about 1.2 million acres in the Midwest Region of the 

Fish and Wildlife Service. Habitats include wetland, grassland, shrubland, woodlands with some 

agriculture. These lands can be characterized as:

41 percent upland

48 percent wetlands

11 percent of open water

Active management occurs on approximately 32 percent of the lands with 10 percent not 

requiring management and 58 percent of management deferred due to time or funding 

constraints. (USFWS 2010). 

The Service acquires land for the National Wildlife Refuge System on a willing-seller-only basis, 

which means that refuges and wetland management districts grow slowly with numerous pockets 

of privately owned land referred to as “inholdings” occurring within acquisition boundaries 

(Table 2).
22

Figure 3: Current Land Cover in the Midwest Region of the FWS 
23

3.3 Existing Management of Refuge System Lands

The Fish and Wildlife Service uses a variety of techniques to manage lands within the National 

Wildlife Refuge System, depending on the habitat, the presence of endangered species, and other 

factors. Habitat management tools include prescribed burning, mechanical and chemical 

treatment to manage invasive species, and managing water levels via impoundments to promote 

aquatic vegetation. 

Row crop farming has been used to accomplish habitat restoration and management objectives, 

to attract wildlife for viewing and photography, and to provide supplemental high-energy food 

for migratory waterfowl and resident wildlife. Farming activities on refuges and wetland 

management districts are almost always a small part of the local farming economy. See Figure 4 

for an illustration of Refuge System farming activities compared to agricultural activities on a 

regional basis. 

Table 2: Land Cover Within Inholdings, Midwest Region Refuge System Lands

Habitat Type Percent of Total Inholding 

Acres

Acres Remaining

Water 12.0 39,491

Developed 4.1 13,396

Barren 0.3 1,127

Forest 11.9 39,162

Grassland 5.3 17,386

Pasture/Hay 4.6 15,278

Cultivated Crops 38.0 125,174

Wetland 23.7 77,987

Total Acres 329,001

Land managers have steadily reduced the amount of cropland on refuges and wetland 

management districts over a number of years. Of the 1.2 million acres in the Refuge System in 

the Midwest Region, an estimated 20,418 acres was farmed for corn and soybeans in 2010, 5,775 

fewer acres than were farmed in 2005 (see “Appendix A: Midwest Region Farming 

Information”). 

3.4 Wildlife

A wide array of wildlife occurs on Refuge System lands in the Midwest Region. Species 

managed on these lands include migratory birds, threatened and endangered species, and fish. A 

variety of mammals, reptiles, amphibians, and insects also depend on Refuge System lands for 

food and cover. Refuge System lands in the Midwest Region support birds primarily from the 

Mississippi Flyway. This flyway is a natural path of bird migration from wintering grounds in 

the Gulf of Mexico or further south, then flights along the Mississippi tributaries obtaining 

sustenance along the way, and to nesting grounds in the Midwest Region or into Canada. In the 

fall, birds return south to their wintering ground. Migratory birds use Refuge System lands for 

resting, feeding and nesting. 
24

Figure 4: Agriculture on Refuge System Lands in the Midwest Region 

Inter-jurisdictional fish follow the waterways in the region and may frequent waters on or 

adjacent to Refuge System lands. A variety of small and large mammals also inhabit Refuge 

System land and management of these resident species is shared with the respective state wildlife 

agency. 

3.5 Threatened and Endangered Species

Seventy threatened, endangered, candidate and experimental species are known to occur on 

Refuge System lands in the Midwest Region (see “Appendix B: Threatened and Endangered 

Species of the Midwest Region” on page 46). In general, the majority of these species will be 

found in more natural habitats rather than in the farmed lands. Occasionally some species may 

visit the fields for incidental feeding during migratory periods. More detailed information for 

each species listed can be found online at: 

http://www.fws.gov/endangered/

Refuge specific species can be found by searching the following database:

http://www.fws.gov/refuges/databases/ThreatenedEndangeredSpecies/ThreatenedEndangered_Se

arch.cfm 
25

3.6 Invasive Species

Invasive species are defined as “non-native species whose introduction does, or is likely to cause 

economic or environmental harm or harm to human health” (National Invasive Species Council, 

www.invasivespecies.gov/). Invasive species can be plants, animals, and microbes, but 

discussion of invasive species in this EA refers to plant species. 

Invasive species are a growing issue on Refuge System lands. Estimates of the number of 

invasive plant species in the Midwest Region reach up to 255 (Czarapata 2005). Invasive plants 

can spread quickly, displace native species, and create significant changes in natural 

environments. Some invasive plant species can affect the severity and frequency of wildfire. 

Some interfere with water flow, and others can alter nutrient availability and water quality. 

While overall damages are difficult to determine, estimates of damage from invasive species in 

the U.S. have been as high as $120 billion per year (Pimental et al. 2005). 

3.7 Socioeconomic

The U.S. Census of 2000 counted 61,440,709 people living in the eight states that comprise the 

Midwest Region. According to Census data, 629,809 people operate farms in the eight-state 

region. 

The value of agricultural production in the United States is concentrated into a few regions: the 

Midwest, the Mississippi Delta, California and the Atlantic Coast. Four of the states in the Fish 

and Wildlife Service’s Midwest Region are among the nine states that account for 50 percent of 

the total value of agricultural products: Iowa, Illinois, Minnesota, and Wisconsin (USDA Census 

2007).

3.8 Cultural Resources

Both prehistoric and historical cultural resources are distributed throughout the eight-state 

Midwest Region. The majority of the areas that are farmed are located in previously disturbed 

areas which have very little likelihood of finding cultural resources. 
26

Chapter 4: Environmental Consequences

This chapter discusses the potential effects of the actions proposed in the alternatives. Included 

in the discussion are the effects to the environment and human communities associated with the 

use of farming and GMGT corn and soybeans in the Midwest Region Refuge System lands.

4.1 Effects Common to All Alternatives

4.1.1 Endangered and Threatened Species

The use of GMGT corn and soybeans on Refuge System lands will not affect any threatened or 

endangered species. None of the plants and only a few of the animals that are listed as threatened 

or endangered in the Midwest Region (Appendix B) spend any time in corn or soybean fields. 

The USDA’s APHIS completed environmental assessments of the use of GMGT corn and 

soybeans (USDA 2000, USDA 2007) and concluded: 

1. There are no significant differences between the chemical compositions of GMGT and nonGMGT corn and soybeans. Contact with, or ingestion of, GMGT corn and soybeans are very 

unlikely to have any effect on any plant and animal. 

2. Feeding experiments with chickens failed to detect any differences between GMGT and nonGMGT corn and soybeans regarding mortality rates, weight gain, and reproductive rates. 

3. There are no known species of weeds that are sexually compatible with corn or soybeans, so 

there is no likelihood that there can be an unintended transfer of genes to a threatened or 

endangered species. 

4. Corn and soybeans are very unlikely to escape into natural habitats because corn and soybeans 

can only persist with intensive human management, so there is no chance they will escape into 

native habitats occupied by threatened or endangered species. 

5. Use of GMGT corn and soybeans will not significantly alter cultivation practices. Grain 

production in the Midwest Region will be dominated by corn and soybeans that are treated with 

herbicides and synthetic fertilizers.

The USDA’s APHIS routinely reviews potential impacts for proposals of the general release of 

genetically modified crops. In that agency’s Environmental Assessment of GMGT soybeans and 

corn, APHIS included an evaluation on threatened and endangered species prior to general 

release. The final EAs and Findings of No Significant Impact (FONSI) for both crops concluded 

that no effect is expected on federally listed threatened and endangered species, species proposed 

for listing, or their proposed or designated critical habitats from exposure to GMGT corn or 

soybeans or from exposure to label rates of glyphosate expected to be used in conjunction with 

GMGT soybeans and corn. In addition, the U.S. Environmental Protection Agency has not 

received any reported adverse effects on threatened or endangered species or their habitats from 

exposure to glyphosate or GMGT soybeans and corn.
27

The use of farming as a management tool on NWRS lands will not affect any threatened or 

endangered species. None of the plants and only a few of the animals that are listed as threatened 

or endangered in the Midwest Region (Appendix B) spend any time in row crop fields. 

Endangered and threatened plant species listed would be negatively affected if exposed to 

herbicides during the growing season and this would need to be considered prior to spraying if 

threatened or endangered plants are located in the vicinity. Using herbicides will not impact 

threatened or endangered plants if:

1. Herbicides are applied following pesticide label instructions. These instructions include 

information regarding the use of a particular herbicide around water, near sensitive habitats, 

and near threatened and endangered species 

(http://www.cdms.net/LabelsMsds/LMDefault.aspx?pd=6935&t=1,2,3,4).

2. Conditions outlined in the Service’s cooperative farming agreement are followed. Many of 

these conditions relate to best management practices designs to protect soil and water, and to 

manage pest and nutrients 

(http://www.epa.gov/owow/watershed/wacademy/acad2000/agmodule/).

3. Pesticide Use Proposals are completed, as required by Service policy. Pesticide Use 

Proposals are required before the application of pesticides on Service lands. Impacts to 

threatened or endangered species are considered during this annual review. 

(http://www.fws.gov/contaminants/pdf/PUP.pdf or 

http://www.fws.gov/contaminants/Documents/7RM14.pdf)

4.1.2 Cultural Resources

The consequences of the planned management on cultural resources are the same across all 

alternatives. Since most of the agricultural activities have resulted in ongoing ground 

disturbance, any additional effects to cultural or historic resources are likely to be minor or nonexistent. Any management actions with the potential to affect cultural resources require Refuge 

or District Manager review, as well as review by the Service’s Regional Historic Preservation 

Officer in consultation with the State Historic Preservation Office as mandated by Section 106 of 

the National Historic Preservation Act. Areas considered in this review have been previously 

farmed or disturbed, reducing the likelihood that impacts to cultural resources will occur.

4.1.3 Organic Soybeans

Organic farming is managed in accordance with the Organic Foods Production Act of 1990 to 

respond to site-specific conditions by integrating cultural, biological, and mechanical practices 

that foster cycling of resources, promote ecological balance, and conserve biodiversity. The 

USDA National Organic Program develops, implements, and administers national production, 

handling, and labeling standards (http://www.ams.usda.gov/AMSv1.0/nop). The use of genetic 

engineering is prohibited in the production of organic crops.

A review of potential impacts of glyphosate-tolerant soybeans and corn to Certified Organic 

Farmers was completed by APHIS prior to general release (USDA 2000, USDA 2007). The 
28

conclusion made was that for soybeans, there should be no apparent potential for significant 

impact on organic farming through deregulation and general release. Soybeans are highly selfpollinated with large, heavy seeds that are not easily dispersed. Therefore minimal buffer zones 

are needed to prevent cross-pollination to other soybeans or contamination of adjacent 

agricultural land (USDA 2007). 

No negative impacts on organic soybean farming are anticipated under any of the five 

alternatives evaluated.

4.2 Effects of Management Alternatives

This analysis of effects compares how each of the five alternatives adheres to Service policy and 

how they affect the environmental issues developed during public outreach and listed in Section 

1.7: Public Outreach. The analysis for each alternative addresses the issues in the following 

outline:

Wildlife Issues

1. Use of GMGT corn and soybeans could provide an alternative for farming with less risk to 

wildlife.

2. Agricultural herbicides may be toxic to wildlife.

3. Refuge System units need to provide high energy food for migrating and resident wildlife.

4. Refuge System units need to provide concentrated food sources to attract wildlife for wildlifedependent recreation.

5. Farming negatively impacts wildlife.

Habitat Issues

6. Farming and genetically modified crops (GMCs) can make habitat restoration and 

management more efficient and economical. Increased cost to the Refuge System for restoration 

and maintenance of habitats could make it more difficult to support diverse natural habitats.

7. Farming is an effective way to control invasive plants and invasion of woody species.

8. The Service should use conservation tillage practices to minimize soil erosion on cultivated 

lands.

9. Concern exists for developing herbicide resistance by using GMCs.

Socioeconomic Issues

10. Non-genetically modified seeds are becoming less available in local communities.
29

11. Not being able to use GMCs could make farming more costly for cooperators. Local farming 

cooperators will lose income if farming is reduced or eliminated.

12. Changing farming on Refuge System lands will impact the economy.

13. Use of GMGT corn and soybeans on Refuge System lands could impact neighboring organic 

farmers due to inadvertent gene flow from GM to organic crops. 

4.2.1 Alternative A: Continue Farming for Multiple Objectives, GMGT Corn and Soybeans 

Allowed (No Action) 

4.2.1.1 Summary of Alternative A Effects

Under Alternative A, the use of GMGT corn and soybeans on Refuge System lands in the 

Midwest Region would continue. Currently, about 50 percent of farmed Refuge System lands are 

scheduled to be restored to natural habitats over the next 15 years. Under Alternative A, the 

Service would adhere to the present schedule for restoring farmland to native habitat. Future 

newly purchased lands could also be farmed until being restored to native habitat. 

Beyond 15 years, it is expected that significant decreases will continue in row crop acreage as 

Refuge and District comprehensive conservation plans (CCPs) are revised. The amount and 

extent of this decrease will be determined as these CCPs are updated. 

Alternative A has wildlife advantages because: it accommodates conservation tillage, and it is an 

efficient, cost-effective method of producing supplemental food for wildlife and preparing farm 

land for conversion to natural habitats. Alternative A would also provide an efficient, costeffective method of growing food to attract wildlife for viewing, photography, and other 

wildlife-dependent recreation. Alternative A would have no effect on seed availability, 

cooperative farmers, or the Midwest farm economy. Alternative A would not increase the threat 

of herbicide toxicity to wildlife, but of the five alternatives, it has the highest risk of developing 

herbicide (glyphosate) resistance in weeds. Use of farming or genetically modified crops on 

Refuge System lands must be determined to be required to accomplish the establishing purpose 

of the refuge or district where it is used. Use also requires specific concurrence through the 

Midwest Region Refuge Chief.

4.2.1.2 Wildlife Issues

Issue 1: Use of GMGT crops could provide an alternative for farming with less risk to wildlife.

Growing GMGT corn and soybeans has some conservation advantages over growing non-GM 

hybrids. The use of glyphosate-tolerant crops increases the chances that conservation tillage can 

be successfully used (Towery and Werblow 2010). Conservation tillage results in reduced soil 

disturbance and increased crop residue which decrease soil erosion. Reduced soil erosion results 

in more productive land and cleaner water. Glyphosate is also relatively environmentally benign, 

especially when compared to most other herbicides (Duke and Powles 2008). Field and 

laboratory studies show it does not leach appreciably, has low potential for runoff (Shipitalo et 
30

al. 2006), is nontoxic to honeybees, practically nontoxic to fish, may be slightly toxic to aquatic 

invertebrates, is slightly toxic to wild birds, and has no significant potential to accumulate in 

animal tissue 

(http://extoxnet.orst.edu/pips/glyphosa.htm). 

Use of GMGT corn and soybeans does offer some conservation advantages over non-GM 

hybrids, but there are also some potential risks involved to aquatic species when some 

commercial formulations of glyphosate are applied too closely to water. Commercial 

formulations of glyphosate often contain additional chemicals (surfactants) that are added to 

increase its effectiveness. Some research indicates that there are commercial formulations of 

glyphosate that can negatively impact amphibians (Dinehart et al. 2010) and aquatic 

communities in general (Relyea 2005, Vera et al. 2010) and it is likely these additional chemicals 

that cause the toxicity (Mann et al. 2009). These impacts can be minimized by applying 

glyphosate following label instructions like “Do not apply directly to water” or “to areas where 

surface water is present.” Because there is a wide range of toxicity exhibited by different 

formulations of glyphosate (Langeland 2006), these impacts can also be managed by using less 

toxic formulations. 

When applied according to label instructions, there is a reasonable certainty that no harm to the 

environment will occur. 

Issue 2: Agricultural herbicides may be toxic to wildlife.

There is wide variation in toxicity of herbicides and some have been banned by the US EPA 

(http://wsprod.colostate.edu/cwis79/Factsheets/Sheets/141BannedPesticides.pdf). 

The Service has implemented a Pesticide Use Proposal program 

(http://www.fws.gov/contaminants/pdf/PUP.pdf or 

http://www.fws.gov/contaminants/Documents/7RM14.pdf) that requires approval before 

application of a pesticide on Service land. In the Midwest Region, Refuge System unit managers 

have a limited list of herbicides that they can approve for use. Herbicides not on the list require 

approval at the regional or national level. 

Using herbicides will not impact wildlife when:

1. Herbicides are applied following label instructions. These instructions include 

information regarding the use of a particular herbicide around water, near sensitive 

habitats, and near threatened and endangered species 

(http://www.cdms.net/LabelsMsds/LMDefault.aspx?pd=6935&t=1,2,3,4).

2. Conditions outlined in the Service’s cooperative farming agreement are followed. Many 

of these conditions relate to best management practices designs to protect soil and water, 

and to manage pest and nutrients 
31

(http://www.epa.gov/owow/watershed/wacademy/acad2000/agmodule/).

3. Pesticide Use Proposals are completed, as required by Service policy. Pesticide Use 

Proposals are required before the application of pesticides on Service lands. Impacts to 

threatened or endangered species are considered during this annual review. 

(http://www.fws.gov/contaminants/pdf/PUP.pdf or 

http://www.fws.gov/contaminants/Documents/7RM14.pdf)

Issue 3: Refuge System units need to provide high-energy food for migrating and resident 

wildlife.

Natural resource managers have long used cultivated crops as a method of supplementing natural 

foods available for wildlife. The focus was traditionally on migrating and wintering game 

species, but there is recognition that this source of food can be valuable for nongame species too 

(Donalty et al. 2003). Many wildlife species have adapted to the loss of natural food sources by 

feeding on cultivated grains (Foster et al. 2010). However, more efficient harvesting equipment 

and more farm land planted in soybeans have resulted in a reduction in the amount waste grain 

available for wildlife (Krapu et al. 2004). Large-scale plans to conserve waterfowl populations 

consider the availability of cultivated grains when determining if enough food exists to support 

desired population levels (U.S. Department of the Interior and Environment Canada 1986). 

