Monsanto Petition (11-202-01p) for 

Determination of Nonregulated Status of Event

MON 87712-4 Soybean

OECD Unique Identifier: 

MON 87712-4

Environmental Assessment 

September 2013

Agency Contact 

Cindy Eck

Biotechnology Regulatory Services

4700 River Road 

USDA, APHIS 

Riverdale, MD 20737 

Fax: (301) 734-8669

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product mentioned. Product names are mentioned solely to report factually on available data and to provide specific 

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This publication reports research involving pesticides. All uses of pesticides must be registered by appropriate State 

and/or Federal agencies before they can be recommended. 
TABLE OF CONTENTS

Page

1 PURPOSE AND NEED ...........................................................................................................1

1.1 Background .......................................................................................................................1

1.2 Purpose of the Product ......................................................................................................1

1.3 Coordinated Framework Review and Regulatory Review................................................1

1.3.1 USDA-APHIS ...........................................................................................................2

1.3.2 Food and Drug Administration..................................................................................3

1.4 Purpose and Need for This APHIS Action........................................................................3

1.5 Public Involvement ...........................................................................................................4

1.5.1 First Opportunity for Public Involvement .................................................................4

1.5.2 Second Opportunity for Public Involvement.............................................................5

1.6 Issues Considered..............................................................................................................6

2 AFFECTED ENVIRONMENT................................................................................................8

2.1 Agricultural Production of Soybean..................................................................................8

2.1.1 Acreage and Area of Soybean Production.................................................................8

2.1.2 Agronomic Practices................................................................................................11

2.1.3 Soybean Seed Production ........................................................................................32

2.1.4 Organic Soybean Production...................................................................................35

2.2 Physical Environment .....................................................................................................38

2.2.1 Soil Quality..............................................................................................................38

2.2.2 Water Resources......................................................................................................40

2.2.3 Air Quality...............................................................................................................43

2.2.4 Climate Change .......................................................................................................45

2.3 Biological Resources.......................................................................................................46

2.3.1 Animal Communities...............................................................................................46

2.3.2 Plant Communities ..................................................................................................48

2.3.3 Gene Flow and Weediness ......................................................................................52

2.3.4 Microorganisms.......................................................................................................53

2.3.5 Biodiversity .............................................................................................................55

2.4 Human Health .................................................................................................................58

2.4.1 Consumer Health .....................................................................................................58

2.4.2 Occupational Health and Safety ..............................................................................59

2.5 Animal Feed ....................................................................................................................60

2.6 Socioeconomic ................................................................................................................61

2.6.1 Domestic Economic Environment...........................................................................61

2.6.2 Trade Economic Environment.................................................................................66

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3 ALTERNATIVES ..................................................................................................................70

3.1 No Action Alternative: Continuation as a Regulated Article.........................................70

3.2 Preferred Alternative: Approve the Request for Nonregulated Status to MON 87712-4 

Soybean...........................................................................................................................70

3.3 Alternatives Considered But Rejected from Further Consideration ...............................71

3.3.1 Prohibit Any MON 87712-4 Soybean from Being Released ..................................71

3.3.2 Isolation Distance between MON 87712-4 Soybean and Non-GE Soybean 

Production and Geographical Restrictions..............................................................71

3.3.3 Requirement of Testing for MON 87712-4 Soybean ..............................................72

3.4 Comparison of Alternatives ............................................................................................72

4 ENVIRONMENTAL CONSEQUENCES .............................................................................81

4.1 Scope of Analysis............................................................................................................82

4.2 Agricultural Production of Soybean................................................................................83

4.2.1 Acreage and Area of Soybean Production...............................................................83

4.2.2 Agronomic Practices................................................................................................85

4.2.3 Soybean Seed Production ........................................................................................89

4.2.4 Organic Soybean Production...................................................................................90

4.3 Physical Environment .....................................................................................................92

4.3.1 Soil Quality..............................................................................................................92

4.3.2 Water Resources......................................................................................................93

4.3.3 Air Quality...............................................................................................................94

4.3.4 Climate Change .......................................................................................................95

4.4 Biological Resources.......................................................................................................96

4.4.1 Animal Communities...............................................................................................96

4.4.2 Plant Communities ..................................................................................................97

4.4.3 Gene Flow and Weediness ......................................................................................99

4.4.4 Microorganisms.....................................................................................................101

4.4.5 Biodiversity ...........................................................................................................103

4.5 Human Health ...............................................................................................................104

4.5.1 Public Health .........................................................................................................104

4.5.2 Occupational Health and Safety ............................................................................106

4.6 Animal Feed ..................................................................................................................106

4.7 Socioeconomic Impacts.................................................................................................108

4.7.1 Domestic Economic Environment.........................................................................108

4.7.2 Trade Economic Environment...............................................................................111

5 CUMULATIVE IMPACTS..................................................................................................114

5.1 Assumptions Used for Cumulative Impacts Analysis...................................................114

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5.2 Cumulative Effects........................................................................................................114

5.2.1 Past and Present Actions and the Preferred Alternative ........................................114

5.2.2 Reasonably Foreseeable Actions...........................................................................120

6 THREATENED AND ENDANGERED SPECIES .............................................................128

6.1 Potential Effects of MON 87712-4 Soybean on TES ...................................................129

6.1.1 Threatened and Endangered Plant Species............................................................129

6.1.2 Threatened and Endangered Animal Species........................................................130

6.1.3 Summary of Potential Effects of MON 87712-4 Soybean on TES.......................132

7 CONSIDERATION OF EXECUTIVE ORDERS, STANDARDS, AND TREATIES 

RELATING TO ENVIRONMENTAL IMPACTS..............................................................134

7.1.1 Executive Orders with Domestic Implications......................................................134

7.1.2 International Implications......................................................................................136

7.1.3 Impacts on Unique Characteristics of Geographic Areas......................................137

7.1.4 National Historic Preservation Act (NHPA) of 1966 as Amended .......................138

8 LIST OF PREPARERS ........................................................................................................139

9 REFERENCES .....................................................................................................................140

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LIST OF FIGURES

Page

Figure 1. Planted and harvested acreage of soybeans in the United States. (1992-2012)............. 9

Figure 2. Soybean planted acres by county for selected states, 2011.......................................... 11

Figure 3. Major rotational crops following soybean in 2008 in the United States and the 

Midwest, Southeast, and East Coastal regions............................................................ 16

Figure 4. Percent of U.S. soybean acres in program states1 treated with 10 most used herbicides 

in 1995, 2001 and 2006................................................................................................ 26

Figure 5. Soybean yield rose at an annual average rate of 0.35 bushels per acre between 1924 –

2010. Linear regression analysis was conducted by Monsanto on data from the 

USDA-NASS (Phillion, 2013 pers. comm.). ............................................................... 30

Figure 6. Nominal price trend of U.S. soybean seeds, 2000-2007(Shi et al., 2009). .................. 33

Figure 7. The evolution of herbicide resistance. ......................................................................... 49

Figure 8. Distribution of crop value in 2012. .............................................................................. 62

Figure 9. U.S. soybean cost and value of production estimates for 2011 (excluding government 

payments). .................................................................................................................... 63

LIST OF TABLES

Page

Table 1. U.S. soybean production in 2011 and 2012. ................................................................ 10

Table 2. Percentage of soybean acreage planted with GE herbicide-resistant soybean varieties 

by state and for the United States................................................................................. 12

Table 3. Nutrient removal rates per unit of yield by soybean and grain crops commonly rotated 

with soybean. ............................................................................................................... 19

Table 4. Soybean nutrient removals at differing rates of grain bushels per acre yields............. 19

Table 5. Soybeans: total fertilizer primary nutrient applications in program states, 2006. ....... 20

Table 6. Soybeans: insecticide chemical applications in program states, 20061........................ 21

Table 7. Percent of U.S. soybean acres1 treated with herbicides in 1995, 2001, 2006 and 2012.

...................................................................................................................................... 24

Table 8. Soybeans: total herbicide applications, 20061.............................................................. 27

Table 9. 2012 average U.S. soybean productivity by region. .................................................... 32

Table 10. U.S. certified organic soybean harvested acres by state, 20111................................... 37

Table 11. Total farm diesel fuel consumption estimate (in gallons per year).............................. 44

Table 12. Summary of world-wide herbicide-resistant weeds by herbicide group...................... 51

Table 13. Soybean crop value by state......................................................................................... 64

Table 14. U.S. soybean supply and disappearance1 2011/12....................................................... 65

Table 15. United States and rest of world (ROW) soybean supply and disappearance1 2011/12.

...................................................................................................................................... 66

Table 16. World soybean production in 2011/12......................................................................... 67

Table 17. World soybean exports in 2011/12. ............................................................................. 68

Table 18. Top 10 U.S. soybean export markets in 2011/12......................................................... 68

Table 19. Summary of issues of potential impacts and consequences of alternatives. ................ 73

iv
ACRONYMS AND ABBREVIATIONS

°C degrees Celsius

°F degrees Fahrenheit

AIA advanced informed agreement

AMS Agricultural Marketing Service

ANZFS Australia and New Zealand Food Standards Agency

AOSCA Association of Official Seed Certifying Agencies

APHIS Animal and Plant Health Inspection Service

ARMS Agricultural Resource Management Survey

ARS Agricultural Research Service

BRS Biotechnology Regulatory Service’s

C carbon

CAA Clean Air Act

CFR Code of Federal Regulations

CH4 methane

CO carbon monoxide

CO2 carbon dioxide

CWA Clean Water Act

DNA deoxyribonucleic acid

EA Environmental Assessment

ECOS Environmental Conservation Online System

EFSA European Food Safety Agency

EIS Environmental Impact Statement

EO Executive Order

EPA Environmental Protection Agency

ERS Economic Research Service

ESA Endangered Species Act

FDA Food and Drug Administration

FFDCA Federal Food, Drug, and Cosmetic Act

FFP food, feed, or processing

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act

FQPA Food Quality Protection Act

FR Federal Register

GE genetically engineered

GHGs greenhouse gases

HRAC Herbicide Resistance Action Committee

IP Identity Preservation

IPPC International Plant Protection Convention

lb/A pounds per acre

LMO living modified organisms

MGs maturity groups

MT metric tons

N2O nitrous oxide

NAAQS National Ambient Air Quality Standards

NAPPO North American Plant Protection Organization

NASS National Agricultural Statistics Service

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ACRONYMS AND ABBREVIATIONS (continued)

NEPA National Environmental Policy Act

NHPA National Historic Preservation Act

NH3 ammonia

NMFS National Marine Fisheries Service

NO2 nitrogen dioxide

NOP National Organic Program

NPDES National Pollutant Discharge Elimination System

NRC National Research Council

NRCS Natural Resources Conservation Service

O3 ozone

OSHA Occupational Safety and Health Administration

Pb lead

PDP Pesticide Data Program

PIPs plant-incorporated protectants

PM coarse particulate matter

PM2.5 fine particles less than 2.5 micrometers in diameter

PM10 particles greater than 2.5 micrometers and less than 10 micrometers in diameter

PRA Plant Risk Analysis

ROW rest of world

SDWA Safe Drinking Water Act of 1974

SIP State Implementation Plan

SO2 sulfur dioxide

SOM soil organic matter

SSA Sole Source Aquifer

TES threatened and endangered species

TMDL total maximum daily loads

TSCA Toxic Substances Control Act

U.S. United States

U.S.C. United States Code

USDA United States Department of Agriculture

USFWS United States Fish and Wildlife Service

WHO World Health Organization

WPS Worker Protection Standard

vi
1 PURPOSE AND NEED

1.1 Background

Monsanto Company of St. Louis, MO (henceforth referred to as Monsanto) submitted petition 

11-202-01p to the United States Department of Agriculture (USDA) Animal and Plant Health 

Inspection Service (APHIS) September 16, 2011 (Monsanto, 2011). The purpose of the petition 

is to support a determination of nonregulated status for Monsanto 87712-4 soybean (henceforth 

referred to as MON 87712). The 87712 variety is currently regulated under Title 7 of the Code 

of Federal Regulations (7 CFR) part 340. Interstate movement and field trials of MON 87712 

soybean have been conducted under permits issued or notifications acknowledged by APHIS 

since 2006. These field trials were conducted within selected soybean growing areas in the U.S., 

including Illinois, Indiana, Ohio, Iowa, Kansas, Nebraska, Missouri, Texas, Florida and 

Kentucky. Data resulting from these field trials are described in the MON 87712 soybean 

petition (Monsanto, 2011; Pioneer, 2011) and analyzed for plant pest risk in the USDA-APHIS 

Plant Pest Risk Assessment (PPRA) (USDA-APHIS, 2011a)

The petition stated that APHIS should not regulate MON 87712 soybean because it does not 

present a plant pest risk. If a determination of nonregulated status is made, it would include 

MON 87712 soybean, any progeny derived from crosses between MON 87712 soybean and 

conventional soybean, and crosses of MON 87712 soybean with other biotechnology-derived 

soybean lines that are no longer subject to the regulatory requirements of 7 CFR part 340 

promulgated under the authority of the Plant Protection Act of 2000 (PPA).

1.2 Purpose of the Product

The purpose of MON 87712 soybean is to provide a trait that potentially increases soybean yield

using a single gene strategy. Increased soybean productivity in the United States has historically 

been accomplished through conventional breeding with genetic selection and subsequent yield 

increases per unit area, likely deriving from multigene mechanisms of inheritance. U.S. soybean 

yield increases can also be attributed to agronomic innovations as well as better control of pests 

and diseases that provide producers effective tools to meet production demands (Specht et al., 

1999). Continuing infusions of genetic resources including those from germplasm centers have 

also been a major source in soybean for yield stability and growth (USDA-ERS, 2006a). The 

potential commercial use of MON87712 soybean might provide a more efficient method to 

increase soybean yield for seed producers and for farmers, additional access to potentially high 

yielding soybean varieties.

1.3 Coordinated Framework Review and Regulatory Review

Since 1986, the United States government has regulated genetically engineered (GE) organisms 

pursuant to Federal regulations published in the Federal Register (51 FR 23302; 57 FR 22984)

entitled The Coordinated Framework for the Regulation of Biotechnology (henceforth referred to 

here as the Coordinated Framework). The Coordinated Framework, published by the Office of 

Science and Technology Policy, describes the comprehensive federal regulatory policy for 

ensuring the safety of biotechnology research and products and explains how federal agencies 

will use existing Federal statutes in a manner to ensure public health and environmental safety 

1
while maintaining regulatory flexibility to avoid impeding the growth of the biotechnology 

industry. The Coordinated Framework is based on several important guiding principles: (1) 

agencies should define those transgenic organisms subject to review to the extent permitted by 

their respective statutory authorities; (2) agencies are required to focus on the characteristics and 

risks of the biotechnology product, not the process by which it is created; (3) agencies are 

mandated to exercise oversight of GE organisms only when there is evidence of “unreasonable” 

risk.

The Coordinated Framework explains the regulatory roles and authorities for the three major 

agencies involved in regulating GE organisms: USDA APHIS, the Environmental Protection 

Agency (EPA), and the Food and Drug Administration (FDA). A summary of each role follows:

1.3.1 USDA-APHIS

APHIS regulations at 7 CFR part 340, which were promulgated pursuant to authority granted by 

the PPA, as amended (7 United States Code (U.S.C.) 7701–7772), regulate the introduction (i.e., 

importation, interstate movement, or release into the environment) of certain GE organisms and 

products. A GE organism is no longer subject to the plant pest provisions of the PPA or to the 

regulatory requirements of 7 CFR part 340, when APHIS determines that it is unlikely to pose a 

plant pest risk. A GE organism is considered a regulated article if the donor organism, recipient 

organism, vector, or vector agent used in engineering the organism belongs to one of the taxa 

listed in the regulation (7 CFR 340.2) and is also considered a plant pest. A GE organism is also 

regulated under 7 CFR 340, when APHIS has reason to believe that the GE organism may be a 

plant pest or APHIS does not have information to determine if the GE organism is unlikely to 

pose a plant pest risk. 

A person may petition the agency for a determination that a particular regulated article is 

unlikely to pose a plant pest risk, and therefore, is no longer regulated under the plant pest 

provisions of the PPA or the regulations at 7 CFR 340. Under § 340.6(c)(4), the petitioner must 

provide information related to plant pest risk that the agency can use to determine whether the 

regulated article is unlikely to present a greater plant pest risk than the unmodified organism. A 

GE organism is no longer subject to the regulatory requirements of 7 CFR part 340 or the plant 

pest provisions of the PPA when APHIS determines that it is unlikely to pose a plant pest risk

1.3.2 Environmental Protection Agency

The EPA is responsible for regulating the sale, distribution, and use of pesticides, including 

pesticides that are produced by an organism through techniques of modern biotechnology. The 

EPA regulates plant incorporated protectants (PIPs) under the Federal Insecticide, Fungicide, and 

Rodenticide Act (FIFRA) (7 U.S.C. 136 et seq.) and certain biological control organisms under 

the Toxic Substances Control Act (TSCA) (15 U.S.C. 53 et seq.). Before planting a crop 

containing a PIP, a company must seek an experimental use permit from EPA. Commercial 

production of crops containing PIPs for purposes of seed increases and sale requires a FIFRA 

Section 3 registration with EPA. 

Under FIFRA (7 U.S.C. 136 et seq.), EPA regulates the use of pesticides, and requires 

registration of all pesticide products for all specific uses prior to distribution for sale. EPA 

2
examines: the ingredients of the pesticide; the particular site or crop on which it is to be used; the 

amount, frequency, and timing of its use; storage and disposal practices. Prior to registration for 

a new use for a new or previously registered pesticide, EPA must determine through testing that 

the pesticide does not cause unreasonable adverse effects on humans, the environment, and nontarget species when used in accordance with label instructions. EPA must also approve the 

language used on the pesticide label in accordance with 40 CFR part 158. Once registered, a 

pesticide may only be legally used in accordance with directions and restrictions on its label. 

The overall intent of the label is to provide clear directions for effective product performance, 

while minimizing risks to human health and the environment. The Food Quality Protection Act 

(FQPA) of 1996 amended FIFRA, enabling EPA to implement periodic registration review of 

pesticides to ensure they are meeting current scientific and regulatory standards of safety and 

continue to have no unreasonable adverse effects (US-EPA, 2011d). 

EPA also sets tolerances (maximum residue levels) or establishes an exemption from the 

requirement for a tolerance, under the Federal Food, Drug, and Cosmetic Act (FFDCA). A 

tolerance is the amount of pesticide residue that can remain on or in food for human consumption 

or animal feed. Before establishing a pesticide tolerance, EPA is required to reach a safety 

determination based on a finding of reasonable certainty of no harm under the FFDCA, as 

amended by the FQPA. FDA enforces the pesticide tolerances set by EPA.

1.3.2 Food and Drug Administration

FDA regulates GE organisms under the authority of the FFDCA (21 U.S.C. 301 et seq.). The 

FDA published its policy statement concerning regulation of products derived from new plant 

varieties, including those derived from genetic engineering, on May 29, 1992 (57 FR 22984). 

Under this policy, FDA implements a voluntary consultation process to ensure that human food 

and animal feed safety issues or other regulatory issues, such as labeling, are resolved before 

commercial distribution of bioengineered food. This voluntary consultation process provides a 

way for developers to receive assistance from FDA in complying with their obligations under 

Federal food safety laws prior to marketing.

More recently (June 2006), FDA published recommendations in “Guidance for Industry: 

Recommendations for the Early Food Safety Evaluation of New Non-Pesticidal Proteins 

Produced by New Plant Varieties Intended for Food Use” (US-FDA, 2006). This establishes 

voluntary food safety evaluations for new non-pesticidal proteins produced by new plant 

varieties intended to be used as food, including bioengineered plants. Early food safety 

evaluations help make sure that potential food safety issues related to a new protein in a new 

plant variety are addressed early in development. These evaluations are not intended as a 

replacement for a biotechnology consultation with FDA, but the information may be used later in 

the biotechnology consultation.

1.4 Purpose and Need for This APHIS Action

As noted in the previous section any party can petition APHIS to seek a determination of 

nonregulated status for a GE organism that is regulated under 7 CFR 340. As required by 7 CFR 

340.6, APHIS must respond to petitioners that request a determination of the regulated status of 

3
GE organisms, including GE plants such as MON 87712 soybean. When a petition for 

nonregulated status is submitted, APHIS must determine if the GE organism is unlikely to pose a 

plant pest risk. The petitioner is required to provide information under § 340.6(c)(4) related to 

plant pest risk that the agency may use to determine whether the regulated article is unlikely to 

present a greater plant pest risk than the unmodified organism. A GE organism is no longer 

subject to the regulatory requirements of 7 CFR part 340 or the plant pest provisions of the PPA 

when APHIS determines that it is unlikely to pose a plant pest risk.

APHIS must respond to the petition from Monsanto requesting a determination of nonregulated 

status for MON 87712 soybean. APHIS has prepared this Environmental Assessment (EA) to 

consider the potential environmental impacts of an agency determination of the nonregulated 

status of MON 87712 soybean. This action is consistent with regulations for the National 

Environmental Policy Act (NEPA) established by the Council of Environmental Quality (CEQ), 

and the USDA APHIS NEPA-implementing regulations and procedures (40 CFR parts 1500-

1508, 7 CFR part 1b, and 7 CFR part 372). This EA has been prepared in order to specifically 

evaluate the impacts on the quality of the human environment1 that may result from a 

determination of nonregulated status for MON 87712 soybean.

1.5 Public Involvement

APHIS routinely seeks public comment on EAs prepared in response to petitions seeking a 

determination of nonregulated status of a regulated GE organism. APHIS does this through a 

notice published in the Federal Register. On March 6, 2012, APHIS published a notice2 in the 

Federal Register advising the public that APHIS is implementing changes to the way it solicits 

public comment when considering petitions for determinations of nonregulated status for GE 

organisms to allow for early public involvement in the process. As identified in this notice, 

APHIS will publish two separate notices in the Federal Register for petitions for which APHIS 

prepares an EA. The first notice will announce the availability of the petition, and the second 

notice will announce the availability of APHIS’ decision making documents. As part of the new 

process, with each of the two notices published in the Federal Register, there will be an 

opportunity for public involvement:

1.5.1 First Opportunity for Public Involvement

Once APHIS deems a petition complete, the petition is made available for public comment for 60 

days, providing the public an opportunity to raise issues regarding the petition itself and give 

input that will be considered by the Agency as it develops its EA and PPRA. APHIS publishes a 

notice in the Federal Register to inform the public that APHIS will accept written comments 

regarding a petition for a determination of nonregulated status for a period of 60 days from the 

date of the notice. This availability of the petition for public comment will be announced in a 

Federal Register notice.

1 Under NEPA regulations, the “human environment” includes “the natural and physical environment and the 

relationship of people with that environment” (40 CFR §1508.14). 2

 This notice can be accessed at: http://www.gpo.gov/fdsys/pkg/FR-2012-03-06/pdf/2012-5364.pdf

4

 
1.5.2 Second Opportunity for Public Involvement 

Assuming an EA is sufficient, the EA and PPRA are developed and a notice of their availability 

is published in a second Federal Register notice. This second notice follows one of two 

approaches for public participation based on whether or not APHIS decides the petition for a 

determination of nonregulated status is for a GE organism that raises substantive new issues:

Approach 1: GE organisms that do not raise substantive new issues. This approach for public 

participation is used when APHIS decides, based on the review of the petition and our evaluation 

and analysis of comments received from the public during the 60-day comment period on the 

petition, that the petition involves a GE organism that does not raise new biological, cultural, or 

ecological issues because of the nature of the modification or APHIS' familiarity with the 

recipient organism. After developing its EA, finding of no significant impact (FONSI), and 

PPRA, APHIS publishes a notice in the Federal Register announcing its preliminary regulatory 

determination and the availability of the EA, FONSI, and PPRA for a 30-day public review 

period.

If APHIS determines that no substantive information has been received that would warrant 

APHIS altering its preliminary regulatory determination or FONSI, substantially changing the 

proposed action identified in the EA, or substantially changing the analysis of impacts in the 

EA, APHIS' preliminary regulatory determination becomes final and effective upon public 

notification through an announcement on its website. No further Federal Register notice is 

published announcing the final regulatory determination.