Cultivated grains are often used in waterfowl management because agricultural seeds tend to 

have greater energy than many natural seeds (Kaminski et al. 2003) and agricultural crops have 

higher yield per unit area than natural wetland plants (Kross et al. 2008). Some waterfowl 

biologists recommend providing unharvested grain fields and natural wetlands for migrating and 

wintering waterfowl because seed resources are low in harvested agricultural fields (Foster et al. 

2010). 

Many Refuge System units were established to support population of waterfowl or migratory 

birds. Providing food for large populations of waterfowl is often accomplished by managing 

natural wetlands, moist soil impoundments, and cultivated grains. Currently, about 4,000 acres of 

Refuge System lands are farmed to provide food for wildlife. This practice would continue under 

this alternative. Because it is now the dominant type of corn planted in the Midwest Region, it 

will be most cost effective and productive to provide high-calorie food (corn) using GMGT corn. 

Issue 4: Refuge System units need to provide concentrated food sources to attract wildlife for 

wildlife-dependent recreation.

Although used minimally, natural resource managers have long grown food plots (cultivated 

stands of corn, milo, sunflowers, millet, etc.) as a method to attract wildlife for increased viewing 

opportunities for the public. This has also been an historic activity on Refuge System lands that 

is used to encourage wildlife observation, wildlife photography, environmental education, and 

environmental interpretation. The National Wildlife Refuge System Improvement Act (1997) 

directs that compatible wildlife-dependent recreational uses including wildlife observation and 

photography, and environmental education and interpretation receive enhanced consideration in 

planning and management over all other general public uses of the Refuge System. When 

compatible, these wildlife-dependent recreational uses are to be strongly encouraged.
32

Because it is now the dominant variety of corn planted in the Midwest Region, it will be most 

cost effective and productive to provide concentrated foods sources to attract wildlife for 

wildlife-dependent recreation using GMGT corn and soybeans. 

Issue 5: Farming negatively impacts wildlife.

While some species in the Midwest Region have readily adapted to the large scale conversion of 

native habitats to cultivated farmland, many wildlife species have been negatively impacted by 

farming. Farming has a great impact on biodiversity and impacts ecosystems by replacing natural 

habitats with vegetation that is nearly monotypic, globally removes about 30 percent of primary 

production for human use, uses and adds water and fertilizers on a scale that influences 

ecosystem functioning, and adds pesticides that directly affect plants and animals (Firbank et al. 

2008, Tilman et al. 2001). 

The Service has long recognized the importance of natural habitat to wildlife. A large portion of 

the Refuge System lands in the Midwest Region were being farmed before they became part of 

the Refuge System. Currently, 1.6 percent of Refuge System lands are farmed. About 50 percent 

of farmed Refuge System lands are scheduled to be restored to natural habitats over the next 15 

years. Future newly purchased lands could also be farmed until land is restored.

Beyond 15 years, it is expected that significant decreases will continue in row crop acreage as 

Refuge and District CCPs are revised. The amount and extent of this decrease will be determined 

as these CCPs are updated. 

4.2.1.3 Habitat Issues

Issue 6: There is a need to restore and maintain more native habitats in an efficient manner. 

Farming and GMCs can make habitat restoration and management more efficient and 

economical. Increased cost to the Refuges for restoration and maintenance of habitats could 

make it more difficult to support diverse natural habitats. 

Restoration of natural habitats is a Service priority: 

Where feasible and consistent with refuge purpose(s), we restore degraded or modified 

habitats in the pursuit of biological integrity, diversity, and environmental health. 

(Improvement Act)

In the Midwest Region, this usually means converting farmland to prairie, forest or wetland. As 

mentioned in Chapter 2, farm fields that are left to grow unmanaged would end up with 

vegetation that does not meet the purposes of Refuge System lands. The typical restoration

technique includes the continuation of farming and herbicide use until just before restoration 

planting occurs. Continued farming and herbicide use minimizes the number of residual weeds 

and weed seeds that will compete with the native vegetation to be planted. The use of herbicideresistant genetically modified crops results in timely and cost-effective restoration of habitat as 

the associated seed and herbicides are readily available (Brookes 2010, Helzer 2010). Excess 

vegetation can also make it difficult or impossible to operate the equipment used to plant native 
33

vegetation. Lastly, using farming to maintain sites in good condition for restoration makes 

restoration more economically feasible. 

Because they are now the dominant type of corn and soybeans planted in the Midwest Region, it 

will be most cost effective to prepare farm land for conversion to native habitats using GMGT 

corn and soybeans. 

Issue 7: Farming is an effective way to control invasive plants and invasion of woody species.

Invasive species of plants and animals are a growing problem on a global, national, and regional 

scale (Pimentel et al. 2005). Invasive species are a threat to agricultural and native habitats 

(http://www.fws.gov/invasives/). The Service often continues farming land until just before 

restoration in order to discourage invasive plants. 

Because they are now the dominant hybrids of corn and soybeans planted in the Midwest 

Region, it will be most cost effective to prevent invasive plants from becoming established in 

areas that will be restored to native habitat by using GMGT corn and soybeans.

Issue 8: The Service should use conservation tillage practices to minimize soil erosion on 

cultivated lands.

Conservation tillage results in reduced soil disturbance and increased crop residue which 

decrease soil erosion. Reduced soil erosion results in more productive land and cleaner water. 

Glyphosate-tolerance increases the chances that conservation tillage can be successfully used 

(Towery and Werblow 2010).

Issue 9: Concern exists for developing herbicide resistance in weeds by using GMCs.

There are almost 200 species of herbicide resistant plants worldwide and many glyphosateresistant weeds in the Midwest Region (Heap 2010: www.weedscience.org). Herbicide 

resistance is a growing problem. For example, glyphosate resistance in horseweed (Conyza 

canadensis) was first identified in Maryland in 2001 (VanGessel 2001). Glyphosate-resistant 

horseweed is now found in five of eight Midwest Region states (www.weedsicence.org). Almost 

90 percent of all herbicide-tolerant crops are glyphosate-tolerant. The use of glyphosate is being 

threatened by the evolution of glyphosate-resistant weeds (Duke and Powles 2008). Currently, 

more than 90 percent of the soybeans and 80 percent of the corn planted in North America is 

glyphosate tolerant. Regular, wide spread use of the same herbicide increases the risk of 

developing herbicide resistance. Integrated pest management techniques minimize the likelihood 

of herbicide resistance by regularly changing the technique used to control weeds: rotating type 

of herbicide used, rotating crop planted, and using mechanical methods.

In theory, using GMGT corn and soybeans should help manage herbicide resistance because it 

would be an additional technique to use in weed management. In practice, GMGT corn and 

soybeans are so widely used on a regular basis, that their use actually encourages herbicide 

resistance (Duke and Powles 2008). Effective use of Integrated Pest Management 
34

(http://www.fws.gov/contaminants/Documents/IPMfinal.pdf) will help manage herbicide 

resistance. 

4.2.1.4 Socio-economic Issues

Issue 10: Non-genetically modified seeds are becoming less available in local communities. 

GM herbicide-tolerant crops were planted on 92 percent of the U.S. soybean acres and 80 

percent of the corn acres in 2008 (Brookes 2010). Alternative A would have no effect on seed 

availability since both GM and non-GM seed could still be used in Refuge System farming 

operations.

Issue 11: Not being able to use GMCs could make farming more costly for cooperators. Local 

farming cooperators will lose income if farming is reduced or eliminated. 

Farmers could continue to use GMGT corn and soybeans under Alternative A. Under Alternative 

A, local farming cooperators will lose farming opportunities as 50 percent of Refuge System row 

crop lands are restored to natural habitats in the next 15 years.

Issue 12: Changing farming on Refuge System lands will impact the economy.

Farming priorities would continue unchanged under Alternative A. Considering the small 

amount of land farmed and the continual reduction in that total as land is restored to natural 

habitat, changes in farming on Refuge System lands can be expected to have a negligible impact 

on the economy.

The 0.02 percent of lands farmed within the Refuge System in the Midwest Region is spread out 

among 54 national wildlife refuges and 12 wetland management districts, further reducing the 

economic impact of any change to farming activities on Refuge System lands. 

Issue 13: Use of GMGT corn and soybeans on Refuge System lands could impact neighboring 

organic farmers due to inadvertent gene flow from GM to organic crops. 

The USDA National Organic Program lists 2,800 Certified Organic Operations (farmers) in the 

Midwest Region (http://apps.ams.usda.gov/nop/). About 60 percent of these farmers raise 

organic corn. Corn is currently raised on 31 refuges and wetland management districts in the 

Midwest Region.

Review of the potential impacts of glyphosate-tolerant corn to Certified Organic Farmers was 

completed by APHIS prior to general release (USDA 2000, USDA 2007). The conclusion made 

for corn was that all corn, whether genetically engineered or not, can transmit pollen to nearby 

corn fields. A small influx of pollen originating from a given corn variety does not appreciably 

change the characteristics of corn in adjacent fields. The frequency of occurrence decreases with 

increasing distance from the pollen source such that it is negligible by 660 feet, the isolation 

distance considered safe for certified corn seeds (USDA 2000).
35

Under Alternative A, the use of GMGT corn on Refuge System lands has the potential to 

negatively affect organic farmers who have fields within 660 feet. Typically, organic farmers are 

responsible for providing their own buffers to ensure that they meet organic farming standards. If 

Refuge or District Managers are made aware of adjacent Certified Organic farm acres for corn, 

they may take measures to address neighboring landowner concerns and assist in providing 

required buffers.

The potential for row crop farming on Refuge System lands to conflict with organic farming 

operations will decrease over the next 15 years as 50 percent of Refuge System row crop lands 

are restored to natural habitats.

4.2.2 Alternative B: Farming for Habitat Restoration Objectives Only, GMGT Corn and 

Soybeans Allowed

4.2.2.1 Summary of Alternative B Effects

Under Alternative B, the use of GMGT corn and soybeans on Refuge System lands in the 

Midwest Region would continue. Currently, about 50 percent of farmed Refuge System lands are 

scheduled to be restored to natural habitats over the next 15 years. Under Alternative B, the 

Service would restore between 50 percent and 80 percent of Refuge System lands in the next 15 

years. Beginning in 2012, as Refuge and District comprehensive conservation plans are revised, 

row crop farming would be limited to meeting habitat restoration objectives only. Future newly 

purchased lands could also be farmed for 3 years until being restored to native habitat. 

Alternative B has wildlife advantages because: it encourages conservation tillage, and it is an 

efficient, cost-effective method of preparing farm land for conversion to natural habitats. 

Compared to Alternative A, Alternative B would be a less efficient, cost-effective method of 

producing supplemental food for wildlife and growing food to attract wildlife for viewing, 

photography, and other wildlife-dependent recreation. Alternative B would have no effect on 

seed availability or the Midwest farm economy. Local cooperative farmers would be affected 

because, ultimately, fewer acres would be farmed. Alternative B would not increase the threat of 

herbicide toxicity to wildlife, and it has a lower risk of developing herbicide (glyphosate) 

resistance in weeds because fewer acres would be planted with GMGT corn and soybeans. Use 

of farming or genetically modified crops on Refuge System lands must be determined to be 

required to accomplish the establishing purpose of the refuge or district where it is used. Use also 

requires specific concurrence through the Midwest Region Refuge Chief.
36

4.2.2.2 Wildlife Issues

Issue 1: Use of GMGT crops could provide an alternative for farming with less risk to wildlife.

The effects under this alternative are the same as the effects under Alternative A.

Growing GMGT corn and soybeans has some conservation advantages over growing non-GM 

hybrids. The use of glyphosate-tolerant crops increases the chances that conservation tillage can 

be successfully used (Towery and Werblow 2010). Conservation tillage results in reduced soil 

disturbance and increased crop residue which decrease soil erosion. Reduced soil erosion results 

in more productive land and cleaner water. Glyphosate is also relatively environmentally benign, 

especially when compared to most other herbicides (Duke and Powles 2008). Field and 

laboratory studies show it does not leach appreciably, has low potential for runoff (Shipitalo et 

al. 2006), is nontoxic to honeybees, practically nontoxic to fish, may be slightly toxic to aquatic 

invertebrates, is slightly toxic to wild birds, and has no significant potential to accumulate in 

animal tissue (http://extoxnet.orst.edu/pips/glyphosa.htm). 

Commercial formulations of glyphosate often contain additional chemicals (surfactants) that are 

added to increase its effectiveness. Some research indicates that there are commercial 

formulations of glyphosate that can negatively impact amphibians (Dinehart et al. 2010) and 

aquatic communities in general (Relyea 2005, Vera et al. 2010) and it is likely these additional 

chemicals that cause the toxicity (Mann et al. 2009). These impacts can be minimized by 

applying glyphosate following label instructions like “Do not apply directly to water” or “to 

areas where surface water is present.” Because there is a wide range of toxicity exhibited by 

different formulations of glyphosate (Langeland 2006), these impacts can also be managed by 

using less toxic formulations.

Use of GMGT corn and soybeans does offer some conservation advantages over non-GM 

hybrids, but there are also some potential risks involved to aquatic species when some 

commercial formulations of glyphosate are applied too closely to water. These risks can be 

minimized by following glyphosate label instructions and using commercial formulations that 

are known to have lower toxicity. 

Issue 2: Agricultural herbicides may be toxic to wildlife. 

The effects under this alternative are the same as the effects under Alternative A.

There is wide variation in toxicity of herbicides and some have been banned by the US EPA 

(http://wsprod.colostate.edu/cwis79/Factsheets/Sheets/141BannedPesticides.pdf). 

The Service has implemented a Pesticide Use Proposal program 

(http://www.fws.gov/contaminants/pdf/PUP.pdf or 

http://www.fws.gov/contaminants/Documents/7RM14.pdf) that requires approval before 

application of a pesticide on Service land. In the Midwest Region, Refuge System unit managers 

have a limited list of herbicides that they can approve for use. Herbicides not on the list require 

approval at the regional or nation level. 
37

Using herbicides will not impact wildlife:

1. Herbicides are applied following label instructions. These instructions include information 

regarding the use of a particular herbicide around water, near sensitive habitats, and near 

threatened and endangered species 

(http://www.cdms.net/LabelsMsds/LMDefault.aspx?pd=6935&t=1,2,3,4).

2. Conditions outlined in the Service’s cooperative farming agreement are followed. Many of 

these conditions relate to best management practices designs to protect soil and water, and to 

manage pest and nutrients 

(http://www.epa.gov/owow/watershed/wacademy/acad2000/agmodule/).

3. Pesticide Use Proposals are completed, as required by Service policy. Pesticide Use Proposals 

are required before the application of pesticides on Service lands. Impacts to threatened or 

endangered species are considered during this annual review. 

(http://www.fws.gov/contaminants/pdf/PUP.pdf or 

http://www.fws.gov/contaminants/Documents/7RM14.pdf)

Issue 3: Refuge System units need to provide high-energy food for migrating and resident 

wildlife.

This alternative would provide supplemental foods to migrating and wintering wildlife only 

during the time land was being prepared for restoration to natural habitat. Currently, about 4,000 

acres of Refuge System lands are farmed to provide food for wildlife.

Natural resource managers have long used cultivated crops as a method of supplementing natural 

foods available for wildlife. The focus was traditionally on migrating and wintering game 

species, but there is recognition that this source of food can be valuable for nongame species too 

(Donalty et al. 2003). Some refuges and wetland management districts may find it difficult to 

meet their establishing purposes without the ability to provide supplemental food for migratory 

birds.

Issue 4: Refuge System units need to provide concentrated food sources to attract wildlife for 

wildlife-dependent recreation.

Although used minimally, natural resource managers have long grown food plots (cultivated 

stands of corn, milo, sunflowers, millet, etc.) as a method to attract wildlife for increased viewing 

opportunities for the public. This has also been an historic activity on Refuge System lands that 

is used to encourage wildlife observation, wildlife photography, environmental education, and 

environmental interpretation. The National Wildlife Refuge System Improvement Act (1997) 

directs that compatible wildlife-dependent recreational uses including wildlife observation and 

photography, and environmental education and interpretation receive enhanced consideration in 

planning and management over all other general public uses of the Refuge System. When 

compatible, these wildlife-dependent recreational uses are to be strongly encouraged. 
38

Under this alternative, Refuge System lands farmed to attract wildlife for wildlife-related 

recreational purposes would be restored to natural habitat within the next 15 years.

Issue 5: Farming negatively impacts wildlife.

While some species in the Midwest Region have readily adapted to the large scale conversion of 

native habitats to cultivated farmland, many wildlife species have been negatively impacted by 

farming. Farming has a great impact on biodiversity and impacts ecosystems by replacing natural 

habitats with vegetation that is nearly monotypic, globally removes about 30 percent of primary 

production for human use, uses and adds water and fertilizers on a scale that influences 

ecosystem functioning, and adds pesticides that directly affect plants and animals (Firbank et al. 

2008, Tilman et al. 2001). 

The Service has long recognized the importance of natural habitat to wildlife. Approximately 

half of the Refuge System lands in the Midwest Region were being farmed before they became 

part of the Refuge System. Currently, 1.6 percent of Refuge System lands are farmed. About 50 

percent of farmed Refuge System lands are scheduled to be restored to natural habitats over the 

next 15 years. Under Alternative B, the Service would restore between 50 percent and 80 percent 

of Refuge System lands in the next 15 years. Beginning in 2012, as Refuge and District 

comprehensive conservation plans are revised, row crop farming would be limited to meeting 

habitat restoration objectives only. Future newly purchased lands could also be farmed for 3 

years until being restored to native habitat. 

4.2.2.3 Habitat Issues

Issue 6: Farming and GMCs can make habitat restoration and management more efficient and 

economical. Increased cost to the Refuges for restoration and maintenance of habitats could 

make it more difficult to support diverse natural habitats. 

The effects under this alternative are the same as the effects under Alternative A, except that 

because the Region would no longer allow farming for purposes other than habitat restoration, 

ultimately, more acres would be restored to natural habitat under this alternative.