Approach 2. For GE organisms that raise substantive new issues not previously reviewed by 

APHIS. A second approach for public participation is used when APHIS determines that the 

petition for a determination of nonregulated status is for a GE organism that raises substantive 

new issues. This could include petitions involving a recipient organism that has not previously 

been determined by APHIS to have nonregulated status or when APHIS determines that gene 

modifications raise substantive biological, cultural, or ecological issues not previously analyzed 

by APHIS. Substantive issues are identified by APHIS based on our review of the petition and 

our evaluation and analysis of comments received from the public during the 60-day comment 

period on the petition. 

APHIS solicits comments on its draft EA and draft PPRA for 30 days through the publication of 

a Federal Register notice. APHIS reviews and evaluates comments and other relevant 

information, then revises the PPRA as necessary and prepares a final EA. Following preparation 

of these documents, APHIS approves or denies the petition, announcing in the Federal Register

the regulatory status of the GE organism and the availability of APHIS' final EA, PPRA, 

National Environmental Policy (NEPA) decision document (either a FONSI or NOI to prepare 

an EIS), and regulatory determination.

Enhancements to public input are described in more detail in the Federal Register notice3

published on March 6, 2012.

3 This notice can be accessed at: http://www.gpo.gov/fdsys/pkg/FR-2012-03-06/pdf/2012-5364.pdf

5

 
APHIS has determined that this EA will follow Approach 2 following an APHIS-BRS decision 

tree, in this case because the trait is a new one, and not previously determined as 

nonregulated. The issues discussed in this EA were developed by considering the public 

concerns, including public comments received in response to the Federal Register notice (77 

F.R. 41354-6) announcing the availability of the petition (i.e., the first opportunity for public 

involvement previously described in this document), as well as issues noted in public comments 

submitted for other EAs of GE organisms, and concerns described in lawsuits and expressed by 

various stakeholders. These issues, including those regarding the agricultural production of 

soybean using various production methods and the environmental and food/feed safety of GE 

plants, were addressed to analyze the potential environmental impacts of MON 87712 soybean.

The public comment period for MON 87712 soybean petition closed on September 11, 2012. At 

its closing, the docket file contained a total of 4,665 public comments. Some of the submissions 

to the docket contained multiple attached comments gathered by organizations from their 

members. The majority of the comments expressed a general dislike of the use of GE organisms 

or was form letters sent to all of the dockets which were open at the time that this docket was 

open. The form letter expressed a concern that there were too many dockets published on the 

same day. It also referenced other open dockets and potential effects from the use of the subjects 

of those petitions. These issues are outside the scope of this EA. The issues that were raised in 

the public comments which were related to the Monsanto 87712 soybean petition included:

• Outcrossing with other soybean lines that are nontransgenic can negatively impact their 

salability and also consumer choice in GE-sensitive markets

• Increased production of soybean reduces plant and subsequent animal diversity 

• Food and feed impacts are conducted and evaluated by the seed developer and need peer 

review along with FDA review

• Increased yield will result in increased supply and lower prices to both US and foreign 

soybean producers

• Concerns that there are economic impacts of cross pollination from MON 87712 soybean 

to organic soybeans for some organic growers. According to the comment organic 

growers have experienced rejection rates of 0.25%.

• Concerns that MON 87712 soybean is not approved in all export markets, and if this 

variety arrived at a market without specific approval, trade disruptions and economic 

losses could occur. The developer needs binding stewardship mechanisms in place to 

prevent potential trade economic impacts as well as compensation mechanisms if these 

mechanisms fail to be observed. 

APHIS evaluated these raised issues and the submitted documentation. APHIS has also included 

a discussion of these issues in this EA.

1.6 Issues Considered

The list of resource areas considered in this EA was developed by APHIS through experience in 

considering public concerns and issues raised in public comments submitted for other EAs of GE 

organisms. The resource areas considered also address concerns raised in previous and unrelated 

6

 
lawsuits, as well as issues that have been raised by various stakeholders in the past. The resource 

areas considered in this EA can be categorized as follows: 

Agricultural Production Considerations:

• Acreage and Areas of Soybean Production

• Agronomic/Cropping Practices

• Soybean Seed Production 

• Organic Soybean Production 

Environmental Considerations:

• Soil

• Water Resources

• Air Quality 

• Climate Change

• Animals

• Plants

• Gene Flow

• Microorganisms

• Biological Diversity

Human Health Considerations:

• Consumer Health

• Worker Safety

Animal Feed Considerations:

Socioeconomic Considerations:

• Domestic Economic Environment 

• Trade Economic Environment

7
2 AFFECTED ENVIRONMENT

The Affected Environment Section provides a discussion of the current conditions of those

aspects of the human environment potentially impacted by a determination of nonregulated status 

of MON 87712 soybean. For the purposes of this EA, those aspects of the human environment 

are: soybean production practices, the physical environment, biological resources, public health, 

animal feed, and socioeconomic issues.

2.1 Agricultural Production of Soybean

Soybean (Glycine max (L.) Merr.) is an economically important leguminous crop, providing oil

and protein. Soybean plants are grown for their seed, which is further processed to yield oil and

meal. Soybean in 2013 is ranked number one for oil production (58%) among the major oil seed

crops production in the world (USDA-FAS, 2013). Other expanding uses for soybeans in the 

United States include soy biodiesel, animal agriculture, exports, and edible soybean oil (USB, 

2012).

2.1.1 Acreage and Area of Soybean Production

As of 2007, there were about 406 million acres of cropland in the United States, of which 

approximately 332 million acres (including harvested, failed crops, and cultivated fallow) were 

used for crop production (USDA-NASS, 2009). The remaining cropland was either idle or was 

used for pasture. In 2007, total U.S. cropland reached its lowest level since 1945, attributed to 

large swings in production levels and in land idled under Federal acreage reduction programs

(USDA-ERS, 2012a). Peaks in total cropland occurred in 1949, again in the late 1970s, and 

decreased again in 2007, mostly due to a 26-million-acre decline in cropland pasture and partly 

due to methodological changes in the 2007 Census of Agriculture that reclassified some cropland 

pasture to permanent grassland pasture and range (USDA-ERS, 2011e). 

Soybean acreage rose rapidly from the end of World War II to the late 1970s, based on increased 

demand for vegetable oil and higher meat consumption (USDA-ERS, 2006c). U.S. soybean acres 

stagnated in the 1980s largely due to farm programs for other crops. In the 1990s, changes in 

farm programs, overseas demand, lower production costs associated with herbicide-resistant 

crops, increased yields and increased rotations with corn resulted in increased acreage planted to 

soybeans (USDA-ERS, 2006). From 1992 to 2012, acreage planted with soybean increased 31%

from just over 59.1 million acres to approximately 77.2 million acres (Figure 1, Table 1) 

(USDA-NASS, 2012l; USDA-NASS, 2012j). The combined acreage planted to the two largest 

U.S. crops, corn and soybeans, was at an all-time high of 168.8 million acres in 2011 (USDAERS, 2011f). This was achieved through maximization of existing cropland, reduction of acreage 

sown to other grain crops and hay, and an increase in the rate of double-cropping (raising two 

crops in one year on the same land) (USDA-ERS, 2011f). Approximately 75.7 million acres of 

soybean were harvested in the United States in 2012, up nearly 1.9 million acres or 2.5% from 

2011 (USDA-NASS, 2012g). USDA projections to 2021/2022 estimate U.S. soybean acreage 

will remain relatively steady at approximately 76 million acres (USDA-OCE, 2012)

The majority of soybeans produced in the United States are grown in 31 states (Figure 2, Table 

1). The top producing states are Iowa, Illinois, Minnesota, Indiana, and Nebraska, commonly 

8
growing soybean in rotation with corn (Soyatech, 2011). U.S. soybean acreage is concentrated 

where soybean yields are highest, namely the Midwest (USDA-ERS, 2006c). More recently, 

soybean acreage has expanded to the northern and western parts of the country due to stagnant 

yields in wheat and improvements in better yielding short-season soybeans adapted to the 

climate in these areas (USDA-ERS, 2010b), increasing the overall acreage devoted to soybean 

production in the U.S.

Over the last 20 years, soybean production has increased 35.6%, from nearly 2.2 billion bushels 

(59.88 million metric tons[MT]) in 1992 to approximately 3.0 billion bushels (81.7 million MT) 

in 2012 (USDA-NASS, 2012j). From 1991 to 2011, average yield increased approximately 

17.6% from 34.2 bushels per acre in 1991 to 41.5 bushels per acre in 2011, but declined 

nationally in 2012 to 39.3 bushels per acre compared to 2011 average yields (USDA-NASS, 

2012j). 

USDA agricultural projections for 2021/2022 estimate about 3.6 billion bushels (97.99 million 

MT) will be produced, of which approximately 2.1 billion bushels (57.16 million MT) of 

soybean will be produced for domestic consumption and 1.6 billion bushels ( 43.55 million MT) 

for export in that year (USDA-OCE, 2012).

Source: (USDA-NASS, 2012h)

Figure 1. Planted and harvested acreage of soybeans in the 

United States. (1992-2012).

9
Table 1. U.S. soybean production in 2011 and 2012.

State

Acres Planted

(x 1,000)

Acres Harvested

(x 1,000)

2011 2012 2011 2012

Alabama 300 330 295 325

Arkansas 3,330 3,250 3,270 3,200

Delaware 170 180 168 178

Florida 18 25 16 23

Georgia 155 190 135 180

Illinois 8,900 8,600 8,860 8,570

Indiana 5,300 5,000 5,290 4,990

Iowa 9,350 9,500 9,230 9,440

Kansas 4,000 3,600 3,750 3,550

Kentucky 1,490 1,400 1,480 1,390

Louisiana 1,020 1,140 980 1,110

Maryland 470 480 465 475

Michigan 1,950 2,000 1,940 1,990

Minnesota 7,100 7,000 7,020 6,920

Mississippi 1,820 2,130 1,800 2,100

Missouri 5,350 5,300 5,200 5,250

Nebraska 4,900 5,100 4,830 5,050

New Jersey 88 95 86 93

New York 280 340 277 337

North Carolina 1,380 1,670 1,360 1,630

North Dakota 4,000 4,600 3,950 4,550

Ohio 4,550 4,600 4,540 4,590

Oklahoma 440 410 265 380

Pennsylvania 500 530 490 520

South Carolina 370 420 360 410

South Dakota 4,100 4,500 4,070 4,450

Tennessee 1,290 1,330 1,250 1,290

Texas 165 100 90 85

Virginia 560 550 550 540

West Virginia 20 20 19 19

Wisconsin 1,610 1,690 1,600 1,680

United States 74,976 76,080 73,636 75,315

Source: USDA-NASS (2012b)

10
Source: USDA-NASS (2012k)

Figure 2. Soybean planted acres by county for selected states, 2011.

Large scale field testing of GE crops began in the 1980s, but it was not until ten years later the 

first generation of GE varieties became commercially available (Fernandez-Cornejo and 

Caswell, 2006). Since GE soybeans’ initial commercial availability in 1996 (Fernandez-Cornejo 

and Caswell, 2006; USDA-ERS, 2011a), their use had expanded to 94% of the total U.S. 

soybean acreage by 2011, which was slightly reduced to 93% in 2012 (Table 2) (USDA-ERS, 

2012e). Currently, most commercially available GE soybean varieties are herbicide-resistant

(USDA-ERS, 2012e).

2.1.2 Agronomic Practices

Conventional farming in this document includes any farming system where synthetic pesticides 

and fertilizers may be used. Conventional farming practices cover a broad scope of activities,

ranging from only occasional use of synthetic pesticides and fertilizers to regular pesticide and 

fertilizer inputs. This definition of conventional farming also includes the use of GE varieties 

that are no longer subject to the regulatory requirements of 7 CFR part 340 or the plant pest 

provisions of the Plant Protection Act. 

11
Table 2. Percentage of soybean acreage planted with GE herbicide-resistant soybean varieties by state and for the United 

States.