Restoration of natural habitats is a Service priority: 

Where feasible and consistent with refuge purpose(s), we restore degraded or modified habitats 

in the pursuit of biological integrity, diversity, and environmental health. (Improvement Act)

In the Midwest Region, this usually means converting farmland to prairie, forest or wetland. As 

mentioned in Chapter 2, farm fields that are left to grow unmanaged would end up with 

vegetation that did not meet the purposes of Refuge System lands. The typical restoration 

technique includes the continuation of farming and herbicide use until just before restoration 

planting occurs. Continued farming and herbicide use minimizes the number of residual weeds

and weed seeds that will compete with the native vegetation to be planted. The use of herbicideresistant genetically modified crops results in timely and cost-effective restoration of habitat as 

the associated seed and herbicides are readily available (Brookes 2010, Helzer 2010). Excess 
39

vegetation can also make it difficult or impossible to operate the equipment used to plant native 

vegetation. Lastly, using farming to maintain sites in good condition for restoration makes 

restoration more economically feasible.

Because they are now the dominant variety of corn and soybeans planted in the Midwest 

Region, it will be most cost effective to prepare farm land for conversion to native habitats using 

GMGT corn and soybeans. 

Issue 7: Farming is an effective way to control invasive plants and invasion of woody species.

The effects under this alternative are the same as the effects under Alternative A.

Invasive species of plants and animals are a growing problem on a global, national, and regional 

scale (Pimentel et al. 2005). Invasive species are a threat to agricultural and native habitats 

(http://www.fws.gov/invasives/). The Service often continues farming land until just before 

restoration in order to discourage invasive plants. 

Because they are now the dominant hybrids of corn and soybeans planted in the Midwest 

Region, it will be most cost effective to prevent invasive plants from becoming established in 

areas that will be restored to native habitat by using GMGT corn and soybeans. 

Issue 8: The Service should use conservation tillage practices to minimize soil erosion on 

cultivated lands.

The effects under this alternative are the same as the effects under Alternative A.

Conservation tillage results in reduced soil disturbance and increased crop residue which

decrease soil erosion. Reduced soil erosion results in more productive land and cleaner water. 

Glyphosate-tolerance increases the chances that conservation tillage can be successfully used 

(Towery and Werblow 2010).

Issue 9: Concern exists for developing herbicide resistance in weeds by using GMCs.

The general effects under this alternative are the same as the effects under Alternative A, 

however, because farming is limited to habitat restoration only, less acres will be farmed in the 

future. This should reduce the chance of developing herbicide resistance in weeds.

There are almost 200 species of herbicide resistant plants worldwide and many glyphosateresistant weeds in the Midwest (Heap 2010: www.weedscience.org). Herbicide resistance is 

growing problem. For example, glyphosate resistance in horseweed (Conyza Canadensis) was 

first identified in Maryland in 2001 (VanGessel 2001). Glyphosate-resistant horseweed now 

found in five of eight Midwest Region states (www.weedscience.org). Almost 90 percent of all

herbicide resistant crops are glyphosate-resistant. The use of glyphosate is being threatened by 

the evolution of glyphosate-resistant weeds (Duke and Powles 2008). Currently, more than 90 

percent of the soybeans and 80 percent of the corn planted in North America is glyphosatetolerant. Regular, widespread use of the same herbicide increases the risk of developing 
40

herbicide resistance. Integrated pest management techniques minimize the likelihood of 

herbicide resistance by regularly changing the technique used to control weeds: rotating type of 

herbicide used, rotating crop planted, and using mechanical methods.

In theory, using GMGT corn and soybeans should help manage herbicide resistance because it 

would be an additional technique to use in weed management. In practice, GMGT corn and 

soybeans are so widely used on a regular basis, that their use actually encourages herbicide 

resistance (Duke and Powles 2008). Effective use of Integrated Pest Management 

(http://www.fws.gov/contaminants/Documents/IPMfinal.pdf) will help manage herbicide 

resistance. Use of genetically modified crops on Refuge System lands must be determined to be 

essential to accomplishing the establishing purpose of the refuge or district where it is used. Use 

also requires specific concurrence through the Midwest Region Refuge Chief. 

4.2.2.4 Socio-economic Issues

Issue 10: Non-genetically modified seeds are becoming less available in local communities.

GM herbicide-tolerant crops were planted on 92 percent of the U.S. soybean acres and 80

percent of the corn acres in 2008 (Brookes 2010). Like Alternative A, Alternative B would have 

no effect on seed availability since both GM and non-GM seed could still be used in Refuge 

System farming operations.

Issue 11: Not being able to use GMCs could make farming more costly for cooperators. Local 

farming cooperators will lose income if farming is reduced or eliminated. 

Farmers could continue to use GMGT corn and soybeans under Alternative B. Under Alternative 

B, local farming cooperators will lose farming opportunities as 50-80 percent of Refuge System 

row crop lands are restored to natural habitats in the next 15 years. Newly acquired lands would 

be farmed only to prepare them for restoration to natural habitats. 

Issue 12: Changing farming on Refuge System lands will impact the economy.

Currently, about 50 percent of the 20,000 acres currently farmed Refuge System lands are 

scheduled to be restored to natural habitats over the next 15 years. Under Alternative B, the 

Service would restore between 50 percent and 80 percent of Refuge System lands in the next 15 

years. Beginning in 2012, as Refuge and District comprehensive conservation plans are revised, 

they would limit row crop farming to meeting habitat restoration objectives only. Future newly 

purchased lands could also be farmed for habitat restoration objectives until being restored to 

native habitat. Because of the small size of the farming operations on Refuge System lands 

relative to the size of the Midwest farming economy, the economic effect of gradually 

eliminating long-term farming will be negligible (Table 3 on page 36).

Issue 13: Use of GMGT corn and soybeans on Refuge System lands could impact neighboring 

organic farmers due to inadvertent gene flow from GM to organic crops. 
41

The USDA National Organic Program lists 2,800 Certified Organic Operations (farmers) in the 

Midwest Region (http://apps.ams.usda.gov/nop/). About 60 percent of these farmers raise 

organic corn. Corn is currently raised on 31 refuges and wetland management districts in the 

Midwest Region.

Review of the potential impacts of glyphosate-tolerant corn to Certified Organic Farmers was 

completed by APHIS prior to general release (USDA 2000, USDA 2007). The conclusion made 

for corn was that all corn, whether genetically engineered or not, can transmit pollen to nearby 

corn fields. A small influx of pollen originating from a given corn variety does not appreciably 

change the characteristics of corn in adjacent fields. The frequency of occurrence decreases with 

increasing distance from the pollen source such that it is negligible by 660 feet, the isolation 

distance considered safe for certified corn seeds (USDA 2000)

Under Alternative B, the use of GMGT corn on Refuge System lands has the potential to 

negatively affect organic farmers who have fields within 660 feet. Typically, organic farmers are 

responsible for providing their own buffers to ensure that they meet organic farming standards. If 

Refuge or District Managers are made aware of adjacent Certified Organic farm acres for corn, 

they may take measures to address neighboring landowner concerns and assist in providing 

required buffers.

4.2.3 Alternative C: Farming for Multiple Objectives, No GMGT Corn and Soybeans 

4.2.3.1 Summary of Alternative C Effects

Two years after approval of this EA, the use of GMGT corn and soybeans would no longer be 

allowed on Refuge System lands in the Midwest Region under Alternative C. Currently, about 50 

percent of farmed Refuge System lands are scheduled to be restored to natural habitats over the 

next 15 years. Under Alternative C, the Service would adhere to the present schedule for 

restoring farmland to native habitat. Future newly purchased lands could also be farmed until 

being restored to native habitat.

Beyond 15 years, it is expected that significant decreases will continue in row crop acreage as 

Refuge and District CCPs are revised. The amount and extent of this decrease will be determined 

as these CCPs are updated. 

Alternative C would lack some wildlife advantages because: conservation tillage is less likely to 

be used, and it is a less efficient and cost-effective method of producing supplemental food for 

wildlife and preparing farm land for conversion to natural habitats. Alternative C would also be a 

less efficient and cost-effective method of growing food to attract wildlife for viewing, 

photography, and other wildlife-dependent recreation. Alternative C would have no effect on the 

Midwest farm economy, but cooperative farmers would be negatively affected because seed 

would be less available and more expensive and profitability may be impacted. Effects of 

herbicide toxicity would be unchanged from Alternative A because the Service restricts the types 

and application of herbicides used on Refuge System lands. Alternative C would have a lower 

threat of developing herbicide (glyphosate) resistance in weeds than Alternative A. Use of 

farming on Refuge System lands must be determined to be required to accomplish the 
42

establishing purpose of the refuge or district where it is used. Use also requires specific 

concurrence through the Midwest Region Refuge Chief.

4.2.3.2 Wildlife Issues

Issue 1: Use of GMGT crops could provide an alternative for farming with less risk to wildlife.

Growing GMGT corn and soybeans has some conservation advantages over growing nonGMGT varieties. The use of glyphosate-tolerant crops increases the chances that conservation 

tillage can be successfully used (Towery and Werblow 2010). Conservation tillage results in 

reduced soil disturbance and increased crop residue which decrease soil erosion. Reduced soil 

erosion results in more productive land and cleaner water. Glyphosate is also relatively 

environmentally benign, especially when compared to most other herbicides (Duke and Powles 

2008). Field and laboratory studies show it does not leach appreciably, has low potential for 

runoff (Shipitalo et al. 2006), is nontoxic to honeybees, practically nontoxic to fish, may be 

slightly toxic to aquatic invertebrates, is slightly toxic to wild birds, and has no significant 

potential to accumulate in animal tissue (http://extoxnet.orst.edu/pips/glyphosa.htm). 

Commercial formulations of glyphosate often contain additional chemicals (surfactants) that are 

added to increase its effectiveness. Some research indicates that there are commercial 

formulations of glyphosate that can negatively impact amphibians (Dinehart et al. 2010) and 

aquatic communities in general (Relyea 2005, Vera et al. 2010) and it is likely these additional 

chemicals that cause the toxicity (Mann et al. 2009). These impacts can be minimized by 

applying glyphosate following label instructions like “Do not apply directly to water” or “to 

areas where surface water is present.” Because there is a wide range of toxicity exhibited by 

different formulations of glyphosate (Langeland 2006), these impacts can also be managed by 

using less toxic formulations.

Under this alternative, there will likely be a reduction in conservation tillage on Refuge System 

lands (Towery and Werblow 2010). This could result in increases in soil disturbance and 

reductions in crop residue which tend to increase soil erosion. Soil erosion results in less 

productive land and cleaner water. 

Issue 2: Agricultural herbicides may be toxic to wildlife.

The effects under this alternative are the same as the effects under Alternative A because the 

Service restricts the types and applications of herbicides used on Refuge System lands.

There is wide variation in toxicity of herbicides and some have been banned by the U.S. EPA 

(http://wsprod.colostate.edu/cwis79/Factsheets/Sheets/141BannedPesticides.pdf). 

The Service has implemented a Pesticide Use Proposal program 

(http://www.fws.gov/contaminants/pdf/PUP.pdf or 

http://www.fws.gov/contaminants/Documents/7RM14.pdf) that requires approval before 

application of a pesticide on Service land. In the Midwest Region, Refuge System unit managers 
43

have a limited list of herbicides that they can approve for use. Herbicides not on the list require 

approval at the regional or nation level. 

Using herbicides will not impact wildlife:

1. Herbicides are applied following label instructions. These instructions include information 

regarding the use of a particular herbicide around water, near sensitive habitats, and near 

threatened and endangered species 

(http://www.cdms.net/LabelsMsds/LMDefault.aspx?pd=6935&t=1,2,3,4).

2. Conditions outlined in the Service’s cooperative farming agreement are followed. Many of 

these conditions relate to best management practices designs to protect soil and water, and to 

manage pest and nutrients 

(http://www.epa.gov/owow/watershed/wacademy/acad2000/agmodule/).

3. Pesticide Use Proposals are completed, as required by Service policy. Pesticide Use Proposals 

are required before the application of pesticides on Service lands. Impacts to threatened or 

endangered species are considered during this annual review. 

(http://www.fws.gov/contaminants/pdf/PUP.pdf or 

http://www.fws.gov/contaminants/Documents/7RM14.pdf)

Issue 3: Refuge System units need to provide high-energy food for migrating and resident 

wildlife.

Natural resource managers have long used cultivated crops as a method of supplementing natural 

foods available for wildlife. The focus was traditionally on migrating and wintering game 

species, but there is recognition that this source of food can be valuable for nongame species too 

(Donalty et al. 2003). Many wildlife species have adapted to the loss of natural food sources by 

feeding on cultivated grains (Foster et al. 2010). However, more efficient harvesting equipment 

and more farm land planted in soybeans has resulted in a reduction in the amount of waste grain 

available for wildlife (Krapu et al. 2004). Large-scale plans to conserve waterfowl populations 

consider the availability of cultivated grains when determining if enough food exists to support 

desired population levels (U.S. Department of the Interior and Environment Canada 1986). 

Cultivated grains are often used in waterfowl management because agricultural seeds tend to 

have greater energy than many natural seeds (Kaminski et al. 2003) and agricultural crops have 

higher yield per unit area than natural wetland plants (Kross et al. 2008). Some waterfowl 

biologists recommend providing unharvested grain fields and natural wetlands for migrating and 

wintering waterfowl because seed resources are low in harvested agricultural fields (Foster et al. 

2010). 

Many Refuge System units were established to support populations of waterfowl or migratory 

birds. Providing food for large populations of waterfowl is often accomplished by managing 

natural wetlands, moist soil impoundments, and cultivated grains. Currently, about 5,000 acres of 

Refuge System lands are farmed to provide food for wildlife. This practice would continue under 

this alternative, but it would be more costly and less productive. Because GMGT corn has 
44

become so dominant in the Midwest, it may become difficult to find farmers with interest in 

farming on Refuge System lands. 

Issue 4: Refuge System units need to provide concentrated food sources to attract wildlife for 

wildlife-dependent recreation.

Although used minimally, natural resource managers have long grown food plots (cultivated 

stands of corn, milo, sunflowers, millet, etc.) as a method to attract wildlife for increased viewing 

opportunities for the public. This has also been an historic activity on Refuge System lands that 

is used to encourage wildlife observation, wildlife photography, environmental education, and 

environmental interpretation. The National Wildlife Refuge System Improvement Act (1997) 

directs that compatible wildlife-dependent recreational uses including wildlife observation and 

photography, and environmental education and interpretation receive enhanced consideration in 

planning and management over all other general public uses of the Refuge System. When 

compatible, these wildlife-dependent recreational uses are to be strongly encouraged.

Growing crops to attract wildlife for wildlife-dependent recreation would continue under this 

alternative, but it may be more costly and less productive. Because GMGT corn has become so 

dominant in the Midwest, it may become difficult to find farmers with interest in farming on 

Refuge System lands. 

Issue 5: Farming negatively impacts wildlife.

The effects under this alternative are the same as the effects under Alternative A.

While some species in the Midwest have readily adapted to the large scale conversion of native 

habitats to cultivated farmland, many wildlife species have been negatively impacted by farming. 

Farming has a great impact on biodiversity and impacts ecosystems by replacing natural habitats 

with vegetation that is nearly monotypic, globally removes about 30 percent of primary 

production for human use, uses and adds water and fertilizers on a scale that influences 

ecosystem functioning, and adds pesticides that directly affect plants and animals (Firbank et al. 

2008, Tilman et al. 2001). 

The Service has long recognized the importance of natural habitat to wildlife. Approximately 

half of the Refuge System lands in the Midwest were being farmed before they became part of 

the Refuge System. Currently, only 1.6 percent of Refuge System lands are farmed. Currently, 

about 50 percent of farmed Refuge System lands are scheduled to be restored to natural habitats 

over the next 15 years. Under Alternative C, the Service would adhere to the present schedule for 

restoring farmland to native habitat. Future newly purchased lands could also be farmed until 

being restored to native habitat.

Beyond 15 years, it is expected that significant decreases will continue in row crop acreage as 

Refuge and District CCPs are revised. The amount and extent of this decrease will be determined 

as these CCPs are updated.
45

4.2.3.3 Habitat Issues

Issue 6: Farming and GMCs can make habitat restoration and management more efficient and 

economical. Increased cost to the Refuges for restoration and maintenance of habitats could 

make it more difficult to support diverse natural habitats. 

Restoration of natural habitats is a Service priority: 

Where feasible and consistent with refuge purpose(s), we restore degraded or modified habitats 

in the pursuit of biological integrity, diversity, and environmental health. (Improvement Act)

In the Midwest Region, this usually means converting farmland to prairie, forest or wetland. As 

mentioned in Chapter 2, farm fields that are left to grow unmanaged would end up with 

vegetation that did not meet the purposes of Refuge System lands. The typical restoration 

technique includes the continuation of farming and herbicide use until just before restoration 

planting occurs. Continued farming and herbicide use minimizes the number of residual weeds 

and weed seeds that will compete with the native vegetation to be planted. The use of herbicideresistant genetically modified crops results in timely and cost-effective restoration of habitat as 

the associated seed and herbicides are readily available (Brookes 2010, Helzer 2010). Excess 

vegetation can also make it difficult or impossible to operate the equipment used to plant native 

vegetation. Lastly, using farming to maintain sites in good condition for restoration makes 

restoration more economically feasible. 

Under this alternative, GMGT corn and soybeans would not be used. Because non-GMGT seed 

is becoming more difficult to find and farming without GMGT is less profitable, this would 

make it more costly to prepare Refuge System lands for restoration to natural habitats. This 

makes it likely that some refuges and districts would not meet planned habitat restoration goals.

Issue 7: Farming is an effective way to control invasive plants and invasion of woody species.

Invasive species of plants and animals are a growing problem on a global, national, and regional 

scale (Pimentel et al. 2005). Invasive species are a threat to agricultural and native habitats 

(http://www.fws.gov/invasives/). The Service often continues farming land until just before 

restoration in order to discourage invasive plants. The ability to apply a broad spectrum herbicide 

(glyphosate) over multiple years results in a great reduction of invasive plants and seeds in areas 

scheduled for restoration. This alternative would make it more expensive to restore farmed 

Refuge System lands to natural habitats because GMGT corn and soybeans are now the 

dominant hybrids of corn and soybeans planted in the Midwest. It will be more difficult for 

farmers to find non-GM seed, the profitability of farming on Refuge System lands is likely to 

decline, and some farmers may choose to not farm on Refuge System lands.

Issue 8: The Service should use conservation tillage practices to minimize soil erosion on 

cultivated lands.

Conservation tillage results in reduced soil disturbance and increased crop residue which 

decrease soil erosion. Reduced soil erosion results in more productive land and cleaner water. 
46

Glyphosate-tolerance increases the chances that conservation tillage can be successfully used 

(Towery and Werblow 2010).

There would be less conservation tillage used under this alternative. This may increase the soil 

erosion rates. 

Issue 9: Concern exists for developing herbicide resistance in weeds by using GMCs.

There are almost 200 species of herbicide resistant plants worldwide and many glyphosateresistant weeds in the Midwest (Heap 2010: www.weedscience.org). Herbicide resistance is 

growing problem. For example, glyphosate resistance in horseweed (Conyza Canadensis) was 

first identified in Maryland in 2001 (VanGessel 2001). Glyphosate-resistant horseweed is now 

found in five of eight Midwest Region states (www.weedsicence.org). There are 33 species of 

herbicide-tolerant plants in the Midwest Region, six of these are glyphosate-tolerant 

(www.weedscience.org). Almost 90 percent of all herbicide resistant crops are glyphosate 

resistant. The use of glyphosate is being threatened by the evolution of glyphosate-resistant 

weeds (Duke and Powles 2008). Currently, more than 90 percent of the soybeans and 80 percent 

of the corn planted in North America is glyphosate-tolerant. Regular, wide spread use of the 

same herbicide increases the risk of developing herbicide resistance. Integrated pest management 

techniques minimize the likelihood of herbicide resistance by regularly changing the technique 

used to control weeds: rotating type of herbicide used, rotating crop planted, and using 

mechanical methods.

Under this alternative, GMGT corn and soybeans would not be allowed. This would result in a 

decrease in the amount of glyphosate being used on Refuge System lands. This should reduce the 

likelihood of developing a glyphosate-resistant weed on Refuge System lands.

4.2.3.4 Socioeconomic Issues

Issue 10: Non-genetically modified seeds are becoming less available in local communities.

GM herbicide-tolerant crops were planted on 92 percent of the U.S. soybean acres and 80 

percent of the corn acres in 2008 (Brookes 2010). Under this alternative, GMGT corn and 

soybeans would not be used. The availability of non-genetically modified seed can be limited in 

some areas of the Midwest Region. Availability is likely to decrease over time as it appears that 

GM crops will continue to dominate the seed market. Under Alternative C, cooperating farmers 

are likely to have increasing difficulties finding corn and soybean seeds that are not genetically 

modified.

Issue 11: Not being able to use GMCs could make farming less profitable for cooperators. Local 

farming cooperators will lose income if farming is reduced or eliminated. 

Under Alternative C, local farming cooperators will lose farming opportunities as 50 percent of 

Refuge System row crop lands are restored to natural habitats in the next 15 years. Not being 

able to use GMCs could make farming less profitable for cooperators. Currently, farming with 

non-GM crops results in higher annual pesticide costs to farmers and farm income is reduced due 
47

to higher production costs (Brookes 2010). The profitability of farming on Refuge System lands 

is likely to decline, and some farmers may choose to not farm on Refuge System lands. 

Issue 12: Changing farming on Refuge System lands will impact the economy.

As in all alternatives, about half of farmed Refuge System lands are scheduled to be restored to 

natural habitats over the next 15 years. Because GMGT corn and soybeans would not be used 

under this alternative, the profitability of farming on Refuge System lands is likely to decline, 

and some farmers may choose to not farm on Refuge System lands. Because of the small size of 

the farming operations on Refuge System lands relative to the size of the Midwest farming 

economy, the economic effect of gradually eliminating long-term farming would be negligible.

Issue 13: Use of GMGT corn and soybeans on Refuge System lands could impact neighboring 

organic farmers due to inadvertent gene flow from GM to organic crops. 

The USDA National Organic Program lists 2,800 Certified Organic Operations (farmers) in the 

Midwest Region (http://apps.ams.usda.gov/nop/). About 60 percent of these farmers raise 

organic corn. Corn is currently raised on 31 refuges and wetland management districts in the 

Midwest Region. Under Alternative C, there would be no effect on organic farming operations 

because GMGT corn and soybeans would not be used on Refuge System lands.

4.2.4 Alternative D: Limited Row Crop Farming, No GMGT Corn and Soybeans

4.2.4.1 Summary of Alternative D Effects

Two years after approval of this EA, the use of GMGT corn and soybeans would no longer be 

allowed on Refuge System lands in the Midwest Region under Alternative D. Currently, about 

50 percent of farmed Refuge System lands are scheduled to be restored to natural habitats over 

the next 15 years. Under Alternative D, farming would cease on about 80 percent of currently 

farmed Refuge System lands within 5 years. Forty to 60 percent of these lands would be left to 

unmanaged succession. Future newly purchased lands could also be farmed for up to 3 years for 

habitat restoration objectives. Alternative D lacks some wildlife advantages when compared to 

Alternative A because an efficient, cost-effective method of producing supplemental food for 

wildlife and preparing farm land for conversion to natural habitats would not be used. Farming to 

produce food to attract wildlife for viewing, photography, and other wildlife-dependent 

recreation would not occur. Alternative D would have no effect on the Midwest farm economy, 

but cooperative farmers would be negatively affected because seed would be less available and 

more expensive, profitability may be impacted, and Alternative D has the fewest acres farmed of 

any alternative. Alternative D would not increase the threat of herbicide toxicity to wildlife, and 

it has the lowest risk of developing herbicide (glyphosate) resistance in weeds because the fewest 

acres would be farmed and GMGT corn and soybeans would not be used. Use of farming on 

Refuge System lands must be determined to be required to accomplish the establishing purpose 

of the refuge or district where it is used. Use also requires specific concurrence through the 

Midwest Region Refuge Chief.

4.2.4.2 Wildlife Issues
48

Issue 1: Use of GMGT crops could provide an alternative for farming with less risk to wildlife.

Growing GMGT corn and soybeans has some conservation advantages over growing non-GM 

hybrids. The use of glyphosate-tolerant crops increases the chances that conservation tillage can 

be successfully used (Towery and Werblow 2010). Conservation tillage results in reduced soil 

disturbance and increased crop residue which decrease soil erosion. Reduced soil erosion results 

in more productive land and cleaner water. Glyphosate is also relatively environmentally benign, 

especially when compared to most other herbicides (Duke and Powles 2008). Field and 

laboratory studies show it does not leach appreciably, has low potential for runoff (Shipitalo et 

al. 2006), is non-toxic to honeybees, practically nontoxic to fish, may be slightly toxic to aquatic 

invertebrates, is slightly toxic to wild birds, and has no significant potential to accumulate in 

animal tissue (http://extoxnet.orst.edu/pips/glyphosa.htm). 

Commercial formulations of glyphosate often contain additional chemicals (surfactants) that are 

added to increase its effectiveness. Some research indicates that there are commercial 

formulations of glyphosate that can negatively impact amphibians (Dinehart et al. 2010) and 

aquatic communities in general (Relyea 2005, Vera et al. 2010) and it is likely these additional 

chemicals are the cause of the toxicity (Mann et al. 2009). These impacts can be minimized by 

applying glyphosate following label instructions like “Do not apply directly to water” or “to 

areas where surface water is present.” Because there is a wide range of toxicity exhibited by 

different formulations of glyphosate (Langeland 2006), these impacts can also be managed by 

using less toxic formulations.

Under this alternative, farming on Refuge System lands would continue up to 3 years on newly 

purchased land that was farmed prior to purchase. On the land that is farmed, there would likely 

be a reduction in conservation tillage (Towery and Werblow 2010), however there would be less 

farming overall. Under Alternative A, 10,000 acres would still be farmed at the end of 15 years. 

This could result in increases in soil disturbance and reductions in crop residue, which tend to 

increase soil erosion. Soil erosion results in less productive land and cleaner water. 

Issue 2: Agricultural herbicides may be toxic to wildlife. 

Under this alternative, farming on Refuge System lands would occur only for up to 3 years on 

newly purchased land that was farmed prior to purchase. The basic effects are the same as 

Alternative A.

There is wide variation in toxicity of herbicides and some have been banned by the US EPA 

(http://wsprod.colostate.edu/cwis79/Factsheets/Sheets/141BannedPesticides.pdf). 

The Service has implemented a Pesticide Use Proposal program 

(http://www.fws.gov/contaminants/pdf/PUP.pdf or 

http://www.fws.gov/contaminants/Documents/7RM14.pdf) that requires approval before 

application of a pesticide on Service land. In the Midwest Region, Refuge System unit managers 

have a limited list of herbicides that they can approve for use. Herbicides not on the list require 

approval at the regional or nation level. 
49

Using herbicides will not impact wildlife:

1. Herbicides are applied following label instructions. These instructions include information 

regarding the use of a particular herbicide around water, near sensitive habitats, and near 

threatened and endangered species 

(http://www.cdms.net/LabelsMsds/LMDefault.aspx?pd=6935&t=1,2,3,4).

2. Conditions outlined in the Service’s cooperative farming agreement are followed. Many of 

these conditions relate to best management practices designs to protect soil and water, and to 

manage pest and nutrients 

(http://www.epa.gov/owow/watershed/wacademy/acad2000/agmodule/).

3. Pesticide Use Proposals are completed, as required by Service policy. Pesticide Use Proposals 

are required before the application of pesticides on Service lands. Impacts to threatened or 

endangered species are considered during this annual review. 

(http://www.fws.gov/contaminants/pdf/PUP.pdf or 

http://www.fws.gov/contaminants/Documents/7RM14.pdf)

Issue 3: Refuge System units need to provide high-energy food for migrating and resident 

wildlife.

Natural resource managers have long used cultivated crops as a method of supplementing natural 

foods available for wildlife. The focus was traditionally on migrating and wintering game 

species, but there is recognition that this source of food can be valuable for nongame species too 

(Donalty et al. 2003). Many wildlife species have adapted to the loss of natural food sources by 

feeding on cultivated grains (Foster et al. 2010). However, more efficient harvesting equipment 

and more farm land planted in soybeans has resulted in a reduction in the amount waste grain 

available for wildlife (Krapu et al. 2004). Large-scale plans to conserve waterfowl populations 

consider the availability of cultivated grains when determining if enough food exists to support 

desired population levels (U.S. Department of the Interior and Environment Canada 1986). 

Cultivated grains are often used in waterfowl management because agricultural seeds tend to 

have greater energy than many natural seeds (Kaminski et al. 2003) and agricultural crops have 

higher yield per unit area than natural wetland plants (Kross et al. 2008). Some waterfowl 

biologists recommend providing unharvested grain fields and natural wetlands for migrating and 

wintering waterfowl because seed resources are low in harvested agricultural fields (Foster et al. 

2010). 

Many Refuge System units were established with the purpose to support population of waterfowl 

or migratory birds. Providing food for large populations of waterfowl is often accomplished by 

managing natural wetlands, moist soil impoundments, and cultivated grains. This alternative 

would provide supplemental foods to migrating and wintering wildlife only during the time land 

was being prepared for restoration to natural habitat. Currently, about 5,000 acres of Refuge 

System lands are farmed to provide food for wildlife. Under this alternative, most these acres 

would be abandoned to natural succession or restored to natural habitat within the next 5 years. 

Some refuges and districts may find it difficult to meet their establishing purposes without the 

ability to provide supplemental food for migratory birds.
50

Issue 4: Refuge System units need to provide concentrated food sources to attract wildlife for 

wildlife-dependent recreation.

Although used minimally, natural resource managers have long grown food plots (cultivated 

stands of corn, milo, sunflowers, millet, etc.) as a method to attract wildlife for increased viewing 

opportunities for the public. This has also been an historic activity on Refuge System lands that 

is used to encourage wildlife observation, wildlife photography, environmental education, and 

environmental interpretation. The National Wildlife Refuge System Improvement Act (1997) 

directs that compatible wildlife-dependent recreational uses including wildlife observation and 

photography, and environmental education and interpretation receive enhanced consideration in 

planning and management over all other general public uses of the Refuge System. When 

compatible, these wildlife-dependent recreational uses are to be strongly encouraged. 

Under this alternative, Refuge System lands farmed to attract wildlife for wildlife-related 

recreational purposes would be abandoned to natural succession or restored to natural habitat 

within the next 5 years.

Issue 5: Farming negatively impacts wildlife.

While some species in the Midwest have readily adapted to the large scale conversion of native 

habitats to cultivated farmland, many wildlife species have been negatively impacted by farming. 

Farming has a great impact on biodiversity and impacts ecosystems by replacing natural habitats 

with vegetation that is nearly monotypic, globally removes about 30 percent of primary 

production for human use, uses and adds water and fertilizers on a scale that influences 

ecosystem functioning, and adds pesticides that directly affect plants and animals (Firbank et al. 

2008, Tilman et al. 2001). 

The Service has long recognized the importance of natural habitat to wildlife. Approximately 

half of the Refuge System lands in the Midwest were being farmed before they became part of 

the Refuge System. Currently, only 1.6 percent of Refuge System lands are farmed. About 80 

percent of farmed Refuge System lands would be abandoned to natural succession or restored to 

natural habitats over the next 5 years. Newly acquired land could be farmed for up to 3 years in 

order to prepare it for restoration to natural habitat. 

4.2.4.3 Habitat Issues

Issue 6: Farming and GMCs can make habitat restoration and management more efficient and 

economical. Increased cost to the Refuges for restoration and maintenance of habitats could 

make it more difficult to support diverse natural habitats. 

Restoration of natural habitats is a Service priority: 

Where feasible and consistent with refuge purpose(s), we restore degraded or modified habitats 

in the pursuit of biological integrity, diversity, and environmental health. (Improvement Act)
51

In the Midwest Region, this usually means converting farmland to prairie, forest or wetland. As 

mentioned in Chapter 2, farm fields that are left to grow unmanaged would end up with 

vegetation that did not meet the purposes of Refuge System lands. The typical restoration 

technique includes the continuation of farming and herbicide use until just before restoration 

planting occurs. Continued farming and herbicide use minimizes the number of residual weeds 

and weed seeds that will compete with the native vegetation to be planted. The use of herbicideresistant, genetically modified crops results in timely and cost-effective restoration of habitat as 

the associated seed and herbicides are readily available (Brookes 2010, Helzer 2010). Excess 

vegetation can also make it difficult or impossible to operate the equipment used to plant native 

vegetation. Lastly, using farming to maintain sites in good condition for restoration makes 

restoration more economically feasible.

Currently, 50 percent of farmed Refuge System lands are scheduled to be restored to natural 

habitats over the next 15 years. Under Alternative D, farming would cease on about 80 percent of 

currently farmed Refuge System lands within 5 years. Forty to 60 percent of these lands would 

be left to unmanaged succession. Newly acquired land could be farmed for up to 3 years in order

to prepare it for restoration to natural habitat. 

Because they are now the dominant hybrid of corn and soybeans planted in the Midwest, it 

would be most cost effective to provide prepare farm land for conversion to native habitats using 

GMGT corn and soybeans. 

Issue 7: Farming is an effective way to control invasive plants and invasion of woody species.

This alternative has the greatest limitations on the use of growing row crops on Refuge System 

lands. In terms of restoring land to natural habitat, Alternative D is less efficient and less costeffective than other alternatives. A significant portion of Refuge System lands have large 

infestations of exotic, invasive plants, lack diverse natural vegetation, or are otherwise in 

degraded condition. Farming provides a method to remove existing, undesirable vegetation and 

prepare land for restoration to diverse, natural vegetation communities. 

Invasive species of plants and animals are a growing problem on a global, national, and regional 

scale (Pimentel et al. 2005). Invasive species are a threat to agricultural and native habitats 

(http://www.fws.gov/invasives/). The Service often continues farming land until just before 

restoration in order to discourage invasive plants. 

In many situations, row crop farming is the most effective and cost-efficient method available for 

converting invasive plant-infested habitat into diverse natural habitats. Because they are now the 

dominant hybrids of corn and soybeans planted in the Midwest, it would be most cost effective

to prevent invasive plants from becoming established in areas that will be restored to native 

habitat by using GMGT corn and soybeans. 

Issue 8: The Service should use conservation tillage practices to minimize soil erosion on 

cultivated lands.
52

Conservation tillage results in reduced soil disturbance and increased crop residue which 

decrease soil erosion. Reduced soil erosion results in more productive land and cleaner water. 

Glyphosate-tolerance increases the chances that conservation tillage can be successfully used 

(Towery and Werblow 2010).

About 80 percent of farmed Refuge System lands will be abandoned to natural succession or 

restored to natural habitats over the next 5 years. Newly acquired land could be farmed for up to 

3 years in order to prepare it for restoration to natural habitat. 

Issue 9: Concern exists for developing herbicide resistance in weeds by using GMCs.

Under this alternative, after 5 years farming would stop on Refuge System lands with the 

exception of newly purchased land, which could be farmed for two 3 years. GMGT corn and 

soybeans would not be used. The likelihood of developing weed resistance on Refuge System 

lands would be minimal.

4.2.4.4 Socio-economic Issues

Issue 10: Non-genetically modified seeds are becoming less available in local communities.

GM herbicide-tolerant crops were planted on 92 percent of the U.S. soybean acres and 80 

percent of the corn acres in 2008 (Brookes 2010). Under Alternative D, GMGT corn and 

soybeans would not be used. The availability of non-genetically modified seed can be limited in 

some areas of the Midwest Region. Availability is likely to decrease over time as it appears that 

GM crops will continue to dominate the seed market. As in Alternative C, cooperating farmers 

are likely to have increasing difficulties finding corn and soybean seeds that are not genetically 

modified.