State 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012

Arkansas 43 60 68 84 92 92 92 92 94 94 96 95 94

Illinois 44 64 71 77 81 81 87 88 87 90 89 92 90

Indiana 63 78 83 88 87 89 92 94 96 94 95 96 93

Iowa 59 73 75 84 89 91 91 94 95 94 96 97 97

Kansas 66 80 83 87 87 90 85 92 95 94 95 96 94

Michigan 50 59 72 73 75 76 81 87 84 83 85 91 91

Minnesota 46 63 71 79 82 83 88 92 91 92 93 95 91

Mississippi 48 63 80 89 93 96 96 96 97 94 98 98 95

Missouri 62 69 72 83 87 89 93 91 92 89 94 91 91

Nebraska 72 76 85 86 92 91 90 96 97 96 94 97 95

North Dakota 22 49 61 74 82 89 90 92 94 94 94 94 98

Ohio 48 64 73 74 76 77 82 87 89 83 86 85 86

South Dakota 68 80 89 91 95 95 93 97 97 98 98 98 98

Wisconsin 51 63 78 84 82 84 85 88 90 85 88 91 92

Other States1 54 64 70 76 82 84 86 86 87 87 90 92 93

United States 54 68 75 81 85 87 89 91 92 91 93 94 93

Source: USDA-ERS (2012e)

1

Includes all other states in the soybean estimating program

12
Cultivation

Soybean (Glycine max L.) is a member of the legume family that grows as an erect, bushy 

herbaceous annual (OECD, 2000). It is a quantitative short-day plant, flowering more quickly 

under short days (OECD, 2000). As a result, photoperiod and temperature responses are 

important in determining areas of specific cultivar adaptation. Soybean cultivars are identified 

based on geographic bands of adaptation that run east-west, determined by latitude and day 

length. In North America, there are 13 maturity groups (MGs) described, ranging from MG 000 

in the north (45° latitude) to MG X near the equator. Within each maturity group, cultivars are 

described as early, medium, or late maturing (OECD, 2000).

The soybean seed will germinate when the soil temperature reaches approximately 50 degrees 

Fahrenheit (°F) (10 degrees Celsius [°C]) and, under favorable conditions, seedlings will emerge 

within a five to seven day period. In new fields of soybean production, an inoculation with 

Bradyrhizobium japonicum, a nitrogen fixing bacterium that develops a symbiotic relationship 

with soybean, dramatically increases plant productivity (Pedersen, 2007; OMAFRA, 2011; 

Missouri-University-of-Science-and-Technology, No Date). Inoculation is necessary for 

optimum efficiency of the nodules that form on the root system (Berglund and Helms, 2003; 

Pedersen, 2007). In the 1990s, row spacing for planting soybean narrowed to seven inches to 

achieve greater yields and then more recently expanded to 15 inches to promote greater air 

circulation to reduce increased incidence of disease that impacts yields (USDA-ERS, 2010b).

Soybeans require more moisture to germinate than corn, and seed-to-soil contact is important for 

good early-season soybean growth. Adequate water supply is most important at planting time, 

during pod-filling, and seed filling (Hoeft et al., 2000). Soybeans require approximately 20- to 

25 inches of water during the growing season (Hoeft et al., 2000) to produce a relatively high 

yield of 40- to 50 bushels per acre (University of Arkansas, 2006). In regions of the United 

States that experience low amounts of rainfall during the growing season or during drought, 

soybean yields benefit from proper irrigation. In 2008, only 9% of harvested soybean acreage, 

approximating 12 million acres, was irrigated primarily in Nebraska, Arkansas, Mississippi, 

Missouri, and Kansas, states with 85% of the irrigated acres. A majority (approximately 73%) of 

U.S. irrigated soybean farms occur in the Missouri and Lower Mississippi Water Resource 

Regions (USDA-NASS, 2010; USDA-ERS, 2011b; USDA-NASS, 2011). In 2006, 

approximately 8.4 inches of water per irrigated acre was used, producing an average of over 51 

bushels per irrigated acre (USDA-ERS, 2011b). This yield was approximately 19.8% higher 

than the national average (42.9 bushels per acre) for that year (USDA-NASS, 2011). 

Soybean can grow in a diversity of environments, but the optimum soil pH is from 5.8 to 7.0 

(NSRL, No Date). Adequate levels of phosphorus, potassium, calcium, and magnesium, as well 

as other minor nutrients, are required for maximum soybean growth and yield. Given the ability 

of soybean to fix nitrogen from the air due to its symbiotic relationship with Bradyrhizobium, 

fertilizer nitrogen is not always needed for soybean production. In areas with increased amounts 

of salt or carbonates, or that have no past history of soybean production, nitrogen amendments 

prior to or at the time of planting have been shown to increase yield if soil tests reveal levels are 

not adequate (Franzen, 1999; Berglund and Helms, 2003). A common practice is to fertilize the 

previous year’s corn crop with enough phosphorus and potassium to allow for the subsequent 

soybean crop to be grown with no supplemental fertilizer (Franzen, 1999; Berglund and Helms, 

13
2003; Ebelhar et al., 2004). Calcium and magnesium are normally present in an adequate supply 

if the soil is near the optimum pH or recently treated with dolomitic limestone (Frank, 2000; 

Harris, 2011).

Crop Rotation

Crop rotation is the successive planting of different crops in the same field over a particular 

period of years. Crop rotation has the two primary goals of sustaining the productivity of the 

agricultural system and maximizing economic returns (Hoeft et al., 2000). Sustaining the 

agricultural system is achieved by rotating crops that may improve soil health and fertility with 

more commercially beneficial “cash crops.” Since soybean fixes nitrogen in soil, the yield of 

some crops following soybean, such as corn or wheat, may increase; moreover, the rotation of 

crops can effectively reduce disease, pest incidence, weediness, and selection pressure for weed 

resistance to herbicides (USDA-ERS, 1997; Berglund and Helms, 2003). Crop rotation may also 

include fallow periods, or sowing with cover crops to prevent soil erosion and to provide 

livestock forage between cash crops (Hoeft et al., 2000; USDA-NRCS, 2010a). Maximizing 

economic returns is realized by rotating crops in a sequence that efficiently produces the most 

net returns for a producer over a single or multi-year period. Many factors at the individual farm 

level affect the crop rotation system chosen, including the soil type present in an individual field, 

the expected commodity price, the need to hire labor, the price of fuel, the availability of funding 

to buy seed, and the price of agricultural inputs (Langemeier, 1997; Hoeft et al., 2000; Duffy, 

2011).

Soybeans are often rotated with such crops as corn, winter wheat, spring cereals, and dry beans 

(OECD, 2000), the selection of which varies regionally. Cropland used for soybean and corn 

production is nearly identical in many areas, such as Illinois, where over 90% of the cropped area 

is planted in a two-year corn-soybean rotation (Hoeft et al., 2000). As of 2006, the USDA 

identified approximately 94% of U.S. soybean acres as grown under a rotation system (USDAERS, 2013c). With the recent high corn prices, many producers are turning to a corn-cornsoybean rotation (Hart, 2006), but returns for producers are variable, dependent upon the price 

and projected yield of both corn and soybean for an individual operator (Stockton et al., 2007). 

Studies have found soybean yield tends to increase under this rotation sequence, attributed to an 

effective break in the soybean disease and pest cycle (Nafziger, 2007; Al-Kaisi, 2011). Soybean 

itself may be a cover crop in short rotations for its nitrogen contributions (Hoorman et al., 

2009a). Continuous soybean production is undertaken, but yield can be reduced the second or 

later years, and pest and disease incidence may increase (Pedersen et al., 2001; Monsanto, 

2010c). Double cropping soybeans is also an option to increase returns. Soybean is frequently 

planted in winter wheat stubble to produce a crop in the same growing season. 

More recently, Monsanto evaluated soybean rotational practices using 2008 USDA-NASS crop 

production data (Monsanto, 2010a). They found the majority of U.S. soybean acreage (68.6%) 

was rotated to corn. Other major crops following soybean were soybean (approximately 14.5%

of soybean acreage) and wheat (approximately 11.2% of soybean acreage), with cotton, rice, and 

sorghum the next largest rotational crops (combined 4.6% of soybean acreage). Summaries of

the total rotation percentage is complicated by agency inclusion or exclusion of soybean that is 

double-cropped following wheat, and of the specific states included within the summary. Figure 

3 charts the acreage of major rotational crops following soybean in the United States Midwest 

(Illinois, Indiana, Iowa, Kansas, Kentucky, Michigan, Minnesota, Missouri, Nebraska, North 

14
Dakota, Ohio, South Dakota, Wisconsin), Southeast (Alabama, Arkansas, Georgia, Louisiana,

Mississippi, North Carolina, Tennessee, South Carolina), and East Coastal (Delaware, 

Maryland, New Jersey, Pennsylvania, Virginia) regions in 2008. In the Midwest, where 82% of 

U.S. soybean was grown in 2008, the crops planted most often after soybean included corn, 

wheat, and soybean. Soybean most frequently followed soybean in the Southeast, with corn and 

cotton the next most prevalent rotational crops. Corn was most often rotated after soybean in the 

East Coastal region, with wheat and then soybean the other most frequently planted rotational 

crops (Monsanto, 2010a). 

Double-cropping maximizes profits if high commodity prices can support it, but careful 

management to achieve uniform stands to sustain high yields is needed: the selection of 

appropriate varieties, a higher seeding rate, closer row spacing, and adequate moisture for 

germination are important variables affecting profitability (McMahon, 2011).

Tillage

Tillage in soybean production systems is used to prepare a seedbed, address soil compaction, 

incorporate fertilizers and herbicides, manage water movement both within and out of a 

production field, and control weeds (Heatherly et al., 2009), depending on tillage type. Field 

preparation is accomplished through a variety of tillage systems, with each system defined by the 

remaining plant residue on the field. Types of tillage systems include conventional, reduced, 

conservation (including mulch-till, strip-till, ridge-till, and no-till), and deep. Multiple 

definitions of these tillage systems are abundant (Heatherly et al., 2009); however, the primary 

purpose of conservation tillage is to reduce soil erosion.

In conventional tillage, post-harvest crop residue is plowed into the soil using moldboard plows, 

heavy disks, and chisel plows to prepare a clean seedbed for planting and to reduce the growth of 

weeds, leaving less than 15% of crop residue on the surface (Heatherly et al., 2009; Towery and 

Werblow, 2010). Conservation tillage employs tools that disturb soil less and leave more crop 

residues on the surface (at least 30%), whereas no-till farming only disturbs the soil for planting 

seed (USDA-NRCS, 2005; Towery and Werblow, 2010). Crop residues are materials left in an 

agricultural field after the crop has been harvested, including stalks and stubble (stems), leaves 

and seed pods (USDA-NRCS, 2005). These residues aid in conserving soil moisture and reduce 

wind and water-induced soil erosion (USDA-ERS, 1997; USDA-NRCS, 2005; Heatherly et al., 

2009). According to USDA Agricultural Resource Management Survey (ARMS) data (USDAERS, 2006b), conservation tillage ranging from no-till to reduced-till conserving 15 to 30% of 

residues was utilized on 88% of planted soybean acres in 2006. No-till systems are not meant to 

control weeds or deal with compaction issues, necessitating the addition of other strategies such 

as herbicidal weed control and track management of heavy machinery use in no-till fields to 

address these problems.

15
Source: Monsanto (2010a)

Note: Midwest is defined as Illinois, Indiana, Iowa, Kansas, Kentucky, Michigan, Minnesota, Missouri, Nebraska, North 

Dakota, Ohio, South Dakota, and Wisconsin. Southeast is comprised of Alabama, Arkansas, Georgia, Louisiana, 

Mississippi, North Carolina, Tennessee, and South Carolina; and East Coastal region consists of Delaware, Maryland, 

New Jersey, Pennsylvania, and Virginia

Figure 3. Major rotational crops following soybean in 2008 in the United States and the Midwest, Southeast, and 

East Coastal regions.

16
Since 1996, the use of a no-till system has increased more than any other reduced tillage system; 

nearly all of the growth in adoption has occurred in herbicide-resistant crop production (i.e., 

soybean, cotton, canola) (Fawcett and Towery, 2002). In a survey conducted in 1997, it was 

found that farmers using no-till practices were more likely to adopt herbicide-resistant soybeans 

as an effective weed control practice; although the study also found that the commercialization of 

herbicide-resistant soybean did not encourage the adoption of no-till practices at that time. 