Issue 11: Not being able to use GMCs could make farming less profitable for cooperators. Local 

farming cooperators will lose income if farming is reduced or eliminated. 

Under Alternative D, local farming cooperators will lose farming opportunities as 80 percent of 

Refuge System row crop lands are restored to natural habitats in the next 15 years. Currently, 

farming with non-GM crops results in higher annual pesticide costs to farmers and farm income 

is reduced due to higher production costs (Brookes 2010). The profitability of farming on Refuge 

System lands is likely to decline, and some farmers may choose to not farm on Refuge System 

lands. 

Issue 12: Changing farming on Refuge System lands will impact the economy.

In this alternative, 80 percent of farmed Refuge System lands would be abandoned to natural 

succession or restored to natural habitats over the next 5 years. Because GMGT corn and 

soybeans would not be used under this alternative, the profitability of farming on Refuge System 

lands is likely to decline, and some farmers may choose to not farm on Refuge System lands. 

Because of the small size of the farming operations on Refuge System lands relative to the size 
53

of the Midwest Region’s farming economy, the economic effect of reducing long-term farming 

would be negligible. 

Issue 13: Use of GMGT corn and soybeans on Refuge System lands could impact neighboring 

organic farmers due to inadvertent gene flow from GM to organic crops. 

Under Alternative D, there would be no effect on organic farming operations because GMGT 

corn and soybeans would not be used on Refuge System lands. 

4.2.5 Alternative E: Continue Farming for Multiple Objectives, GMGT Corn and Soybeans 

Allowed for Habitat Restoration Only (Selected Alternative)

4.2.5.1 Summary of Alternative E Effects

Under Alternative E, the use of GMGT corn and soybeans on Refuge System lands in the 

Midwest Region would continue only for habitat restoration purposes. Currently, about 50 

percent of farmed Refuge System lands are scheduled to be restored to natural habitats over the 

next 15 years. Under Alternative E, the Service would adhere to the present schedule for 

restoring farmland to native habitat. Future newly purchased lands could also be farmed for up to 

five years until being restored to native habitat. 

Beyond 15 years, it is expected that significant decreases will continue in row crop acreage as 

Refuge and District comprehensive conservation plans (CCPs) are revised. The amount and 

extent of this decrease will be determined as these CCPs are updated. 

Alternative E has wildlife advantages because it accommodates conservation tillage, and it is an 

efficient, cost-effective method for preparing land for conversion to natural habitats. 

Alternative E would allow the continued use of farming as a tool to achieve multiple objectives, 

but GMGT crops would not be allowed for objectives other than habitat restoration. This portion 

of Alternate E would lack some wildlife advantages because: conservation tillage is less likely to 

be used, and it is a less efficient and cost-effective method of producing supplemental food for 

wildlife and growing food to attract wildlife for viewing, photography, and other wildlifedependent recreation. Alternative E would have no effect on the overall Midwest farm economy, 

but cooperative farmers would be negatively affected because seed would be less available and 

farming operations may be more expensive effecting profitability. Effects of herbicide toxicity 

would be unchanged from Alternative A because the Service restricts the types and application 

of herbicides used on Refuge System lands. Alternative E would have a lower threat of 

developing herbicide (glyphosate) resistance in weeds than Alternative A, because of a five year 

limit on the use of GMGT crops for habitat restoration and the elimination of GMGT crops for 

other uses. 

4.2.5.2 Wildlife Issues
54

Issue 1: Use of GMGT crops could provide an alternative for farming with less risk to wildlife.

Under this alternative GMGT corn and soybeans would be used for habitat restoration only. The 

effects under this portion of the alternative are similar to the effects under Alternative A. For 

objectives other than habitat restoration, GMGT corn and soybeans would not be allowed. This 

portion of the alternative would be similar to Alternative C

Growing GMGT corn and soybeans has some conservation advantages over growing non-GM 

hybrids. The use of glyphosate-tolerant crops increases the chances that conservation tillage can 

be successfully used (Towery and Werblow 2010). Conservation tillage results in reduced soil 

disturbance and increased crop residue which decrease soil erosion. Reduced soil erosion results 

in more productive land and cleaner water. Glyphosate is also relatively environmentally benign, 

especially when compared to most other herbicides (Duke and Powles 2008). Field and 

laboratory studies show it does not leach appreciably, has low potential for runoff (Shipitalo et 

al. 2006), is nontoxic to honeybees, practically nontoxic to fish, may be slightly toxic to aquatic 

invertebrates, is slightly toxic to wild birds, and has no significant potential to accumulate in 

animal tissue (http://extoxnet.orst.edu/pips/glyphosa.htm). 

Commercial formulations of glyphosate often contain additional chemicals (surfactants) that are 

added to increase its effectiveness. Some research indicates that there are commercial 

formulations of glyphosate that can negatively impact amphibians (Dinehart et al. 2010) and 

aquatic communities in general (Relyea 2005, Vera et al. 2010) and it is likely it is these 

additional chemicals that cause the toxicity (Mann et al. 2009). These impacts can be minimized 

by applying glyphosate following label instructions like “Do not apply directly to water” or “to 

areas where surface water is present.” Because there is a wide range of toxicity exhibited by 

different formulations of glyphosate (Langeland 2006), these impacts can also be managed by 

using less toxic formulations.

Use of GMGT corn and soybeans does offer some conservation advantages over non-GM 

hybrids, but there are also some potential risks involved to aquatic species when some 

commercial formulations of glyphosate are applied too closely to water. These risks can be 

minimized by following glyphosate label instructions and using commercial formulations that 

are known to have lower toxicity.

Issue 2: Agricultural herbicides may be toxic to wildlife.

The effects under this alternative are the same as the effects under Alternative A because the 

Service restricts the herbicides and types of herbicide applications used on Refuge System lands.

There is wide variation in toxicity of herbicides and some have been banned by the U.S. EPA 

(http://wsprod.colostate.edu/cwis79/Factsheets/Sheets/141BannedPesticides.pdf). 

The Service has implemented a Pesticide Use Proposal program 

(http://www.fws.gov/contaminants/pdf/PUP.pdf or 

http://www.fws.gov/contaminants/Documents/7RM14.pdf) that requires approval before 

application of a pesticide on Service land. In the Midwest Region, Refuge System unit managers 
55

have a limited list of herbicides that they can approve for use. Herbicides not on the list require 

approval at the regional or nation level. 

Using herbicides will not impact wildlife if:

1. Herbicides are applied following label instructions. These instructions include information 

regarding the use of a particular herbicide around water, near sensitive habitats, and near 

threatened and endangered species 

(http://www.cdms.net/LabelsMsds/LMDefault.aspx?pd=6935&t=1,2,3,4).

2. Conditions outlined in the Service’s cooperative farming agreement are followed. Many of 

these conditions relate to best management practices designs to protect soil and water, and to 

manage pest and nutrients 

(http://www.epa.gov/owow/watershed/wacademy/acad2000/agmodule/).

3. Pesticide Use Proposals are completed, as required by Service policy. Pesticide Use Proposals 

are required before the application of pesticides on Service lands. Impacts to threatened or 

endangered species are considered during this annual review. 

(http://www.fws.gov/contaminants/pdf/PUP.pdf or 

http://www.fws.gov/contaminants/Documents/7RM14.pdf)

Issue 3: Refuge System units need to provide high-energy food for migrating and resident 

wildlife.

Natural resource managers have long used cultivated crops as a method of supplementing natural 

foods available for wildlife. The focus was traditionally on migrating and wintering game 

species, but there is recognition that this source of food can be valuable for nongame species too 

(Donalty et al. 2003). Many wildlife species have adapted to the loss of natural food sources by 

feeding on cultivated grains (Foster et al. 2010). However, more efficient harvesting equipment 

and more farm land planted in soybeans has resulted in a reduction in the amount of waste grain 

available for wildlife (Krapu et al. 2004). Large-scale plans to conserve waterfowl populations 

consider the availability of cultivated grains when determining if enough food exists to support 

desired population levels (U.S. Department of the Interior and Environment Canada 1986). 

Cultivated grains are often used in waterfowl management because agricultural seeds tend to 

have greater energy than many natural seeds (Kaminski et al. 2003) and agricultural crops have 

higher yield per unit area than natural wetland plants (Kross et al. 2008). Some waterfowl 

biologists recommend providing unharvested grain fields and natural wetlands for migrating and 

wintering waterfowl because seed resources are low in harvested agricultural fields (Foster et al. 

2010). 

Many Refuge System units were established to support populations of waterfowl or migratory 

birds. Providing food for large populations of waterfowl is often accomplished by managing 

natural wetlands, moist soil impoundments, and cultivated grains. Currently, about 5,000 acres of 

Refuge System lands are farmed to provide food for wildlife. This practice would continue under 

this alternative, but it would be more costly and less productive. Because GMGT corn has 
56

become so dominant in the Midwest, it may become difficult to find farmers with interest in 

farming on Refuge System lands.

Issue 4: Refuge System units need to provide concentrated food sources to attract wildlife for 

wildlife-dependent recreation.

The effects under this alternative are the same as the effects under Alternative C.

Although used minimally, natural resource managers have long grown food plots (cultivated 

stands of corn, milo, sunflowers, millet, etc.) as a method to attract wildlife for increased viewing 

opportunities for the public. This has also been a historic activity on Refuge System lands that is 

used to encourage wildlife observation, wildlife photography, environmental education, and 

environmental interpretation. The National Wildlife Refuge System Improvement Act (1997) 

directs that compatible wildlife-dependent recreational uses including wildlife observation and 

photography, and environmental education and interpretation receive enhanced consideration in 

planning and management over all other general public uses of the Refuge System. When 

compatible, these wildlife-dependent recreational uses are to be strongly encouraged.

Growing crops to attract wildlife for wildlife-dependent recreation would continue under this 

alternative, but it would be more costly and less productive. Because GMGT corn has become so 

dominant in the Midwest, it may become difficult to find farmers with interest in farming on 

Refuge System lands.

Issue 5: Farming negatively impacts wildlife.

The effects under this alternative are the same as the effects under Alternative A.

While some species in the Midwest have readily adapted to the large scale conversion of native 

habitats to cultivated farmland, many wildlife species have been negatively impacted by farming. 

Farming has a great impact on biodiversity and impacts ecosystems by replacing natural habitats 

with vegetation that is nearly monotypic, globally removes about 30 percent of primary 

production for human use, uses and adds water and fertilizers on a scale that influences 

ecosystem functioning, and adds pesticides that directly affect plants and animals (Firbank et al. 

2008, Tilman et al. 2001). 

The Service has long recognized the importance of natural habitat to wildlife. Approximately 

half of the Refuge System lands in the Midwest were being farmed before they became part of 

the Refuge System. Currently, only 1.6 percent of Refuge System lands are farmed. Currently, 

about 50 percent of farmed Refuge System lands are scheduled to be restored to natural habitats 

over the next 15 years. Under Alternative C, the Service would adhere to the present schedule for 

restoring farmland to native habitat. Future newly purchased lands could also be farmed until 

being restored to native habitat.

Beyond 15 years, it is expected that significant decreases will continue in row crop acreage as 

Refuge and District CCPs are revised. The amount and extent of this decrease will be determined 

as these CCPs are updated.
57

4.2.5.3 Habitat Issues

Issue 6: There is a need to restore and maintain more native habitats in an efficient manner. 

Farming and GMCs can make habitat restoration and management more efficient and 

economical. Increased cost to the Refuges for restoration and maintenance of habitats could 

make it more difficult to support diverse natural habitats. 

The effects under this alternative are the same as the effects under Alternative A.

Restoration of natural habitats is a Service priority: 

Where feasible and consistent with refuge purpose(s), we restore degraded or modified habitats 

in the pursuit of biological integrity, diversity, and environmental health. (Improvement Act)

In the Midwest Region, this usually means converting farmland to prairie, forest or wetland. As 

mentioned in Chapter 2, farm fields that are left to grow unmanaged would end up with 

vegetation that does not meet the purposes of Refuge System lands. The typical restoration 

technique includes the continuation of farming and herbicide use until just before restoration 

planting occurs. Continued farming and herbicide use minimizes the number of residual weeds 

and weed seeds that will compete with the native vegetation to be planted. The use of herbicideresistant genetically modified crops results in timely and cost-effective restoration of habitat as 

the associated seed and herbicides are readily available (Brookes 2010, Helzer 2010). Excess 

vegetation can also make it difficult or impossible to operate the equipment used to plant native 

vegetation. Lastly, using farming to maintain sites in good condition for restoration makes 

restoration more economically feasible. 

Because they are now the dominant type of corn and soybeans planted in the Midwest Region, it 

will be most cost effective to prepare farm land for conversion to native habitats using GMGT 

corn and soybeans.

Issue 7: Farming is an effective way to control invasive plants and invasion of woody species.

The effects under this alternative are the same as the effects under Alternative A.

Invasive species of plants and animals are a growing problem on a global, national, and regional 

scale (Pimentel et al. 2005). Invasive species are a threat to agricultural and native habitats 

(http://www.fws.gov/invasives/). The Service often continues farming land until just before 

restoration in order to discourage invasive plants. 

Because GMGT is now the dominant hybrid of corn and soybeans planted in the Midwest 

Region, it will be most cost effective to prevent invasive plants from becoming established in 

areas that will be restored to native habitat by using GMGT corn and soybeans.
58

Issue 8: The Service should use conservation tillage practices to minimize soil erosion on 

cultivated lands.

The effects under this alternative are the same as the effects under Alternative A for the habitat 

restoration portion of this alternative. The effect of this alternative concerning farming for other 

objectives is the same as Alternative C.

Conservation tillage results in reduced soil disturbance and increased crop residue which 

decrease soil erosion. Reduced soil erosion results in more productive land and cleaner water. 

Glyphosate-tolerance increases the chances that conservation tillage can be successfully used 

(Towery and Werblow 2010).

Issue 9: Concern exists for developing herbicide resistance in weeds by using GMCs.

Under Alternative E, GMGT corn and soybeans would be used for habitat restoration only for a 

maximum of five years on individual sites. Also, GMGT crops will not be allowed for other 

refuge objectives that involve farming operations. These restrictions, along with the use of 

integrated pest management techniques should assist in reducing the possible development of 

herbicide resistant plants on Refuge System lands in the Midwest Region.

4.2.5.4 Socio-economic Issues

Issue 10: Non-genetically modified seeds are becoming less available in local communities. 

GM herbicide-tolerant crops were planted on 92 percent of the U.S. soybean acres and 80 

percent of the corn acres in 2008 (Brookes 2010). Alternative E would allow the use of GMGT 

crops for habitat restoration. This portion of Alternate E would have no effect on seed 

availability since both GM and non-GM seed could still be used in Refuge System habitat 

restoration farming operations. However, Alternative E does not allow the use of GMGT crops

for objectives other than habitat restoration. The availability of non-genetically modified seed 

can be limited in some areas of the Midwest Region. Availability is likely to decrease over time 

as it appears that GM crops will continue to dominate the seed market. Under this portion of 

Alternative E, cooperating farmers are likely to have increasing difficulties finding corn and 

soybean seeds that are not genetically modified.

Issue 11: Not being able to use GMCs could make farming more costly for cooperators. Local 

farming cooperators will lose income if farming is reduced or eliminated. 

Farmers could continue to use GMGT corn and soybeans under Alternative E only for habitat 

restoration. Under Alternative E, local farming cooperators will lose farming opportunities as 50 

percent of Refuge System row crop lands are restored to natural habitats in the next 15 years.

Alternative E does not allow the use of GMGT crops for objectives other than habitat restoration. 

Not being able to use GMCs could make farming less profitable for cooperators. Currently, 

farming with non-GM crops results in higher annual pesticide costs to farmers and farm income 

is reduced due to higher production costs (Brookes 2010). The profitability of farming on Refuge 
59

System lands is likely to decline, and some farmers may choose to not farm on Refuge System 

lands. 

Issue 12: Changing farming on Refuge System lands will impact the economy.

As in all alternatives, about half of farmed Refuge System lands are scheduled to be restored to 

natural habitats over the next 15 years. Because GMGT corn and soybeans are only allowed for 

habitat restoration under this alternative, the profitability of farming on Refuge System lands is 

likely to decline, and some farmers may choose to not farm on Refuge System lands. Because of 

the small size of the farming operations on Refuge System lands relative to the size of the 

Midwest farming economy, the economic effect of gradually eliminating long-term farming 

would be negligible.

Issue 13: Use of GMGT corn and soybeans on Refuge System lands could impact neighboring 

organic farmers due to inadvertent gene flow from GM to organic crops. 

Under Alternative E, the use of GMGT corn on Refuge System lands may have some potential to 

negatively affect organic farmers who have fields within 660 feet. Typically, organic farmers are 

responsible for providing their own buffers to ensure that they meet organic farming standards. If 

Refuge or District Managers are made aware of adjacent Certified Organic farm acres for corn, 

they may take measures to address neighboring landowner concerns and assist in providing 

required buffers. This concern is reduced under Alternative E, as GMGT crops are restricted to 

habitat restoration objects only.

Table 3: Comparison of Impacts by Issue 

Issue Alternative A: 

Continue 

Farming for 

Multiple 

Objectives, 

GMGT Corn and 

Soybeans Allowed 

(No Action) 

(Preferred 

Alternative)

Alternative B: 

Farming for 

Habitat 

Restoration 

Objectives Only, 

GMGT Corn and 

Soybeans 

Allowed

Alternative C: 

Farming for 

Multiple 

Objectives, No 

GMGT Corn and 

Soybeans 

Alternative D: 

Limited Row 

Crop Farming, 

No GMGT Corn 

and Soybeans 

Alternative E: 

Continue 

Farming for 

Multiple 

Objectives, 

GMGT Corn 

and Soybeans 

Allowed for 

Restoration 

Purposes Only 

Wildlife Issues

Issue 1: GMGT 

crops could 

benefit wildlife

Extensive use of 

conservation 

tillage.

Same as 

Alternative A.

Less conservation 

tillage.

Less conservation 

tillage, many fewer 

acres farmed.

Same as 

Alternative A 

for restoration, 

Same as 

Alternative C

for other 

purposes

Issue 2: Toxicity 

of Herbicides to 

Wildlife

Low. Label 

instructions, PUPs, 

and BMPs.

Same as 

Alternative A.

Same as 

Alternative A.

Same as 

Alternative A.

Same as 

Alternative A

Issue 3: High 

energy waterfowl 

food 

Crops grown for 

waterfowl.

No farming for 

waterfowl.

Less effective, 

more costly 

waterfowl foods 

without GMGT 

corn and soybeans. 

Same as 

Alternative B.

Same as 

Alternative C
60

Table 3: Comparison of Impacts by Issue 

Issue Alternative A: 

Continue 

Farming for 

Multiple 

Objectives, 

GMGT Corn and 

Soybeans Allowed 

(No Action) 

(Preferred 

Alternative)

Alternative B: 

Farming for 

Habitat 

Restoration 

Objectives Only, 

GMGT Corn and 

Soybeans 

Allowed

Alternative C: 

Farming for 

Multiple 

Objectives, No 

GMGT Corn and 

Soybeans 

Alternative D: 

Limited Row 

Crop Farming, 

No GMGT Corn 

and Soybeans 

Alternative E: 

Continue 

Farming for 

Multiple 

Objectives, 

GMGT Corn 

and Soybeans 

Allowed for 

Restoration 

Purposes Only 

Issue 4: Attractant 

for Wildlifedependent 

recreation

Crops grown to 

attract wildlife for 

viewing, etc.

No farming to 

attract wildlife for 

viewing, etc.

Less effective, 

more costly 

without GMGT 

corn and soybeans.

No farming to 

attract wildlife for 

viewing, etc.

Same as 

Alternative C

Issue 5: Row 

crops are poor 

wildlife habitat

50% reduction in 

row crops in 15 

years.

50-80% reduction 

in row crops in 15 

years.

50% reduction in 

row crops in 15 

years.

80% reduction in 

row crops in 5 

years.

50% reduction 

row crops in 15 

years.

Row Crops on 

Refuge System 

Lands

Current Acres 

(2010)

20,000 20,000 20,000 20,000 20,000

2025 10,000 4,000-10,000 10,000 4,000 10,000

Habitat Issues

Issue 6: Farming 

is a Useful 

Habitat 

Restoration Tool

Farming and 

GMGT corn and 

soybeans available 

tool for habitat 

restoration.

Same as 

Alternative A.

Restoration less 

effective, more 

costly without 

GMGT corn and 

soybeans.

More costly. May 

not be feasible to 

meet refuge and 

district purposes.

Same as 

Alternative A

Issue 7: Control 

of invasive plants

Partial control in 

areas scheduled for 

restoration.

Same as 

Alternative A.

Same as 

Alternative A.

Less control in 

areas scheduled for 

restoration.

Same as 

Alternative A

Issue 8: 

Tillage/soil 

erosion

More use of 

conservation 

tillage, less soil 

erosion.

Same as 

Alternative A.

Less use of 

conservation 

tillage, more soil 

erosion.

Less conservation 

tillage, on fewer 

acres.

Same as 

Alternative A 

for restoration, 

Same as 

Alternative C 

for other 

purposes

Issue 9: Herbicide 

resistance

Higher risk with 

much use of 

glyphosate on 

GMGT corn and 

soybeans.

Much use of 

glyphosate on 

GMGT corn and 

soybeans, fewer 

acres farmed.

Lower risk since 

no use of GMGT 

corn and soybeans 

will mean less use 

of glyphosate.

Lowest risk since 

no use of GMGT 

corn and soybeans 

on fewer acres.

Lower risk 

because of five 

year limit on 

restoration and 

no use of 

GMGT crops 

for other 

purposes

Socio-economic 

Issues

Issue 10: Seed 

availability

Readily available 

in all areas.

Same as 

Alternative A.

Limited 

availability of nonGMGT seeds.

Same as 

Alternative C.

Same as 

Alternative A 

for restoration. 

.Same as 

Alternative C 

for other 

objectives

Issue 11: Impacts 

on cooperative 

farmers

GMGT corn and 

soybeans allowed, 

50% reduction in 

row crops in 15 

GMGT corn and 

soybeans allowed, 

50-80% reduction 

in row crops in 15 

GMGT corn and 

soybeans 

prohibited, 50% 

reduction in row 

GMGT corn and 

soybeans 

prohibited, 80% 

reduction in row 

GMGT corn and 

soybeans 

allowed for 

restoration only, 
61

Table 3: Comparison of Impacts by Issue 

Issue Alternative A: 

Continue 

Farming for 

Multiple 

Objectives, 

GMGT Corn and 

Soybeans Allowed 

(No Action) 

(Preferred 

Alternative)

Alternative B: 

Farming for 

Habitat 

Restoration 

Objectives Only, 

GMGT Corn and 

Soybeans 

Allowed

Alternative C: 

Farming for 

Multiple 

Objectives, No 

GMGT Corn and 

Soybeans 

Alternative D: 

Limited Row 

Crop Farming, 

No GMGT Corn 

and Soybeans 

Alternative E: 

Continue 

Farming for 

Multiple 

Objectives, 

GMGT Corn 

and Soybeans 

Allowed for 

Restoration 

Purposes Only 

years. years. crops in 15 years. crops in 5 years. 50% reduction 

in row crops in 

15 years.

Issue 12: Impacts 

on economy 

Activities on 

0.02% of the total 

row crop acreage 

in the Service’s 

eight-state 

Midwest Region 

would have a 

negligible impact 

on the region’s 

economy. 

Same as 

Alternative A.

Same as 

Alternative A.

Same as 

Alternative A.

Same as 

Alternative A.

13. Impacts on 

organic crops 

Localized negative 

impacts are 

possible but 

unlikely; potential 

would be reduced 

as 50% of existing 

acres farmed on 

Refuge System 

land are converted 

to native habitat.

Localized negative 

impacts are 

possible but 

unlikely; potential 

would be reduced 

as 50-80% of 

existing acres 

farmed on Refuge 

System land are 

converted to native 

habitat.

No impacts since 

GMGT corn and 

soybeans will not 

be used.

No impacts since 

GMGT corn and 

soybeans will not 

be used.

Same as 

Alternative A, 

plus GMGT 

crops will only 

be used for 

habitat 

restoration.

4.3 Environmental Justice

Executive Order 12898 “Federal Actions to Address Environmental Justice in Minority 

Populations and Low-Income Populations” was signed by President Clinton on February 11, 

1994. Its purpose was to focus the attention of federal agencies on the environmental and human 

health conditions of minority and low-income populations with the goal of achieving 

environmental protection for all communities. The Order directed federal agencies to develop 

environmental justice strategies to aid in identifying and addressing disproportionately high and 

adverse human health or environmental effects of their programs, policies, and activities on 

minority and low-income populations. The Order is also intended to promote nondiscrimination 

in federal programs substantially affecting human health and the environment, and to provide 

minority and low-income communities access to public information and participation in matters 

relating to human health or the environment.

None of the management alternatives described in this EA would disproportionately place any 

adverse environmental, economic, social, or health impacts on minority and low-income 

populations. 

4.4 Cumulative Impacts Analysis
62

Cumulative effects are effects on the environment that result from the incremental impact of an 

action when added to other past, present, and reasonably foreseeable future actions. Potential 

cumulative effects for the alternatives are described in this section. The discussion considers the 

interaction of activities on Midwest Region Refuge System lands with other actions occurring 

over a larger spatial and temporal frame of reference.

Service policy states:

We do not allow refuge uses or management practices that result in the maintenance of nonnative plant communities unless we determine there is no feasible alternative for accomplishing 

refuge purpose(s). (601 FW 3 Biological Integrity, Diversity, and Environmental Health).

This policy and trends in land management practices indicate that future actions will result in 

more restoration of crop land to natural habitats on Refuge System lands. This trend is unlikely 

to have any significant impacts on a regional (eight-state) scale when Refuge System lands 

currently cover only 0.4 percent of the Midwest Region. If all Midwest refuges and districts 

purchased all the land currently authorized (Chapter 2, Table 2), Refuge System lands would 

cover 0.5 percent of the Midwest Region. Conversion of farm land to natural habitats is likely to 

have only modest impacts on the National Wildlife Refuge System in the Midwest Region, since 

farm land currently makes up only 1.6 percent of Refuge System lands. Restoration to natural 

habitats could have a more significant impact as future land is added to the Refuge System since 

about 40 percent of the land that could be purchased is currently farmed (Table 2 on page 17).

4.4.1 Alternative A: Continue Farming for Multiple Objectives, GMGT Corn and Soybeans 

Allowed (No Action) ( Preferred Alternative) 

4.4.1.1 Wildlife Issues

In general, the cumulative effect of the Midwest Region’s farming program is that there will be 

fewer farmed acres and more restored natural areas. On an eight-state regional scale, most 

wildlife-related issues are unlikely to be effected by Alternative A because:

Refuge System lands currently cover only 0.4 percent of the eight-state region and are 

unlikely to increase to more than 0.5 percent in the foreseeable future.

Row crops cover only 1.6 percent of Refuge System lands and will decrease to 0.8 

percent within the next 15 years.

Given the small percentage of land affected by the farming program on an eight-state regional 

scale, Alternative A is unlikely to have an effect on most wildlife issues. However, providing 

food for waterfowl on Refuge System lands may become more critical as agricultural techniques 

intensify leaving less waste grain available (Krapu et al. 2004). As more of the eight-state region 

is developed, Refuge System lands could become more critical for the protection of threatened 

and endangered species. Alternative A allows the use of row crop farming and GMGT corn and 

soybeans as an effective and cost efficient method of growing supplemental food for wildlife and 

restoring disturbed areas to natural habitats that are more likely to support threatened and 

endangered species.
63

Refuge System lands could continue to provide concentrated food sources to attract wildlife for 

wildlife-dependent recreation such as wildlife observation, wildlife photography, and 

environmental interpretation. Wildlife-dependent recreation has growing economic and social 

values. 

4.4.1.2 Habitat Issues

The loss of natural habitats in the Midwest region continues and some habitats are becoming 

very rare (Noss et al. 1995). Alternative A allows the continued use of row crop farming and 

GMGT corn and soybeans as an effective and cost efficient method of restoring disturbed areas 

to diverse, natural habitats. Because row crops on Refuge System lands are such a small part 

(0.02 percent) of the row crop acreage in the eight-state region (Figure 4 on page 17), it’s 

unlikely that they would contribute significantly to regional/national issues like herbicide 

resistance in weeds and water quality issues related to soil erosion. 

4.4.1.3 Socio-economic Issues

Because row crops on Refuge System lands are such a small part (0.02 percent) of the row crop 

acreage in the eight-state region, it’s unlikely that they would impact the larger economy. 

Compared to the other alternatives, Alternative A has the least short-term impact on cooperative 

farmers. Some cooperative farmers will lose farming opportunities under this alternative as about 

50 percent of Refuge System farm lands are converted to natural habitats over the next 15 years. 

Although U.S. cropland acreages have remained relatively stable over the last 50 years 

(http://www.ers.usda.gov/Briefing/LandUse/urbanchapter.htm), small decreases in future row 

crop acreages are possible in the Midwest Region. The relatively small amount (20,000 acres) of 

Refuge System row crops spread over the eight Midwest Region states provides only a very 

small proportion of the farming opportunities in the Midwest Region, which has 116,000,000 

acres of row crops. Potential impacts on organic farming are unlikely and the likelihood will 

decline as farming acreage will decrease by 50 percent over the next 15 years.

4.4.2 Alternative B: Farming for Habitat Restoration Objectives Only, GMGT Corn and 

Soybeans Allowed

4.4.2.1 Wildlife Issues

The cumulative effect of the Midwest Region’s farming program is that there will be fewer 

farmed acres and more natural areas. On an eight-state regional scale, most wildlife-related 

issues are unlikely to be effected by Alternative B because:

Refuge System lands currently cover only 0.4 percent of the eight-state region and are 

unlikely to increase to more than 0.5 percent in the foreseeable future.

Row crops cover 1.6 percent of Refuge System lands and will decrease to 0.8 percent 

within the next 15 years. 

On an eight-state regional scale, Alternative B is unlikely to have an effect on most wildlife 

issues. However, providing food for waterfowl on Refuge System lands may become more 
64

critical as agricultural techniques intensify leaving less waste grain available. Alternative B 

would not allow growing row crops on Refuge System lands for the purpose of providing 

supplemental food for wildlife. As more of the eight-state region is developed, Refuge System 

lands could become more critical for the protection of threatened and endangered species. 

Alternative B allows the use of row crop farming and GMGT corn and soybeans as an effective 

and cost efficient method of restoring disturbed areas to natural habitats that are more likely to 

support threatened and endangered species.

Under Alternative B, Refuge System lands would not continue to provide concentrated food 

sources to attract wildlife for wildlife-dependent recreation such as wildlife observation, wildlife 

photography, and environmental interpretation. Wildlife-dependent recreation has growing 

economic and social values.

4.4.2.2 Habitat Issues

The loss of natural habitats in the eight-state region continues and some habitats are becoming 

very rare. Alternative B allows the continued use of row crop farming and GMGT corn and 

soybeans as an effective and cost efficient method of restoring disturbed areas to diverse, natural 

habitats. Because row crops on Refuge System lands are such a small part (0.02 percent) of the 

row crop acreage in the eight-state region, it’s unlikely that they would contribute significantly to 

regional/national issues like herbicide resistance in weeds and water quality issues related to soil 

erosion.

4.4.2.3 Socio-economic Issues

Because row crops on Refuge System lands are such a small part (0.02 percent) of the row crop 

acreage in the eight-state region, it’s unlikely that they would impact the larger economy. 

Compared to Alternative A, this alternative has more short-term impacts on cooperative farmers 

because more farm land will be converted to natural habitats. Some cooperative farmers will lose 

farming opportunities under this alternative as 50-80 percent of Refuge System farm lands will 

be converted to natural habitats over the next 15 years. Although U.S. cropland acreages have 

remained relatively stable over the last 50 years 

(http://www.ers.usda.gov/Briefing/LandUse/urbanchapter.htm), small decreases in future row 

crop acreages are possible in the Midwest Region. The relatively small amount (20,000 acres) of 

Refuge System row crops spread over the eight Midwest Region states provides only a very 

small proportion of the farming opportunities in the Midwest Region, which has 116,000,000 

acres of row crops. Potential impacts on organic farming are unlikely and the likelihood will 

decline as farming acreage will decrease by 50-80 percent over the next 15 years.

4.4.3 Alternative C: Farming for Multiple Objectives, No GMGT Corn and Soybeans 

4.4.3.1 Wildlife Issues

The cumulative effect of the Midwest Region’s farming program is that there will be fewer 

farmed acres and more natural areas. On an eight-state regional scale, most wildlife-related 

issues are unlikely to be effected by Alternative C because:
65

Refuge System lands currently cover only 0.4 percent of the eight-state region and are 

unlikely to increase to more than 0.5 percent in the foreseeable future.

Row crops cover only 1.6 percent of Refuge System lands and will decrease to 0.8 

percent within the next 15 years.

On an eight-state regional scale, Alternative C is unlikely to have an effect on most wildlife 

issues. However, providing food for waterfowl on Refuge System lands may become more 

critical as agricultural techniques intensify leaving less waste grain available. As more of the 

eight-state region is developed, Refuge System lands could become more critical for the 

protection of threatened and endangered species. Alternative C allows the use of row crop 

farming as a useful method of growing supplemental food for wildlife and restoring disturbed 

areas to natural habitats that are more likely to support threatened and endangered species. The 

prohibition against the use of GMGT corn and soybeans will cause this method to be less 

effective and cost efficient.

Refuge System lands could continue to provide concentrated food sources to attract wildlife for 

wildlife-dependent recreation such as wildlife observation, wildlife photography, and 

environmental interpretation. Wildlife-dependent recreation has growing economic and social 

values. The prohibition against the use of GMGT corn and soybeans would cause this method to 

be less effective and cost efficient.

4.4.3.2 Habitat Issues

Alternative C allows the use of row crop farming as a useful method of restoring disturbed areas 

to diverse, natural habitats. The prohibition against the use of GMGT corn and soybeans would 

cause this method to be less effective and cost efficient. Because row crops on Refuge System 

lands are such a small part (0.02 percent) of the row crop acreage in the eight-state region, it’s 

unlikely that they would contribute significantly to regional/national issues like herbicide 

resistance in weeds and water quality issues related to soil erosion.

4.4.3.3 Socio-economic Issues

Because row crops on Refuge System lands are such a small part (0.02 percent) of the row crop 

acreage in the eight-state region, it’s unlikely that they would impact the larger economy. Since 

GMGT corn and soybeans would not be allowed under Alternative C, there is no potential for 

inadvertent gene flow from GMGT crops on refuge lands to organic crops. The prohibition 

against the use of GMGT corn and soybeans is likely to negatively impact the profitability of 

farming in Refuge System lands. Genetically modified crops dominate agriculture in the eightstate region and their importance would likely continue to grow. It’s likely that new GM crops 

and other changes in agricultural practices would occur faster than the Service’s ability to assess 

their potential impacts on Refuge System lands. Cooperative farmers would lose farming 

opportunities under this alternative as about 50 percent of Refuge System farm lands are 

converted to natural habitats. Although U.S. cropland acreages have remained relatively stable 

over the last 50 years (http://www.ers.usda.gov/Briefing/LandUse/urbanchapter.htm), small 

decreases in future row crop acreages are possible in the Midwest Region. The relatively small 

amount (20,000 acres) of Refuge System row crops spread over the eight Midwest Region states 
66

provides only a very small proportion of the farming opportunities in the Midwest Region, which 

has 116,000,000 acres of row crops. 