Another survey conducted between 1996 and 2001 found that producers using herbicide-resistant 

seed varieties were more likely to both use conservation tillage practices over conventional 

methods and practice conservation tillage to a greater degree than producers that did not use 

herbicide-resistant crops (Fawcett and Towery, 2002). A survey of 1,195 producers conducted 

by Givens et al. (2009) between November 2005 and January 2006 revealed that 25% of farmers 

that had been using conventional tillage switched to no-till and 31% switched to reduced-till after 

adopting GE crops that were glyphosate resistant. 

With the increase in production of glyphosate-resistant soybeans, there has been a corresponding 

increase in the use of no-till production practices (Carpenter et al., 2002; Sankula, 2006). From 

the introduction and commercial availability of glyphosate-resistant soybeans in 1996 to 2004,

the use of no-till practices increased by 64% (Sankula, 2006). Use of conservation tillage 

practices by U.S. soybean growers increased by 12 million acres (4.9 million hectares) from 51% 

in 1996 to 63% in 2008 (NRC, 2010). 

No-till soybean production is not suitable for all producers or areas. For example, no-till 

soybean production is less successful in heavier, cooler soils more typical of northern latitudes 

(Kok et al., 1997; NRC, 2010) where the potential for increased weed and insect pests and 

disease requires careful management (Peterson, 1997; Pedersen et al., 2001).

Agronomic Inputs

Agronomic inputs, including water, soil and foliar nutrients, inoculates, fungicides, pesticides, 

and herbicides, are used in soybean production to maximize yields (Hoeft et al., 2000; OECD, 

2000; Clevenger, 2010; OMAFRA, 2011). Irrigation provides essential water for growth where 

rainfall is insufficient or erratic. This issue is discussed in detail in Subsection 2.2.2, Water 

Resources, and the corresponding impacts analysis in Subsection 4.3.1, Soil Quality. Soil and 

foliar macronutrient applications to soybean primarily include nitrogen, phosphorous 

(phosphate), potassium (potash), calcium, and sulfur, with other micronutrient supplements such 

as zinc, iron, and magnesium applied as needed (Whitney, 1997; USDA-NASS, 2007a; NSRL, 

No Date). 

Nutrients, Fertilizer

Fertilizer and nutrients may be applied to the soil or sprayed on foliage in soybean production. 

Soil fertilizers have differential availability to plants based upon soil characteristics and 

moisture. For example, in a drought year, potassium may become fixed between clay layers until

water moves through the soil again (Corn and Soybean Digest, 2012). Fertilizer such as nitrogen, 

potassium and phosphorous may be incorporated into the soil at soybean planting by tillage or 

drilling (Vitosh et al., 2007). Fertilizer may be purposefully concentrated in bands at varying 

depths in the soil to enhance nutrient availability at different growth stages (Vitosh et al., 2007; 

Fernandez and White, 2012). In conservation tillage crop production, phosphorous and 

potassium may become vertically stratified from use of surface broadcast fertilizers that 

17
minimize soil disturbance; hence, more farmers are turning to strip till practices to enhance 

nutrient availability to sustain higher yields (Fernandez and White, 2012). 

The amount of nutrients removed from the soil by soybean production depends upon the planting 

population and yield. On average, soybean removes 0.85 1bs of phosphate (phosphorous) and 1.2 

lbs of potash (potassium) per bushel of seed produced (CAST, 2009a). Table 3 presents removal 

rates of nitrogen, phosphate and potassium for soybean, and corn and wheat that are commonly 

rotated with soybean, as reported by the Michigan State University Extension (Silva, 2011). 

Although the data presented show soybean removes more nitrogen, potassium and phosphorous 

than either corn or wheat, a typical corn yield is 180 bushels per acre as opposed to a typical 

soybean yield of 42 bushels per acre and 46 bushels per acre for wheat. Table 4 compares 

soybean nutrient removal at different bushels per acre yield rates, indicating the higher the yield, 

the more nutrients are removed from the soil (Snyder, 2000). As discussed in Section 2.1.2.1, 

Cultivation, soybean fixes nitrogen in the soil in symbiosis with rhizobium bacteria. Recent 

research summarized by the Council for Agricultural and Science Technology indicates nitrogen 

supplementation supplants rather than supplements natural cost-free nitrogen production in 

soybean cultivation, as the size, weight, and number of nitrogen-producing nodules formed on 

soybean roots are actually reduced (CAST, 2009a). Application of nitrogen under drought 

conditions, in acid subsoil conditions, in soils having low residual nitrogen, in a high-yield 

environment, or in late or doublecrop plantings has raised soybean yields but not enough to 

offset the added cost. Phosphorous should be applied at least at the crop removal rate and based 

upon regular soil testing. Soil test levels of potassium may change considerably from one testing

time to the next, and so it too should be regularly monitored to continuously support optimum 

yields (CAST, 2009a). 

Soybean is often grown in rotation with corn and the nutrient supplements applied to corn are 

often adequate to produce soybean the following year without additional supplementation

(Bender et al., 2013), making it more economical to apply nutrients such as nitrogen, potassium 

and phosphorous ahead of the corn crop in two-year corn-soybean rotations (CAST, 2009a). 

Other research has found that annual supplementation of potassium and phosphorous is most 

beneficial in the south where soybean to soybean rotation is more common (Heatherly, 2012).

Corn and soybean take up nutrients and both localize each mineral nutrient in different parts of 

the plant cell (Mallarino et al., 2011). In plants, potassium is located mainly in the cytoplasm of 

cells and cell vacuoles where it activates enzymes, regulates stomata functions, and assists in 

transfer of compounds across membranes. In contrast, most phosphorous is located in cell 

membranes and nucleic acids, is incorporated into plant organic matter, and is a major 

component of the energy compounds that drive photosynthesis and plant metabolism in general. 

Much more potassium than phosphorous is absorbed by plants, and a larger proportion of 

phosphorous is found in the grain than potassium.

18
Table 3. Nutrient removal rates per unit of yield by soybean and grain crops

commonly rotated with soybean.

Crop Nitrogen Potash Phosphate

Pounds Removed per Bushel Produced

corn 0.9 0.37 0.27

soybean 3.8 0.8 1.4

wheat 1.2 0.63 0.37

Source: Silva (2011)

Table 4. Soybean nutrient removals at differing rates of grain bushels per acre yields.

Bushels Per 

Acre Yield

Nitrogen Potash Phosphate Magnesium Sulfur

Pounds Per Acre Removed From Soil

40 220 38 140 16 14

55 290 53 190 22 18

70 360 67 220 28 22

Source: Snyder (2000)

Some portion of these nutrients taken up by the crop from the soil may be returned by retaining 

plant residue such as corn stalks and soybean foliage in the field (Mallarino et al., 2011).

However, by maturity, soybean seed contains approximately 65% of the nitrogen, 73% of the 

phosphorous, and 55% of the potassium taken up during the season (Snyder, 2000); thus,

harvesting the seed removes considerable portions of nutrients from the field.

Bender et al. (2013) have recently evaluated the nutrient uptake of modern, higher yielding

transgenic insect-resistant corn varieties in Iowa and found average applications of phosphorous 

to these modern varieties would deplete this nutrient to inadequate levels for following soybean 

crops if not supplemented. Further research by the International Plant Nutrition Institute has 

indicated an increasing percentage of United States and Canadian soils have dropped to levels 

near or below critical phosphorous, potassium, sulfur and zinc levels in the last five years (Fixen 

et al., 2010), attributed to producing increased yields of field crops. Another study has shown 

micronutrient (manganese, boron, zinc) depletion may be higher with increased soybean yields 

but the amounts documented were highly variable, reflective of management and environmental 

factors, and were insignificant in comparison to potassium and phosphorous removal (Mallarino 

et al., 2011).

Table 5 presents summary data of the latest available USDA chemical fertilizer usage statistics 

from a 2006 survey reported by USDA National Agricultural Statistics Service (NASS) (USDANASS, 2007a). The survey found that among 19 select states, nitrogen was applied to 18% of 

the planted soybean acreage in those states at an average rate of 16 pounds per acre (lb/A) per 

year, and phosphate was applied to 23% of the planted acres at an annual average rate of 46 lb/A. 

19
Potash was applied to 25% of the planted acreage at an average annual rate of 80 lb/A, and sulfur 

was applied to 3% of the planted acres at an average annual rate of 11 lb/A (USDA-NASS, 

2007a). These supplements were applied on average only once per crop year. The relatively low

rate of soybean nutrient supplementation is likely a function of most soybean being rotated after 

corn that has had sufficient nutrients applied to sustain the subsequent soybean crop.

Table 5. Soybeans: total fertilizer primary nutrient applications in program states,

2006.

Primary 

Nutrient

Area Applied

(Percent)

Applications

(Number)

Rate per 

Application

(Pounds per 

Acre)

Rate per Crop 

Year

(Pounds per 

Acre)

Total Applied

(Million 

Pounds)

Nitrogen 18 1.1 15 16 212.40

Phosphate 23 1.0 45 46 772.80

Potash 25 1.0 79 80 1,454.70

Sulfur 3 1.1 10 11 20.00

Source: USDA-NASS (2007a)

Inoculates

As mentioned above, inoculates of the bacteria B. japonicum can increase soybean yields, 

estimated at an average of a bushel per acre (Conley and Christmas, 2005). Historically, a 

nonsterile peat powder applied to the seed at planting had been the carrier for the inoculant into 

the field. More recently, improvements have been made in inoculant manufacturing, such as the

use of sterile carriers, the addition of adhesives for inoculates to stick to seed, the introduction of

liquid carriers, the use of concentrated frozen products, the introduction of new organism strains, 

the use of pre-inoculants, and the introduction of inoculants with extended biofertilizer and 

biopesticidal properties (Conley and Christmas, 2005). Industry has estimated that about onethird of U.S. soybean acreage was inoculated in 2009 (Seed Today, 2009). 

Pesticides

A wide variety of pests can hinder soybean production and many require agricultural pesticidal 

inputs for their control. Several groups and types of insects can feed on the foliage, seed pods 

and roots of the soybean plant, and can reduce yield if not adequately controlled (Lorenz et al., 

2006; Whitworth et al., 2011). A major pest for soybean producers are soybean nematodes that 

have no effective pesticidal treatment, especially the soybean cyst nematode (Nelson, 2003). 

Nematodes are microscopic organisms, some of which feed on the roots of various plants, 

including soybeans. There are several races or different groups of nematodes and their control is 

difficult. Some soybean varieties have resistance to some of the races, but often these resistant 

varieties have yielded less than other commercially available soybean varieties. A combination 

of crop rotation to a non-susceptible host and the use of resistant varieties can help alleviate the 

problem (Nelson, 2003). 

Insect infestation thresholds have been established to indicate when control measures are actually 

necessary (Higgins, 1997). The thresholds are commonly based on number of insects found in 

20
field sampling surveys and in established standard defoliation thresholds, such as those provided 

by the National Information System of the Regional Integrated Pest Management Centers in pest 

management strategic plans (USDA, 2011). Table 6 presents summary data of the latest 

available USDA NASS chemical insecticide usage statistics for U.S. soybeans from a 2006 

survey (USDA-NASS, 2007a). The survey found that insecticides were applied to 16% of the 

Table 6. Soybeans: insecticide chemical applications in program states, 20061

. 

Insecticide Area 

Applied

(percent)

Applications

(number)

Rate per 

Application

(pounds per 

acre)

Rate per 

Crop Year

(pounds per 

acre)

Total 

Applied

(Million 

pounds)

Acephate 1 1.3 0.72 0.934 0.546

Benzoic acid <0.5 1.1 0.051 0.056 0.009

Carbaryl <0.5 1 0.633 0.633 0.091

Chlorpyrifos 5 1.1 0.454 0.48 1.663

Cyfluthrin <0.5 1.1 0.028 0.03 0.01

Diflubenzuron <0.5 1.7 0.037 0.062 0.01

Esfenvalerate 3 1.1 0.035 0.037 0.07

Gammacyhalothrin <0.5 1 0.011 0.011 0.003

Lambdacyhalothrin 6 1.1 0.02 0.021 0.097

Methyl parathion <0.5 1.1 0.529 0.565 0.066

Permethrin <0.5 1 0.065 0.065 0.012

Thiodicarb <0.5 1 0.32 0.32 0.039

Source: USDA-NASS (2007a)

1

Program states surveyed - Arkansas, Illinois, Indiana, Iowa, Kansas, Kentucky, Louisiana, Michigan, 

Minnesota, Mississippi, Missouri, Nebraska, North Carolina, North Dakota, Ohio, South Dakota, 

Tennessee, Virginia, and Wisconsin totaling 72.9 million planted acres.

72.9 million soybean acres planted in surveyed states in 2006. Of the 12 reported insecticides, 

the three most common, lambda-cyhalothrin, chlorpyrifos, and esfenvalerate, were applied to 

6%, 5%, and 3% of the planted acres, respectively (USDA-NASS, 2007a). Other methods of 

addressing insect infestations include crop rotation and tillage as discussed above, and efforts to 

conserve natural enemies that prey on principle insect pests. 

Fungicides

Several plant diseases can also reduce soybean yield, many of which are addressed by planting 

disease resistant cultivars, and relatively few that may be treated with fungicides. Diseases that 

afflict soybean include fungal, bacterial, and viral (Jardine, 1997). Diseases of major concern in 

soybean are Cercospora foliar blight, purple seed stain, aerial blight, soybean rust, pod and stem 

blight, and anthracnose (Padgett et al., 2011). Besides selecting cultivars with resistance to 

diseases prevalent in a producer’s particular region (Hershman, 1997), a healthy soybean crop 

21
starts with planting disease-free seed (Jardine, 1997), implementing best management practices 

such as crop rotation to reduce disease carryover from crop to crop, and providing adequate 

nutrients and water for growth (Nelson, 2011). Additionally, a grower may also purchase seed 

treated with various chemicals, such as fungicide, to enhance soybean seed germination success 

(Jardine, 1997). 

When disease does occur in soybean, despite taking such measures, chemical treatment options 

are fairly limited to those of fungal origin (Jardine, 1997; Padgett et al., 2011). USDA NASS 

(2007a) found that the most commonly applied fungicides on soybean (azoxystrobin, 

propiconazole, pyraclostrobin, tebuconazole, and trifloxystrobin) were applied to only 4% of the 

2006 U.S. soybean planted acreage in the 19 states surveyed. Pyraclostrobin and azoxystrobin 

were the only two applied on more than 0.5% of the planted acres. Pyraclostrobin was applied to 

2% of the planted acres at an average rate of 0.112 lb/A per year, whereas, azoxystrobin was 

applied to 1% of planted acres at an average rate of 0.106 lb/A per year (USDA-NASS, 2007a).

Herbicides

The presence of weeds in soybean fields is a primary detriment to soybean productivity. Weeds 

have been estimated to cause a potential yield loss of 37% in world-wide soybean production 

(Heatherly et al., 2009). Weeds compete with soybean for light, nutrients, and soil moisture; can 

harbor insects and diseases; and, can also interfere with harvest, causing extra wear on harvest 

equipment (Loux et al., 2008). In addition to weed density, the time period that weeds compete 

with the soybean crop influences the level of yield loss. The later the weeds emerge, the less 

impact they will have on yield. Soybean plants withstand early-season weed competition longer 

than corn, as the soybean canopy closes earlier (Boerboom, 2000). The extent of canopy closure 

restricts the light available for weeds and other plants growing below the soybean. In addition, 

canopy closure occurs more quickly when soybean is drilled or planted in narrow rows 

(Boerboom, 1999); however, in some studies it has also been observed that, depending on factors 

such as weed species, environmental conditions (i.e., rainfall amounts), and soybean cultivar, 

soybeans are able to compete with weeds with no resulting yield reduction (Krausz et al., 2001). 

Place et al. (2011) have determined that larger soybean seeds produce a larger canopy more 

quickly and are, therefore, more successful at outcompeting weeds.

Herbicides have been the primary tactic to manage weed communities in soybeans since the mid1960s and will continue to be an important feature of row crop weed management for the 

foreseeable future. One study looked at aggregate data on crop yield losses and herbicide use 

and estimated that even if additional tillage and hand weeding labor replaced the use of 

herbicides, U.S. crop production would decline by 20% with a $16 billion loss in value if 

herbicides were not used (Gianessi and Reigner, 2007). 

In selecting an herbicide, a grower must consider, among other factors, whether an herbicide can 

be used on the crop (herbicides are registered by the EPA for specific uses and crops, the 

potential adverse effects on the crop, residual effects that can limit crops that can be grown in 

rotation, effectiveness on expected weeds, and cost. Herbicides have different ways of acting on 

plant physiology (i.e., modes of action) to affect the health of a given plant. Some common 

modes of herbicide action include auxin growth regulators like 2,4-D; amino acid inhibitors such 

as glyphosate; photosystem II inhibitors such as metribuzin; lipid biosynthesis inhibitors like 

quizalofop; and inhibition of protoporphyrinogen oxidase (PPO) inhibitors like fomesafen 

22
(University of Wisconsin, No Date). Herbicides may be applied pre-plant (or “burndown” in notill), pre-emergence post-emergence and post-harvest.

Table 7 presents the most commonly applied herbicides to soybean in 1995, 2001, and 2006, the 

latest year with available national statistics and the corresponding percent of acres treated 

(USDA-NASS, 2007b). Figure 4 graphs the usage trends of the top 10 herbicides included in 

Table 7 in terms of percent planted acres treated. Glyphosate has become the most often-used 

herbicide on U.S. soybean, while the use of other herbicides has decreased. In 2006, nearly 92 

million lbs of glyphosate were applied to 92% of the planted acres, compared to only 21% of 

planted soybean acres in 1995. Prior to 1995, glyphosate was primarily used for pre-plant weed 

control in soybean (Young, 2006). After 1995, annual glyphosate usage increased due to postemergence application on Monsanto’s Roundup Ready® Soybean (GTS 40-3-2), which became 

commercially available to growers in 1996.

23
Table 7. Percent of U.S. soybean acres1 treated with herbicides in 1995, 2001, 2006

and 2012.

Herbicide 1995 2001 2006 2012 Herbicide 1995 2001 2006 2012

2,4-D2 10 4 3 4 Fomesafen 4 7 2 8

2,4-D 2HE 1 --3 7 11 Glufosinate -- -- -- 3

Acetamide -- <1 <1 -- Glyphosate 21 73 92 98

Acifluorfen -- 3 <1 1 Imazamox -- 5 <1 --

Alachlor 4 <1 <1 -- Imazaquin 15 2 1 --

Acifluorfen -- 3 <1 1 Imazethapyr 4 9 3 5

Atrazine -- -- -- -- Lactofen 5 1 <1 2

Bentazon 12 1 <1 -- Linuron 2 -- -- --

Butoxy ester 2,4-D -- -- <1 -- Metolachlor 7 <1 -- --

Carfentrazone ---- ---- <1 -- Metribuzin 11 2 2 3

Chlorimuron 16 5 4 11 Paraquat 2 -- 1 3

Clethodim 5 4 3 9 Pendimethalin 26 10 3 2

Clomazone 4 <1 -- -- Quizalofop 6 -- -- 2

Cloransulam -- 5 1 4 S-Metolachlor -- <1 1 7

Dimethenamid 1 -- -- 1 Saflufencil -- -- -- 4

Ethalfluralin 1 -- -- -- Sethoxydim 7 1 <1 --

Fenoxaprop 6 3 <1 <1 Sulfentrazone -- 5 1 8

Fluazifop 10 3 1 3 Sulfosate -- 3 1 --

Flumetsulam 2 <1 <1 <1 Thifensulfuron 12 2 1 5

Flumiclorac -- <1 <1 1 Tribenuron -- -- 1 1

Flumioxazin -- -- -- 11 Trifluralin 20 7 2 2

Fluthiocetmethyl -- -- -- 2

Source: USDA-NASS, (2007b); USDA (2013)

1

Survey states:

1995: Arkansas, Georgia, Illinois, Indiana, Iowa, Kentucky, Louisiana, Minnesota, Mississippi,

Missouri, Nebraska, North Carolina, Ohio, and Tennessee.

2001: Arkansas, Illinois, Indiana, Iowa, Minnesota, Missouri, Nebraska, and Ohio.

2006: Arkansas, Illinois, Indiana, Iowa, Kansas, Kentucky, Louisiana, Michigan, Minnesota, 

Mississippi, Missouri, Nebraska, North Carolina, North Dakota, Ohio, South Dakota, Tennessee, 

Virginia, and Wisconsin.

2

Dimethylamine salt formulation of 2,4-D

3

-- = No value

The next herbicide most frequently applied to soybean acres was 2,4-D in several formulations, 

with just over 3.5 million lbs (1.6 million kg) applied to 10.5% of the planted soybean acres in 

2006, and the majority of the herbicide was for preplant burndown (USDA-NASS, 2007a). 

Applied 2,4-D increased slightly to 15% of acres in 2012 (Figure 8). Figure 4 also shows that, 

24
while glyphosate-applied acres increased for the period, the number of acres on which other 

herbicides were applied significantly declined, as has been noted previously by others (Young, 

2006; NRC, 2010). The widespread adoption of the glyphosate-resistant soybean cultivar, in 

tandem with an increased reliance on glyphosate, has been related to the ability to grow no-till 

soybean cultivation while effectively controlling weeds, simplifying weed control compared to 

past practices, reducing input and labor costs associated with the cultivar and glyphosate use, and 

allowing increased flexibility in timing herbicide applications to resistant soybean (Young, 

2006). In 2006, based on soybean farmers surveyed in selected states, it was estimated that 98%

of the planted soybeans were treated with at least one type of herbicide, ranging from 0.004 to 

1.931 lb/A per crop year (Table 8) (USDA-NASS, 2007a).

25
Figure 4. Percent of U.S. soybean acres in program states1 treated with 10 most used 

herbicides in 1995, 2001 and 2006.

Source: USDA-NASS (2007b)

1

Survey states:

1995: Arkansas, Georgia, Illinois, Indiana, Iowa, Kentucky, Louisiana, Minnesota, Mississippi, 

Missouri, Nebraska, North Carolina, Ohio, and Tennessee.

2001: Arkansas, Illinois, Indiana, Iowa, Minnesota, Missouri, Nebraska, and Ohio.

2006: Arkansas, Illinois, Indiana, Iowa, Kansas, Kentucky, Louisiana, Michigan, Minnesota, 

Mississippi, Missouri, Nebraska, North Carolina, North Dakota, Ohio, South Dakota, Tennessee, 

Virginia, and Wisconsin.

0

10

20

30

40

50

60

70

80

90

100

1995 2001 2006

Percent of Treated Acre s 

Year

2,4-D Dimethylamine salt

2,4-D Acetic acid

Bentazon

Chlorimuron, ethyl

Glyphosate

Imazaquin

Imazethapyr

Metribuzin

Pendimethalin

Trifluralin

26
Table 8. Soybeans: total herbicide applications, 20061

.