4.4.4 Alternative D: Limited Row Crop Farming, No GMGT Corn and Soybeans

4.4.4.1 Wildlife Issues

The cumulative effect of the Midwest Region’s farming program is that there will be fewer 

farmed acres and more natural areas. On an eight-state regional scale, most wildlife-related 

issues are unlikely to be effected by Alternative D because:

Refuge System lands currently cover only 0.4 percent of the eight-state region and are 

unlikely to increase to more than 0.5 percent in the foreseeable future.

Row crops cover only 1.6 percent of Refuge System lands and will decrease to 0.8 

percent within the next 15 years.

On an eight-state regional scale, Alternative D is unlikely to have an effect on most wildlife 

issues. However, providing food for waterfowl on Refuge System lands may become more 

critical as agricultural techniques intensify leaving less waste grain available. As more of the 

eight-state region is developed, Refuge System lands could become more critical for the 

protection of threatened and endangered species. Row crop farming would be allowed for up to 3 

years on newly purchased lands, and GMGT corn and soybeans would not be allowed. The 

Service would lack this effective and cost efficient method of growing supplemental food for 

wildlife and restoring disturbed areas to natural habitats.

Refuge System lands would not continue to provide concentrated food sources to attract wildlife 

for wildlife-dependent recreation such as wildlife observation, wildlife photography, and 

environmental interpretation. Wildlife-dependent recreation has growing economic and social 

values. 

4.4.4.2 Habitat Issues

Alternative D does not allow the use of row crop farming as a method of restoring disturbed 

areas to diverse, natural habitats. Because row crops on Refuge System lands are such a small 

part (0.02 percent) of the row crop acreage in the eight-state region, it’s unlikely that they would 

contribute significantly to regional/national issues like herbicide resistance in weeds and water 

quality issues related to soil erosion.

4.4.4.3 Socio-economic Issues

Because row crops on Refuge System lands are such a small part (0.02 percent) of the row crop 

acreage in the eight-state region, it’s unlikely that they would impact the larger economy. Since 

GMGT corn and soybeans will not be allowed under Alternative D, there is no potential for 

inadvertent gene flow from GM to organic crops. The prohibition against the use of GMGT corn 

and soybeans is likely to negatively impact the profitability of farming in Refuge System lands. 

Genetically modified crops dominate agriculture in the eight-state region and their importance 
67

will likely continue to grow. It’s likely that new GM crops and other changes in agricultural 

practices will occur faster than the Service’s ability to assess their potential impacts on Refuge 

System lands. Cooperative farmers will lose farming opportunities under this alternative as about 

80 percent of Refuge System farm lands are converted to natural habitats within 5 years. 

Although U.S. cropland acreages have remained relatively stable over the last 50 years 

(http://www.ers.usda.gov/Briefing/LandUse/urbanchapter.htm), small decreases in future row 

crop acreages are possible in the Midwest Region. The relatively small amount (20,000 acres) of 

Refuge System row crops spread over the eight Midwest Region states provides only a very 

small proportion of the farming opportunities in the Midwest Region, which has 116,000,000 

acres of row crops. 

4.4.5 Alternative E: Continue Farming for Multiple Objectives, GMGT Corn and Soybeans 

Allowed for Restoration Purposes Only (Selected Alternative)

4.4.5.1 Wildlife Issues

The cumulative effect of the Midwest Region’s farming program is that there will be fewer 

farmed acres and more natural areas. On an eight-state regional scale, most wildlife-related 

issues are unlikely to be effected by Alternative E because:

• Refuge System lands currently cover only 0.4 percent of the eight-state region and are 

unlikely to increase to more than 0.5 percent in the foreseeable future.

• Row crops cover 1.6 percent of Refuge System lands and will decrease to 0.8 percent 

within the next 15 years. 

As more of the eight-state region is developed, Refuge System lands could become more critical 

for the protection of threatened and endangered species. Alternative E allows the use of row crop 

farming and GMGT corn and soybeans as an effective and cost efficient method of restoring 

disturbed areas to natural habitats that are more likely to support threatened and endangered 

species.

Alternative E allows the use of row crop farming as a useful method of growing supplemental 

food for wildlife, but does not allow the use of GMGT crops for this objective. Prohibiting the 

use of GMGT corn and soybeans may cause this method to be less cost efficient.

Refuge System lands could continue to provide concentrated food sources to attract wildlife for 

wildlife-dependent recreation such as wildlife observation, wildlife photography, and 

environmental interpretation. Wildlife-dependent recreation has growing economic and social 

values. The prohibition against the use of GMGT corn and soybeans may cause this method to be 

less cost efficient.
68

4.4.5.2 Habitat Issues

The loss of natural habitats in the eight-state region continues and some habitats are becoming 

very rare. Alternative E allows the continued use of row crop farming and GMGT corn and 

soybeans as an effective and cost efficient method of restoring disturbed areas to diverse, natural 

habitats. Because row crops on Refuge System lands are such a small part (0.02 percent) of the 

row crop acreage in the eight-state region, it’s unlikely that they would contribute significantly to 

regional/national issues like herbicide resistance in weeds and water quality issues related to soil 

erosion.

4.4.5.3 Socio-economic Issues

Compared to Alternative A, this alternative has more short-term impacts on cooperative farmers 

because the use of GMGT corn and soybeans will be restricted to habitat restoration objectives 

only. Because row crops on Refuge System lands are such a small part (0.02 percent) of the row 

crop acreage in the eight-state region, it’s unlikely that they would impact the larger economy. 

Some cooperative farmers will lose farming opportunities under this alternative as about 50 

percent of Refuge System farm lands are converted to natural habitats over the next 15 years. 

Although U.S. cropland acreages have remained relatively stable over the last 50 years 

(http://www.ers.usda.gov/Briefing/LandUse/urbanchapter.htm), small decreases in future row 

crop acreages are possible in the Midwest Region. The relatively small amount (20,000 acres) of 

Refuge System row crops spread over the eight Midwest Region states provides only a very 

small proportion of the farming opportunities in the Midwest Region, which has 116,000,000 

acres of row crops. Potential impacts on organic farming are unlikely and the likelihood will 

decline as farming acreage will decrease by 50 percent over the next 15 years.
69

Chapter 5: Consultation and Coordination

5.1 Planning Team and Contributors

The Planning Team is made up of representatives from both the Midwest Region (R3) and 

Region 6. Team members are Kevin Brennan and Doug Wells from Fergus Falls Wetland 

Management District, Mike Brown, Refuge Manager at Cypress Creek NWR, Mike Artmann 

from Region 6 Regional Office, and Tom Koerner from Sand Lake National Wildlife Refuge 

Complex. 

Sandra Siekaniec, formerly Assistant Refuge Supervisior in the Midwest Region, was the 

Regional Office representative until October 2010. Richard Speer, current Assistant Refuge 

Supervisior in the Midwest Region completed the document.

All members of the Planning Team contributed to the development of this EA. Activities 

included public scoping, reviewing comments, researching and reading literature, interviewing 

Refuge Managers, producing maps, and writing and editing the EA. 

Other individuals also contributed to the Draft Environmental Assessment:

Tom Larson, Chief of the Division of Conservation Planning in the Midwest Region

Jane Hodgins, Former Technical Writer/Editor with the Division of Conservation 

Planning

Dean Granholm, Wildlife Biologist/Planner, Division of Conservation Planning

Gary Muehlenhardt, Wildlife Biologist/Planner, Division of Conservation Planning

Gabriel DeAlessio, GIS Specialist/Biologist with the Division of Conservation Planning

Sean Killen, Cartographer with the Division of Realty, National Wildlife Refuge System, 

in the Midwest Region

5.2 Agencies Consulted

USDA/APHIS’s Biotechnology Regulatory Services

EPA’s Biopesticides and Pollution Prevention Division

FDA’s Center for Food Safety and Applied Nutrition

Office of Science and Technology Policy

5.3 Public Comments on Draft Environmental Assessment

The draft EA was released for a public comment period from January 10, 2011 through February 

14, 2011. After completion of the comment period, all new information and comments were 

reviewed before writing and adopting a final signed EA. Responses to comments may be found 

in Appendix F.
70

Appendix A: Midwest Region Farming Information

Refuge or 

Wetland 

Management 

District

State Total Refuge 

or District 

Acres

2005 

RAPPCrop 

Management 

Acres

2010 RAPP 

Crop 

Management 

Acres

Change in 

Crop 

Management 

Acres (2010 

- 2005)

Agassiz 

NWR

MN 61,500 155 155 0

Big Muddy 

NWR

MO 16,139 1,190 600 -590

Big Oaks 

NWR

IN 50,900 0 0 0

Big Stone 

NWR

MN 11,586 532 295 -237

Big Stone 

WMD

MN 4,986 204 15 -189

Boyer Chute 

NWR

NE 429 18 0 -18

Cedar Point 

NWR

OH 2,598 0 0 0

Chautauqua 

NWR

IL 6,198 0 0 0

Clarence 

Cannon 

NWR

MO 3,750 562 700 138

Crab Orchard 

NWR

IL 45,456 4,704 4,704 0

Crane 

Meadows 

NWR

MN 1,761 30 0 -30

Cypress 

Creek NWR

IL 16,250 1,767 1,567 -200

DeSoto NWR IA 8,355 1,495 1,010 -485

Detroit Lakes 

WMD

MN 58,004 2,263 776 -1,487

Detroit River 

International 

Wildlife 

Refuge

MI 5,657 70 290 220

Driftless Area 

NWR

IA 911 49 50 1

Emiquon 

NWR

IL 2,514 62 317 255
71

Refuge or 

Wetland 

Management 

District

State Total Refuge 

or District 

Acres

2005 

RAPPCrop 

Management 

Acres

2010 RAPP 

Crop 

Management 

Acres

Change in 

Crop 

Management 

Acres (2010 

- 2005)

Fergus Falls 

WMD

MN 72,187 115 400 285

Fox River 

NWR

WI 1,054 0 0 0

Glacial Ridge 

NWR

MN 7,337 0 0 0

Gravel Island 

NWR

WI 35 0 0 0

Great River 

NWR

MO 12,330 947 423 -524

Green Bay 

NWR

WI 336 0 0 0

Hamden 

Slough NWR

MN 3,210 246 218 -28

Harbor Island 

NWR

MI 695 0 0 0

Horicon 

NWR

WI 22,000 0 0 0

Huron NWR MI 147 0 0 0

Iowa WMD IA 24,327 3,797 3,451 -346

Kirtlands 

Warbler 

WMA

MI 6,684 0 0 0

LaCrosse 

District 

UMNWFR

WI 47,557 0 117 117

Leopold 

WMD

WI 12,790 318 188 -130

Litchfield 

WMD

MN 49,061 0 0 0

McGregor 

District 

UMNWFR

IA 91,772 296 0 -296

Meredosia 

NWR

IL 3,582 135 0 -135

Michigan 

WMD

MI 535 0 0 0

Michigan 

Islands NWR

MI 619 0 0 0

Middle 

Mississippi 

IL, MO 8,348 0 0 0
72

Refuge or 

Wetland 

Management 

District

State Total Refuge 

or District 

Acres

2005 

RAPPCrop 

Management 

Acres

2010 RAPP 

Crop 

Management 

Acres

Change in 

Crop 

Management 

Acres (2010 

- 2005)

River NWR

Mille Lacs 

NWR

MN 1 0 0 0

Mingo NWR MO 21,519 624 315 -309

MN Valley 

NWR

MN 12,500 0 0 0

MN Valley 

WMD

MN 6,319 0 0 0

Morris WMD MN 80,715 1,128 346 -782

Muscatatuck 

NWR

IN 7,802 344 258 -86

Neal Smith 

NWR

IA 5,383 0 0 0

Necedah 

NWR

WI 43,696 0 0 0

Northern 

Tallgrass 

Prairie NWR

IA, MN 4,897 59 431 372

Ottawa NWR OH 6,546 442 210 -232

Ozark 

Cavefish 

NWR

MO 42 0 0 0

Patoka River 

NWR

IN 7,121 739 615 -124

Pilot Knob 

NWR

MO 90 0 0 0

Port Louisa 

NWR

IA 15,297 80 45 -35

Rice Lake 

NWR

MN 20,194 0 0 0

Rydell NWR MN 2,174 0 0 0

Savanna 

District 

UMNWFR

IA 64,393 0 0 0

Seney NWR MI 96,524 0 0 0

Sherburne 

NWR

MN 30,700 0 0 0

Shiawassee 

NWR

MI 9,437 1,270 1,146 -124

Squaw Creek 

NWR

MO 6,517 502 354 -148
73

Refuge or 

Wetland 

Management 

District

State Total Refuge 

or District 

Acres

2005 

RAPPCrop 

Management 

Acres

2010 RAPP 

Crop 

Management 

Acres

Change in 

Crop 

Management 

Acres (2010 

- 2005)

St. Croix 

WMD

WI 8,174 700 172 -528

Swan Lake 

NWR

MO 10,611 750 1,115 365

Tamarac 

NWR

MN 42,738 15 15 0

Tamarac 

WMD

MN 881 0 0 0

Trempealeau 

NWR

WI 6,226 0 0 0

Two Rivers 

NWR

IL 12,485 436 0 -436

Union Slough 

NWR

IA 3,334 0 0 0

West Sister 

Island NWR

OH 77 0 0 0

Whittlesey 

Creek NWR

WI 298 0 0 0

Windom 

WMD

MN 16,828 149 120 -29

Winona 

District 

UMNWFR

MN 37,517 0 0 0

TOTAL 1,242,636 26,193 20,418 -5,775
74

Appendix B: Threatened and Endangered Species of the Midwest Region

Common 

Name

Latin Name IL IN IA MI MN MO OH WI

(No common 

name)

Geocarpon 

minimum

T

American 

chaffseed

Schwalbea 

americana

T

American 

hart's-tongue 

fern

Asplenium 

scolopendrium 

var. 

americanum

T

Decurrent 

false aster

Boltonia 

decurrens

T T

Dwarf lake 

iris

Iris lacustris T T

Eastern 

prairie 

fringed 

orchid

Platanthera 

leucophaea

T T T T T T

Fassett’s 

Locoweed

Oxytropis 

campestris var. 

chartacea

T

Houghton's 

goldenrod

Solidago 

houghtonii

T

Lakeside 

Daisy

Hymenoxys 

herbacea

T T T

Leafy prairie 

clover

Dalea foliosa E

Leedy's 

roseroot

Sedum 

integrifolium 

ssp. leedyi

T

Mead’s 

milkweed

Asclepias 

meadii

T T T T

Michigan 

monkeyflower

Mimulus 

glaberatus var. 

michiganensis

E

Minnesota 

dwarf trout 

lily

Erythronium 

propullans

E

Missouri 

bladdderpod

Lesquerella 

filiformis

T

Northern 

wild 

Aconitum 

noveboracense

T T
75

Common 

Name

Latin Name IL IN IA MI MN MO OH WI

monkshood

Pitcher's 

thistle

Cirsium 

pitcheri

TTTT

Pondberry Lindera 

melissifolia

T

Prairie bush 

clover

Lespedeza leptostachyaTTTT

Price’s 

potato-bean

Apios priceanaT

Running 

buffalo 

clover

Trifolium 

stoloniferum

EEE

Small 

whorled 

pogonia

Isotria 

medeoloides

TTTT

Virginia 

sneezeweed

Helenium 

virginicum

T

Virginia 

spiraea

Sprirea 

virginiana

T

Western 

prairie 

fringed 

orchid

Platanthera 

praeclara

TTT

American 

burying 

beetle

Nicrophorus 

americanus

EEE

Canada lynx Lynx 

Canadensis

TTT

Clubshell Pleurobema 

clava

EEE

Copperbelly 

water snake

Nerodia 

erythrogaster 

neglecta

TTE

Curtis 

pearlymussel

Epioblasma 

florentina 

curtisii

E

Eastern 

Massasauga

Sistrurus 

catenatus

C

Fanshell Cyprogenia 

stegaria 

(=c.irrorata)

EE

Fat 

pocketbook

Potamilus 

capax

EEE

Gray bat Myotis EEE
76

Common 

Name

Latin Name IL IN IA MI MN MO OH WI

grisescens

Gray wolf Canis lupisETT

Higgins eye 

pearlymussel

Lampsilis 

higginsii

EEEEE

Hine’s 

emerald 

dragonfly

Somatochlora 

hineana

EE

Hungerford’s 

crawling 

water beetle

Brychius 

hungerfordi

E

Illinois cave

amphipod

Gammarus 

acherondytes

E

Indiana bat Myotis sodalisEEEEEE

Iowa 

Pleistocene 

snail

Discus 

macclintocki

EE

Karner Blue 

Butterfly

Lycaeides 

Melissa 

samuelis

EEEEEE

Kirtland’s 

warbler

Dendroica 

kirtlandii

E

Lake Erie 

water snake

Nerodia 

sipedon 

insularum

T

Least tern Sterna 

antillarum

EEE

Least Tern 

(Interior)

Sterna 

antillarum

E

Mitchell’s 

satyr 

butterfly

Neonympha 

mitchellii

EE

Neosho 

madtom

Noturus 

placidus

T

Niangua 

darter

Etheostoma 

nianguae

T

Northern 

Riffleshell

Epioblasma 

torulosa 

rangiana

EEE

Orange-

footed 

pimpleback 

pearlymussel

Plethobasus 

copperianus 

EE

Ozark big-

eared bat

Corynorhinus 

townsendii 

E
77

Common 

Name

Latin Name IL IN IA MI MN MO OH WI

ingens

Ozark 

cavefish

Amblyopsis

rosea

T

Pallid 

sturgeon

Scaphirhynchus 

albus

EEE

Pink mucket 

pearlymussel

Lampsilis 

abrupt

EEEE

Piping plover Charadrius 

melodus

EETTETEE

Purple cat’s 

paw 

pearlymussel

Epioblasma 

obliquata 

obliquata

E

Rabbitsfoot Quadrula 

cylindrical 

cylindrica

C

Rough pigtoe Pleurobema 

plenum

E

Scaleshell 

mussel

Leptodea 

leptodon

E

Scioto 

madtom

Noturus 

trautmani

E

Sheepnose Plethobasus 

cyphyus

C

Spectaclecase Cumberlandia 

monodonta

C

Topeka 

shiner

Notropis 

Topeka

EEE

Tumbling 

Creek 

cavesnail

Antrobia 

culveri

E

White 

Catspaw 

pearlymussel

Epioblasma 

obliquata 

perobliqua

EE

White 

wartyback 

pearlymussel

Plethobasus 

cicatricosus

E

Winged 

Entire 

Mapleleaf

Quadrula 

fragosa

EEE
78

Appendix C: References

Brookes, G., and P.Barfoot, 2010. GM Crops: global socio-economic and environmental 

impacts 1996-2008. PG Economics Ltd, Dorchester, UK

Cerdeira, A.L. and S. O. Duke. 2006. The Current Status and Environmental Impacts of 

Glyphosate-Resistant Crops: a Review. J. Environ. Qual. 35:1633-1658.