Herbicide Area 

Applied 

(percent)

Applications 

(number)

Rate Per 

Application 

(pounds per 

acre)

Rate Per 

Crop Year 

(pounds 

per acre)

Applied 

(thousand 

pounds)

2,4-D, 2-EHE 7 1 0.493 0.503 2,505

2,4-D, BEE <0.5 1.1 0.426 0.459 68

2,4-D, dimeth. salt 3 1 0.462 0.475 953

Acifluorfen, 

sodium 

<0.5 1 0.287 0.296 47

Alachlor <0.5 1 1.931 1.931 485

Bentazon <0.5 1 0.687 0.687 70

Carfentrazoneethyl <0.5 1.2 0.038 0.046 10

Chlorimuronethyl 4 1 0.017 0.017 52

Clethodim 3 1.1 0.096 0.102 190

Cloransulammethyl 1 1 0.019 0.019 17

Dicamba, digly 

salt 

<0.5 1 0.25 0.25 16

Fenoxaprop <0.5 1 0.031 0.031 9

Fluazifop-P-butyl 1 1 0.099 0.099 43

Flufenacet <0.5 1 0.265 0.265 80

Flumetsulam <0.5 1 0.048 0.048 8

Flumicloracpentyl 1 1.4 0.02 0.028 17

Flumioxazin 3 1 0.066 0.066 138

Fomesafen 2 1.2 0.19 0.233 330

Glyphosate 4 1.5 0.63 1.044 2,841

Glyphosate amm. 

salt 

<0.5 1.7 0.489 0.745 142

Glyphosate 

isop.salt 

92 1.5 0.802 1.33 88,903

Imazamox <0.5 1 0.03 0.03 9

Imazaquin 1 1 0.061 0.062 66

Imazethapyr 3 1 0.053 0.053 100

Imazethapyr, 

ammon 

<0.5 1 0.048 0.048 5

Lactofen <0.5 1 0.11 0.11 23

Metribuzin 2 1 0.255 0.26 437

Paraquat 1 1 0.492 0.511 335

Pendimethalin 3 1 0.92 0.926 1,894

27
Table 8. Soybeans: total herbicide applications, 20061 (continued).

Herbicide Area 

Applied 

(percent)

Applications 

(number)

Rate Per 

Application 

(pounds per 

acre)

Rate Per 

Crop Year 

(pounds 

per acre)

Applied 

(thousand 

pounds)

Quizalofop-Pethyl <0.5 1.1 0.038 0.041 14

S-Metolachlor 1 1 1.023 1.023 837

Sethoxydim <0.5 1 0.153 0.153 10

Sulfentrazone 1 1 0.087 0.091 70

Sulfosate 1 1.8 0.967 1.701 970

Thifensulfuron 1 1.1 0.004 0.004 3

Tribenuronmethyl 1 1 0.008 0.008 5

Trifluralin 2 1 0.818 0.818 1,454

Source:USDA-NASS (2007a)

1

Program states surveyed - Arkansas, Illinois, Indiana, Iowa, Kansas, Kentucky, Louisiana, Michigan, 

Minnesota, Mississippi, Missouri, Nebraska, North Carolina, North Dakota, Ohio, South Dakota, 

Tennessee, Virginia, and Wisconsin; totaling 72.9 million planted acres.

Herbicide usage trends since the adoption of GE crops are the subject of much debate, with 

initial assessments indicating a decline in herbicide use in the early years of herbicide-resistant

crop production (Carpenter et al., 2002) that some argue was then followed by an increase in the 

volume of herbicide usage as the technology spread (Benbrook, 2009). Others report a 

continuing decline in herbicide use with the adoption of GE crops (Fernandez-Cornejo and 

Caswell, 2006), or relative stability in the amount of herbicide active ingredients applied to 

soybeans (Brookes and Barfoot, 2010). The contradictory findings have been attributed to the 

different measurement approaches used by researchers, how different factors affecting pesticide 

use such as weather or cropping patterns were controlled for, and how the collected data was 

statistically analyzed (NRC, 2010).

Not unlike all agronomic practices, herbicides may impart selection pressures on weed 

communities resulting in shifts in the weed community that favor weeds that no longer respond 

to the herbicide used (Owen, 2008). In many instances, these weed community shifts are 

attributable to the evolution of herbicide-resistant weed biotypes. The shift to herbicide 

resistance in plants is largely a function of the natural selection of herbicide-resistant traits and is 

strongly related to the repeated use of one or a limited number of herbicides (Durgan and 

Gunsolus, 2003; Duke, 2005). Both the increased selection pressure resulting from the extensive 

use of glyphosate associated with glyphosate-resistant crops with subsequent reductions in the 

use of other herbicides and changes in weed management practices (i.e., conservation tillage or 

no-till) have resulted in weed population shifts and increasing glyphosate resistance among some 

weed populations (Duke, 2005; Owen, 2008). Glyphosate-resistant crops themselves do not 

influence weeds any more than non-transgenic crops. It is the weed control tactics chosen by 

growers that create selection pressure that ultimately over time change these weed communities 

and may result in the evolution of herbicide-resistant weeds (Owen, 2008). Herbicide-resistant 

weeds are discussed in more detail in Subsection 2.3.2, Plant Communities.

28
Currently, there are 396 herbicide-resistant weed biotypes described, which are represented in 

210 plant species (WSSA, 2013). The first herbicide-resistant biotypes were described in the 

1950s but the number of weeds resistant to herbicides increased dramatically in the 1980s and 

1990s, and currently evolved resistance to 21 different herbicide mechanisms of action is 

described (Heap, 2011). The management of glyphosate-resistant weeds has become a 

substantial issue for U.S. agriculture and in particular, soybean production, especially given 

reduced number of economically acceptable alternative management tactics (Powles, 2008a; 

Powles, 2008b; Owen, 2011). 

A variety of strategies have been proposed to help farmers avoid new development of

glyphosate-resistant weeds (Boerboom, 1999; Beckie, 2006; Sammons et al., 2007; Frisvold et 

al., 2009), including:

• The rotation of herbicides with different modes of action;

• Site specific herbicide applications; 

• Use of full labeled application rates; 

• Crop rotation;

• Use of tillage for supplemental weed control;

• Cleaning equipment between fields; 

• Controlling weed escapes;

• Controlling weeds early; and

• Scouting for weeds before and after herbicide applications.

Volunteer soybean is not a widespread problem, and when they occur, it is most often in parts of 

the Delta and the southeast United States. In production systems where soybean is rotated, it has 

shown up as a volunteer weed, yet was not generally seen as a substantial problem by farmers 

(Owen and Zelaya, 2005). Volunteer soybean is not considered difficult to manage, as soybean

seeds rarely remain viable the following season and any interference they may pose to 

subsequent crops are minimal; furthermore, herbicides usually used for weed control in corn are 

also effective at controlling volunteer soybean (Owen and Zelaya, 2005). Conversely, volunteer 

glyphosate-resistant corn in soybean is a greater concern (Owen and Zelaya, 2005). Glyphosate 

had been used to control all weeds, including the presence of corn in soybean fields, yet, the 

increase in cultivation of glyphosate-resistant corn has created problems for growers in the 

Midwest managing volunteer corn with glyphosate. Growers must now often include 

graminicides (herbicides to control weedy grasses) as part of their weed management strategy 

(Owen and Zelaya, 2005). 

Soybean Yield

Soybean production has increased 35.6%, from nearly 2.2 billion bushels (59.88 million MT) in 

1992, to approximately 3.0 billion bushels (81.66 million MT) in 2012 (USDA-NASS, 2012j). 

Increased soybean production in the United States has been accomplished by both increasing the 

area under cultivation and through yield increases per unit area. Based on recent trends in farm 

production and land area, soybean farmers will have the future challenge of expanding 

agricultural output by raising productivity on a stable or reduced land area (OECD-FAO, 2008). 

Much of the projected expansion in soybean production in the future is expected to come from 

increased yield rather than increased area under production (OECD-FAO, 2008).

29
Egli (2008) recently compared historical trends in U.S. corn and soybean yields from the early 

20th century to 2005. Soybean yield data was first available in 1924. He found soybean yield 

steadily increased over the period, as substantiated by data analyzed from 1924 to 2012, showing 

an average annual rate of 0.35 bushels per acre (Phillion, 2013 pers. comm.) (Figure 5).

Beginning about 1945, U.S. agriculture entered into a high input era of improved hybrids of corn 

and soybean (among other crops), manufactured nitrogen fertilizer (important to corn yield 

increases), herbicide use, and higher plant populations that continue in today’s practices. In the 

study states (Iowa, Illinois, Indiana, Kentucky, Missouri, and Tennessee), corn yield increased 

faster than soybean yield in the early high input era, but from 1950 to 2005, corn and soybean 

yields grew at comparable respective rates of 1.8% and 1.4% annually. Changes in soybean 

cultivars contributing to increased yields included longer seed filling periods, decreased lodging,

shorter plants, and increased disease resistance. Beneficial improved management practices such 

as mechanization, narrow-row planting, earlier planting, adoption of conservation tillage, 

increased weed control, and decreased harvest loss also contributed to increased yields (Egli, 

2008). Agricultural biotechnology has further enhanced crop yields through the introduction of 

new genetic elements that use or modify existing constituents or pathways in the plant. For 

example, De Bruin and Pedersen (De Bruin and Pedersen, 2008; De Bruin and Pedersen, 2009)

estimate soybean cyst nematode resistance of recent and currently available soybean cultivars 

produced yields ranging from 17% to 19% higher than comparative new non-resistant cultivars.

Figure 5. Soybean yield rose at an annual average rate of 0.35 bushels per acre

between 1924 – 2010. Linear regression analysis was conducted by Monsanto on data from 

the USDA-NASS (Phillion, 2013 pers. comm.).

Soybean maximum yield is determined by soybean genetics and this genetic yield potential is 

only achieved when environmental conditions are perfect. The concept of yield potential of 

soybean is defined as the yield of a cultivar when grown in environments to which it is adapted, 

with non-limiting amounts of nutrients and water, and with pests, diseases, weeds, lodging, and 

y = 0.3459x - 654.2

R2 = 0.9452

10

15

20

25

30

35

40

45

50

1920 1930 1940 1950 1960 1970 1980 1990 2000 2010

Seed Yield (bushels/ac)

Production Year

30
other stresses effectively controlled (Evans and Fischer, 1999; Specht et al., 1999). Some 

researchers have determined substantial gains in soybean yields is still possible through careful 

management practices, including selecting the right variety for a given field, taking steps early to 

manage cyst nematodes, optimizing planting time, proper row spacing, sound weed management, 

controlling pests, and ensuring appropriate soil fertility (Specht et al., 2006; Pedersen, 2008).

Research has shown an important factor in soybean yield is determined early in development by 

biomass production: row closure must be achieved by beginning pod set (R3) to maximize light 

interception during the critical pod and seed filling period to maximize yield (Pedersen, 2008). 

This is achieved by reducing stress from weeds, insects and pathogens and then planting early 

and in narrow rows. Early row closure is also critical to achieving higher yield because it reduces 

soil moisture loss. Other research evaluating the role of superoptimal seeding rates, narrow row 

spacing, seed inoculants, fungicide and insecticide seed treatments, additional soil fertilizers, 

foliar fertilizers, and foliar fungicides has found the single most important factor in achieving 

high soybean yields was row spacing (Naeve, 2012). Foliar fungicide applications were also 

important, and pre-plant supplementation of soil fertility was significantly beneficial in fields 

that tested with suboptimal fertility levels (Heatherly, 2012). While the study found that biennial 

application of potassium and phosphorous was beneficial in areas where corn is most often 

rotated with soybean, annual supplementation is recommended in the south where soybean to 

soybean rotation is more common (Heatherly, 2012).

Conventional high-yield soybean varieties are currently available from several seed companies 

such as Advantage Seeds’ ADV Heartbeat and OAC Quinte; Albert Lea Sheyenne and Viking 

lines; several D.F. Seeds’ varieties; and eMerge Genetics’ 348.TCS, e3782s, e45120s, and e5110 

varieties (Advantage Seeds, 2005; D.F. Seeds, 2011; Albert Lea Seeds, 2012; eMerge, 2012). 

Much of the breeding of conventional soybean varieties is accomplished by State University 

Extension Services such as The Ohio State University, Kansas State University, North Carolina 

State University, University of Arkansas, and University of Missouri (Pierzynski, 2009; North 

Carolina Soybean Producers Association, 2010; Shannon et al., 2010; The Ohio State University, 

No Date; University of Arkansas, No Date). There are also high yielding soybean cultivars 

available having herbicide or pest resistance or the combination of the two traits and include 

varieties such as Genuity Roundup Ready 2 Yield® (Monsanto), Liberty Link® (Bayer), and Y 

Series® (Pioneer), to name a few.

A world record maximum yield for soybean was achieved in Missouri in 2010 of 160.6 bushels 

per acre for irrigated soybean and 98.9 bushels per acre for non-irrigated soybean, where the 

statewide average yield in 2010 was 42 bushels per acre (Alsager, 2010). USDA projections 

through 2021/2022 show an average annual rate of increased average yields of 0.45 bushels per 

acre for the period 2012/2013 to 2021/2022, which results in an average U.S. yield of 46.05 

bushels per acre for the period (USDA-OCE, 2012). While USDA projects increasing yields, the 

projected rate of increase is lower than the past rate (for example, see USDA-OCE (2012)). 

Current and future factors that negatively affect yield increases are the expansion of soybean 

production into northern and western parts of the country, where yields are typically lower than 

in the core Midwestern production area, and a shift in some areas away from narrow rows to 

improve air circulation, which helps combat disease (USDA-ERS, 2012m). The U.S. average in 

2012 (a drought year in the Midwest) of 39.3 bushels per acre (USDA-NASS, 2012j) was 

substantially below the current estimate of yield potential, suggesting that there is an opportunity 

to close the gap between average annual yield performance and yield potential.