Committee on the Impact of Biotechnology on Farm-Level Economics and Sustainability: 

National Research Council. 2010. Impact of Genetically Engineered Crops on Farm 

Sustainability in the United States. National Academy of Sciences. 

http://www.nap.edu/catalog/12804.html

Czarapata, E.J. 2005. Invasive Plants of the Upper Midwest: An Illustrated Guide to Their 

Identification and Control. Univ. of Wisconsin Press, Madison. 

Dinehart, S.K., L.M. Smith, S.T. McMurry, P.N. Smith, T.A. Anderson, and D.A. Haukos. 2010. 

Acute and chronic toxicity of Roundup Weathermax® and Ignite® 280SL to larval Spea 

multiplicata and S. bombifrons from the Southern high Plains USA. Environmental Pollution 

158:2610-2617.

Donalty, S, S.E. Henke, and C.L. Kerr. 2003. Use of winter food plots by nongame wildlife 

species. Wildlife Society Bulletin 31:774-778.

Duke, S.O., and S.B. Powles. 2008. Glyphosate: a once-in-a-century herbicide. Pest Management 

Science 64:319-325.

Ferry, N. and Anghaard, M.R. 2008. Environmental Impact of Genetically Modified Crops. 

Gatehouse. School of Biology. Institute for Research on Environment and Sustainability. 

Newcastle University. 

Fredrickson, L. H. and Reid, F. A. 1988 Nutritional Values of Waterfowl Foods. Waterfowl 

Management Handbook, Fish and Wildlife Leaflet 13.1.1

Fredrickson, L. H. 1991. Strategies for water level manipulations in moist-soil systems. 

Waterfowl Management Handbook, Fish and Wildlife Service Leaflet. 13.4.6, 8 pp.

Firbank, L.G., S. Petit, S. Smart, A. Blain, and R.J. Fuller. 2008. Assessing the impacts of 

agricultural intensification on biodiversity: a British perspective. Philosophical Transactions of 

the Royal Society 363:777-787.

Foster, M.A., M.J. Gray, and R.M. Kaminski. 2010. Agricultural seed biomass for migrating and 

wintering waterfowl in the southeastern United States. Journal of Wildlife Management 74:489-

495.
79

Helzer, C. 2010. The Ecology and Management of Prairies in the Central United States. 

University of Iowa Press.

Herkert, J. R., D.W. Sample, and R. E. Warner. 1996. Management of Midwestern grassland 

landscapes for the conservation of migratory birds. Pages 89 – 116 in F. R. Thompson III, ed., 

Management of Midwestern landscapes for the conservation of neotropical migratory birds, 

USDA For. Serv. North Central Forest Exper. Stat. Gen. Tech Rep NC-187, St. Paul, MN

Kaminski, R.M., J.B. Davis, H.W. Essig, P.D. Gerard, and K.J. Reinecke. 2003. True 

metabolizable energy for wood ducks from acorns compared to other waterfowl foods. Journal of 

Wildlife Management 67:542-550.

Krapu, G.L., D.A. Brandt, and R.R. Cox, Jr. 2004. Less waste corn, more land in soybeans, and 

the switch to genetically modified crops: trends with important implications for wildlife 

management. Wildlife Society Bulletin 32:127-136.

Kilde, Rebecca 2000 Going Native: A Prairie Restoration Handbook for Minnesota Landowners 

Minnesota Department of Natural Resources Pamplet 63 pp

Kross, J. R.M. Kaminski, K.J. Reinecke, E.J. Penny, and A.T. Pearse. 2008. Moist-soil seed 

abundance in managed wetlands in the Mississippi Alluvial Valley. Journal of Wildlife 

Management 72:707-714.

Langeland, K.A. 2006. Safe use of glyphosage-containing products in aquatic and upland natural 

areas. Florida Cooperative Extension Serivce, Gainesville, FL, 4 pp.

Mann, R.M., R.V. Hyne, C.B. Choung, and S.P. Wilson. 2009. Amphibians and agricultural 

chemicals: review of the risks in a complex environment. Environmental Pollution 157:2903-

2927.

National Invasive Species Council. http://www.invasive speciesinfo.gov

Noss, R.F., E.T. LaRoe, and J.M. Scott. 1995. Endangered Ecosystems of the United States: A 

Preliminary Assessment of Loss and Degradation. Biological Report 28. USDI National 

Biological Service, Washington, DC.

Pimentel, D., R. Zuniga, and D. Morrison. 2005. Update on the environmental and economic 

costs associated with alien-invasive species in the United States. Ecological Economics 52:273-

288.

Reylea, R.A. 2005. The impact of insecticides and herbicides on the biodiversity and 

productivity of aquatic communities. Ecological Applications 15:618-627.

Ringelmann, J. K. 1990 Managing Agricultural Foods for Waterfowl. Waterfowl Management 

Handbook, Fish and Wildlife Leaflet 13.4.3
80

Shipitalo, M.J., R.W. Malone, and L.B. Owens. 2008. Impact of glyphosate-tolerant soybean and 

glufosinate-tolerant corn production on herbicide losses in surface runoff. Journal of 

Environmental Quality. 37:401-408.

Smith D., D. Williams, G. Houseal, and K. Henderson. 2010. The Tallgrass Prairie Center Guide 

to Prairie Restoration in the Upper Midwest. University of Iowa Press. 

Tilman, D., J. Fargione, B. Wolff, C. D’Antonio, A. Dobson, R. Howarth, D. Schindler, W. H. 

Schlesinger, D. Simberloff, and D. Swackhamer. 2001. Foresasting agriculturally driven global 

environmental change. Sicence 292:281-284.

Towery, D., and S. Werblow. 2010. Facilitating conservation farming practices and enhancing 

environmental sustainability. West Lafayette, IN. (At: 

http://www2.ctic.purdue.edu/biotech/pdfs/Biotechnology_Final.pdf.)

USDA-APHIS. 2000. Environmental Assessment and FONSI in response to petition 00-011-01p 

corn line NK603. http://www.aphis.usda.gov/brs/aphisdocs2/00_01101p_com.pdf

USDA-APHIS. 2007. Environmental Assessment and FONSI in response to petition 06-178-01p 

soybean line MON 89788. http://www.aphis.usda.gov/brs/aphisdocs2/06_17801p_com.pdf

USDA Dec 2009. The 2007 Census of Agriculture AC-07-A-51 739 pp 

http://www.agcensus.usda.gov/Publications/2007/Full_Report/index.asp

U.S. Department of Interior and Environment Canada. 1986. North American waterfowl 

management plan. U.S. Department of Interior, Washington, D.C., USA.

USFWS 1985 Refuge Manual Part 6 Section 4 Cropland Management (6 RM 4) 15 pp, 

Arlington, VA

USFWS 2001 Manual, Part 601 Chapter 3 (601 FW 3) Biological Integrity, Diversity, and 

Environmental Health 6 pp, Arlington, VA (http://www.fws.gov/policy/601fw3.html)

USFWS 2005 Refuge Annual Performance Plan Database (RAPP). Arlington, VA.

USFWS 2010 Refuge Annual Performance Plan Database (RAPP). Arlington, VA.

VanGessel, M.J. 2001. Glyphosate-resistant horseweed from Delaware. Weed Science 49:703-

705.

Vera, M.S. L. Lagomarsino, M. Sylverster, G.L. Perez, P. Rodriguez, H. Mugni, R. Sinistro, M. 

Ferraro, C. Bonetto, H. Zagarese, and H. Pizarro. 2010. New evidences of Roundup® 

(glyphosate formulation) impact on the periphyton community and the water quality of 

freshwater ecosystems. Ecotoxicology 19:710-721.
81

Appendix D: Glossary

Comprehensive Conservation Plan

The National Wildlife Refuge System Improvement Act of 1997 requires that each refuge and 

wetland management district must be managed in accordance with an approved CCP that will 

guide management decisions and set forth strategies for achieving station purposes and 

contributing to the mission ofthe Refuge System.

Environmental Assessment

A concise public document, prepared in compliance with NEPA, that briefly discusses the 

purpose and need for an action, alternatives to such action, and provides sufficient evidence and 

analysis of impacts to determine whether to prepare an environmental impact statement or 

finding of no significant impact (40 CFR 1508.9).

Farming

For the purposes of this Environmental Assessment, “farming” refers to planting and harvesting 

row crops.

Genetically Modified/Engineered Organism/Transgenic Organism

Contains a gene or genes that have been artificially inserted instead of the plant acquiring the 

gene or genes through pollination. The inserted gene or genes may come from an unrelated plant 

or from a completely different species.

Glyphosate

Glyphosate is a broad-spectrum, non-selective herbicide. It is probably the most widely used 

herbicide wordwide and is generally considered to be highly effective, but toxicologically and 

environmentally safe.

National Wildlife Refuge 

A national wildlife refuge is land or water acquired or held in easement by the U.S. Fish and 

Wildlife Service for the purpose of habitat and wildlife conservation. Refuges range is size from 

half an acre (Mille Lacs NWR in Minnesota) to more than 19 million acres (Arctic NWR in 

Alaska). 

National Wildlife Refuge System

All lands, waters, and interests therein administered by the U.S. Fish and Wildlife Service as 

wildlife refuges, wildlife ranges, wildlife management areas, wetland management districts, 
82

waterfowl production areas, and other areas for the protection and conservation of fish, wildlife 

and plant resources.

No Action Alternative

The alternative where current conditions and trends are projected into the future without another 

proposed action (40 CFR 1502.14(d)).

Waterfowl Production Area

Upland grasslands and wetlands that are purchased by the federal government to provide nesting 

habitat for waterfowl and hunting areas for waterfowl and upland game hunters.

Wetland Management District

The federal administrative unit that is charged with acquiring, overseeing and managing the 

Waterfowl Production Areas and easements within a specified group of counties. Most Districts 

are large, covering several counties,
83
84
85
86
87
88

Appendix F: Responses to Public Comments

The Service received 61 comment letters or e-mail messages during the public review period of 

the Draft Environmental Assessment. The following organizations provided comments on the 

Draft EA.

Virginia Commonwealth University

Sherburne Soil and Water Conservation District

Illinois Farm Bureau

University of Illinois – Institute of Natural Resource Sustainability

Franklin College

Public Employees for Environmental Responsibility

Organic Independents LLP

Biotechnology Industry Organization

Rodale Institute

American Seed Trade Association

Pulaski-Alexander Farm Bureau

Organic Trade Association

Iowa State University

Missouri Farm Bureau Federation

Iowa Farm Bureau

The Cornucopia Institute

The Center for Food Safety

Beyond Pesticides

Monsanto Company

Mississippi Valley Hunters and Fisherman Association

The planning team has reviewed all of the public comments. The majority of respondents 

expressed a general opinion on the use of GMGT, farming on refuges, or a preference for a 

particular alternative. The following discussion summarizes the substantive issues raised during 

the comment period and our responses to them. Many of our responses refer to the full text copy 

of the Draft EA, and indicate how this Final EA reflects any proposed changes. The Discussion 

section addresses specific comments expressing concern, need for clarification, or opposition. 

Support for Alternative D

We developed a new alternative, Alternative E, which is the selected alternative. Under this 

alternative, farming would continue at levels indicated in the EA and GMGT corn and soybeans 

could be used for habitat restoration if their use is found to be essential by the Regional Chief of 

Refuges.

Given our limited knowledge about the long term effects of GMO crops on animals and 

ecosystems we should not use them on public lands.

Chapter 4 of the EA includes analysis that references two other EAs completed by USDA’s 

Animal and Plant Health Inspection Service that found no significant impact from the use of 

GMGT corn and soybeans.
89

Support for Alternative A

We developed a new alternative, Alternative E, which is the selected alternative. Under this 

alternative, farming would continue at levels indicated in the EA and GMGT corn and soybeans 

could be used for habitat restoration if their use is found to be essential by the Regional Chief of 

Refuges.

Do not reduce the acres farmed in row crops.

Restoring native habitats is part of the mission of the National Wildlife Refuge System. Farming 

is one tool used to accomplish this, but as more acres are restored fewer acres will be in row 

crops.

Ban GMO crop planting on national wildlife refuges.

Using GM crops would cause irrevocable harm to the environment and wildlife.

The use of genetically modified organisms is not safe.

The EA does not adequately disclose the effects of GE crops and herbicides on wildlife, plants, 

and soil.

The risk of herbicide use to amphibians and other aquatic species is not adequately 

considered.

Based on the analysis included in Chapter 4 of the EA and other referenced EAs (see also 

Chapter 2) there is no significant impact from the use of GMGT corn and soybeans.

Support for the use of genetically modified crops

We developed a new alternative, Alternative E, which is the selected alternative. Under this 

alternative, farming would continue at levels indicated in the EA and GMGT corn and soybeans 

could be used for habitat restoration if their use is found to be essential by the Regional Chief of 

Refuges.

Farming, including the use of GM crops, should continue to be used for habitat restoration on 

national wildlife refuges.

We developed a new alternative, Alternative E, which is the selected alternative. Under this 

alternative, farming would continue at levels indicated in the EA and GMGT corn and soybeans 

could be used for habitat restoration if their use is found to be essential by the Regional Chief of 

Refuges.

The EA does not comport with NEPA, as it fails to analyze alternatives or fully assess likely 

impacts.

The Preferred Alternative is too vague to gauge environmental impacts.

The EA considers a reasonable range of alternatives and the impacts are assessed in Chapter 4 of 

the EA.

It appears that with respect to approval for GE crops FWS is improperly placing the 

profitability of local cooperating farmers over the refuge values it is supposed to place 

paramount.

Profitability is an issue for cooperating farmers, but it is not a primary consideration in the use of 

farming on national wildlife refuges.
90

The Preferred Alternative violates FWS Ecological Integrity Policy.

Alternative E, the selected alternative, includes additional explanation of the steps to ensure 

farming activity complies with the Service policy on Biological Integrity, Diversity, and 

Environmental Health.

Since this is not a programmatic EA, in order to comply with NEPA, FWS must do a refugeby-refuge review of each farming program. 

Comprehensive Conservation Plans (CCPs) have been completed or currently in progress for all 

but two refuges or management districts that have farming programs. The remaining two are 

scheduled to occur next year. The NEPA requirements are completed as part of the CCP 

process. Farming programs are evaluated during this planning process.

The FWS wrongfully failed to consider a No Farming alternative.

The Service considered a No Farming alternative but did not further develop it as documented in 

Chapter 2 of the EA.

The Preferred Alternative fosters evolution of herbicide resistant weeds and increased use of 

herbicides.

These issues are addressed in the Chapter 4 Environmental Consequences. Alternative E, the 

selected alternative specifically addresses this concern by limiting the use of GMGT corn and 

soybeans to a five year restoration period at any one site. It confines the use of GMGT corn and 

soybeans to habitat restoration.

The risk of biological contamination from GE crops is not adequately analyzed.

Inadvertent crop to weed gene flow is addressed in Chapter 4 Environmental Consequences of 

the EA.

Neither the EA nor FWS policy lays out clear enforcement mechanisms to make sure that 

safeguards in cooperative agreements, IPM plans or refuge Pesticide Use Proposals are 

enforced.

Refuge and District Managers are responsible for enforcement of cooperative agreements, IPM 

plans and Pesticide Use Proposals at each unit.

GE crops are not needed as a wildlife food source.

Alternative E, the selected alternative, limits the use of GMGT crops to habitat restoration 

activities. 

Refuge crops may illegally bait wild birds.

Refuge and District Managers work closely with Law Enforcement Officers to ensure crops on 

Refuges and Wetland Management Districts comply with state and federal regulations.

The EA does not explain why GE crops are necessary.

We developed a new alternative, Alternative E, which is the selected alternative. Under this 
91

alternative, farming would continue at levels indicated in the EA and GMGT corn and soybeans 

could be used for habitat restoration if their use is found to be essential by the Regional Chief of 

Refuges.

The EA falls short of meeting the Department of Interior order on scientific integrity.

This EA meets the purpose of the Department of Interior policy on Integrity of Scientific and 

Scholarly Activities as stated below.

305 DM 3

3.1 Purpose. 

 A. This chapter establishes Departmental policy on the integrity of scientific and 

scholarly activities the Department conducts and science and scholarship it uses to inform 

management and public policy decisions. Scientific and scholarly information considered in 

Departmental decision making must be robust, of the highest quality, and the result of as 

rigorous scientific and scholarly processes as can be achieved. Most importantly, it must be 

trustworthy. It is essential that the Department establish and maintain integrity in its scientific 

and scholarly activities because information from such activities is a critical factor that informs 

decision making on public policies. Other factors that inform decision making may include 

economic, budget, institutional, social, cultural, legal and environmental considerations. 

Organic crops were not considered as an alternative.

Although this was not considered as a stand alone alternative nothing precludes the use of 

organic crops or other farming methods that help meet Refuge or District objectives.

Does glyphosate remain in the soil to affect future native plantings?

Glyphosate is strongly adsorbed to soil particles (so it is no longer harmful to plants) and is then 

rapidly biodegraded. Its average half-life in soil is about 60 days. Glyphosate has been 

commonly used for many years in habitat restoration across the Midwest Region. Many sites 

where glyphosate was used now have robust stands of native plants.