31
Actual yield performance is a complex outcome that is dependent on a number of genetic and 

environmental factors that influence a crop’s opportunity to realize its full yield potential. 

As shown in Figure 5, soybean yields can be highly variable from year to year, and yield varies 

geographically (Table 9) due to planting decisions and weather. From 1991 to 2011, average 

yield increased approximately 17.6% from 34.2 bushels per acre in 1991 to 41.5 bushels per acre 

in 2011, but declined nationally in 2012 to 39.3 bushels per acre compared to 2011 average 

yields (USDA-NASS, 2012j). In 2012, soybean average yields ranged as low as 23 bushels per 

acre in the Midwest and Great Plains to as high as 47 bushels per acre there and in the eastern 

coastal United States (USDA-NASS, 2012j) (Table 9), likely due to the drought impacting large 

areas of the central United States that year.

Table 9. 2012 average U.S. soybean productivity by region.

Region 2012 U.S. Soybean 

Acreage1

2012 Average Yield 

(bushels per acre)

Range of Average 

State Yields (bushels 

per acre)

Midwest/Great 

Plains1

64.3 38.2 23 – 47

Southeast2 10.1 38.8 32 – 44

Eastern Coastal3 2.2 43 40 – 47

Source: USDA-NASS (2012j)

1

U.S. soybean acreage – million acres

2

Indiana, Iowa, Kansas, Kentucky, Michigan, Minnesota, Missouri, Nebraska, North Dakota, Ohio, South 

Dakota Wisconsin 

3

Alabama, Arkansas, Georgia, Louisiana, Mississippi, North Carolina, South Carolina, Tennessee

4

Delaware, Maryland, New Jersey, New York, Pennsylvania, Virginia

Within a state there is considerable local variability, as, for example, in southern Nebraska, 

where the 2012 yields for Harlan and Kearney counties were 48 bushels per acre and 62 bushels 

per acre, respectively (USDA-NASS, 2012j). For another example, in two adjacent counties in 

Iowa, Plymouth and Cherokee, in 2012 the average soybean yield in Cherokee County (50.7 

bushels per acre) was 39% greater than the 2012 average yield in Plymouth County (36.4 bushels 

per acre) (USDA-NASS, 2012f). In 2011, on the other hand, the average soybean yield in 

Plymouth County had previously been 50.7 bushels per acre. Within each county between 2011 

and 2012, the average yield in Plymouth County decreased by 28% while the average yield in 

Cherokee decreased by only 4% (USDA-NASS, 2012f; USDA-NASS, 2012j). Since these values 

represent averages over counties, variation from farm to farm and within a farm from year to 

year would be expected to be even greater. Thus, even with the positive management decisions 

that were previously discussed, observed yield is highly variable, is dependent on many factors 

and likely rarely reaches the theoretical maximum yield potential.

2.1.3 Soybean Seed Production

In 2012, nearly 77.2 million acres of soybean required seed for planting in the United States

(USDA-NASS, 2012j). Several factors influence optimal planting rate for soybean such as row 

spacing, seed germination rate, soil conditions, climate, disease and pest pressure, past tillage 

practices and crop rotation (Robinson and Conley, 2007). Seeding rate is also determined by the 

32
plant population desired by the grower. In Iowa, the recommended planting rate for soybean 

ranges from 150,000 to 200,000 seeds per acre or between 37.5 and 100 lbs of seed per acre 

depending on seed size (Whigham, 1998). Seed sizes range from 2,000 to 4,000 seeds per pound 

(Whigham, 1998). Growers may plant certified soybean seed, uncertified seed, and “binrun” 

soybean seed that is grown and stored on individual farms (Oplinger and Amberson, 1986). 

Since 93% of the soybean acres planted in the United States in 2012 were GE varieties (see 

Table 2) (USDA-ERS, 2012e), about 71.8 million acres were planted with certified seeds. Using 

a conservative planting rate of 150,000 seeds per acre, an estimated 1.3 to 2.7 million tons of 

certified soybean planting seeds were required in 2012.

Between 1996 and 2006, corn and soybean seeds accounted for 55% of total seed expenditures;

within that timeframe, expenditures for soybean seed increased from 15% to 23% of total seed 

expenditures (Roucan-Kane and Gray, 2009). In addition, from 1985 to 2005, real seed costs per 

acre have steadily increased, with significant increases since 2000, likely due to new seed 

technologies that express plant protection traits (e.g., herbicide and insect resistance). From 

2000 to 2007, conventional, single-traited GE, and stacked GE seed cost trends were similar

(Figure 6); however, prices for conventional seeds were less expensive than GE seed (e.g., 

$0.36/lb and $0.58/lb in 2007 respectively) (Shi et al., 2009).

Figure 6. Nominal price trend of U.S. soybean seeds, 2000-2007(Shi et al., 2009).

Seed production differs from grain production due to additional biological, technical, and quality 

control factors required to maintain varietal purity. Genetic purity in the production of 

commercial soybean seed is regulated through a system of seed certification which ensures the 

desired traits in that particular seed remain within purity standards (Bradford, 2006). The 

production and certification of foundation, registered, certified, or quality assurance seeds are 

administered by state and regional crop improvement associations, several of which are chartered 

under the laws of the state(s) they serve (e.g., see Mississippi Crop Improvement Association, 

2008; Illinois Crop Improvement Association, 2013; SSCA, No Date-a; Virginia Crop 

Improvement Association, No Date). These agencies certify varietal purity and identity, while 

33
issues concerning germination and mechanical purity are governed under state and federal seed 

laws. Seed quality includes a variety of attributes, including genetic purity, vigor, weed seed 

content, seed borne diseases, and the presence of foreign material such as dirt or chaff (Bradford, 

2006). The genetic purity of the seed must be maintained to maximize the value of the new 

variety or cultivar (Sundstrom et al., 2002). Procedures required during seed production include 

such actions as maintaining seed tags as proof of seed origin and class; fields meeting cropping 

history, weed, and isolation requirements prior to planting; cultivation, transportation, and 

storage equipment meeting cleanliness requirements; field inspections accomplished by certified 

crop inspectors; inspection and laboratory analysis of harvested seeds from approved fields; and 

separating harvested seeds in storage (Mississippi Crop Improvement Association, 2008; South 

Dakota Crop Improvement Association, 2011; Illinois Crop Improvement Association, 2013; 

SSCA, No Date-a; Virginia Crop Improvement Association, No Date). In addition, there are also 

crop specific field, inspection, isolation, and harvested seed purity (e.g., percentage of pure seed, 

inert matter, weed seeds, other crop seeds, other variety seeds, and germination) standards in 

order to meet certification requirements (South Dakota Crop Improvement Association, 2011; 

Virginia Crop Improvement Association, 2013; SSCA, No Date-b)

The U.S. Federal Seed Act of 1939 recognizes seed certification and official certifying agencies. 

Implementing regulations further recognize land history, field isolation, and varietal purity 

standards for seed. States have developed laws to regulate the quality of seed available to 

farmers (Bradford, 2006). Most of the laws are similar in nature and have general guidelines for 

providing information on the label for the following:

• Commonly accepted name of agricultural seed;

• Approximate total percentage by weight of purity;

• Approximate total percentage of weight of weed seeds;

• Name and approximate number per pound of each kind of noxious weed seeds;

• Approximate percentage of germination of the seed; and

• Month and year the seed was tested.

Various seed associations have standards to help maintain the quality of soybean seed. The 

Association of Official Seed Certifying Agencies (AOSCA) (AOSCA, No Date) defines the 

classes of seed as follows:

• Breeder seed is directly controlled by the plant breeder that developed the variety.

• Foundation seed is the progeny of Breeder or Foundation seed that is handled to most 

nearly maintain specific genetic identity and purity.

• Registered seed is a progeny of Breeder or Foundation seed that is so handled as to 

maintain satisfactory genetic identity and purity.

• Certified seed is the progeny of Breeder, Foundation, or Registered seed that is so 

handled as to maintain satisfactory genetic identity and purity.

Seed certification systems should be distinguished from Identity Preservation (IP) systems for 

certain agricultural commodities. IP refers to a system of production, handling, and marketing 

practices used in order to maintain the integrity and purity of crop products throughout the food 

supply chain (Sundstrom et al., 2002). IP systems are utilized to meet the demands for 

34
specialized grains products, including those from crops with output-specific traits (e.g., high 

oleic oil), without specific traits or attributes (e.g., non-GE crops), grown under specific 

production methods (e.g., organic crops), and requiring rigorous safeguards and confinements 

practices (e.g., pharmaceutical and industrial crops) (Elbehri, 2007).

Soybean is self-pollinated, propagated commercially by seed (Hoeft et al., 2000; OECD, 2000). 

In the United States, there are no Glycine species found outside of cultivation, and the potential 

for outcrossing is minimal (OECD, 2000). Additionally, Minimum Land, Isolation, Field, and 

Seed Standards (7 CFR part 201.76) specify that isolation distances for the production of 

Foundation, Registered and Certified soybean seeds from any potential contaminating source 

must be adequate to prevent mechanical mixing. 

2.1.4 Organic Soybean Production

In the United States., only products produced using specific methods and certified under the 

USDA’s Agricultural Marketing Service (AMS) National Organic Program (NOP) definition of 

organic farming can be marketed and labeled as “organic” (USDA-AMS, 2008). Organic 

certification is a process-based certification, not a certification of the end product; the 

certification process specifies and audits the methods and procedures by which the product is 

produced.

In accordance with NOP, an accredited organic certifying agent conducts an annual review of the 

certified operation’s organic system plan and makes on-site inspections of the certified operation 

and its records. Organic growers must maintain records to show that production and handling 

procedures comply with USDA organic standards. 

The NOP regulations preclude the use of excluded methods. The NOP provides the following 

guidance under 7 CFR § 205.105:

...to be sold or labeled as “100 percent organic”, “organic” or “made with organic 

(specified ingredients or group(s)),” the product must be produced and handled 

without the use of: ...

(a) Synthetic substances and ingredients...

(e) Excluded methods...

Excluded methods are then defined at 7 CFR § 205.2 as:

A variety of methods used to genetically modify organisms or influence their 

growth and development by means that are not possible under natural conditions 

or processes and are not considered compatible with organic production. Such 

methods include cell fusion, microencapsulation and macroencapsulation, and 

recombinant deoxyribonucleic acid (DNA) technology (including gene deletion, 

gene doubling, introducing a foreign gene, and changing the positions of genes 

when achieved by recombinant DNA technology). Such methods do not include 

the use of traditional breeding, conjugation, fermentation, hybridization, in vitro 

fertilization, or tissue culture.

35
Organic farming operations, as described by the NOP, are required to have distinct, defined 

boundaries and buffer zones to prevent unintended contact with excluded methods from 

adjoining land that is not under organic management. Organic production operations must also 

develop and maintain an organic production system plan approved by their accredited certifying 

agent. This plan enables the production operation to achieve and document compliance with the 

National Organic Standards, including the prohibition on the use of excluded methods (USDAAMS, 2008). 

Common practices organic growers may use to exclude GE products include planting only 

organic seed, planting earlier or later than neighboring farmers who may be using GE crops so 

that the crops will flower at different times, and employing adequate isolation distances between 

the organic fields and the fields of neighbors to minimize the chance that pollen will be carried 

between the fields (NCAT, 2003). Although the National Organic Standards prohibit the use of

excluded methods, they do not require testing of inputs or products for the presence of excluded 

methods. The presence of a detectable residue of a product of excluded methods alone does not 

necessarily constitute a violation of the National Organic Standards (USDA-AMS, 2008). The 

current NOP regulations do not specify an acceptable threshold level for the adventitious 

presence of GE materials in an organic-labeled product. The unintentional presence of the 

products of excluded methods will not affect the status of an organic product or operation when 

the operation has not used excluded methods and has taken reasonable steps to avoid contact 

with the products of excluded methods as detailed in their approved organic system plan (Ronald 

and Fouche, 2006; USDA-AMS, 2008). 

Organic soybean production practices include crop rotation, use of cover crops, green and animal 

manures, application of rock minerals such as lime, other soil additives, mechanical weed 

control, biological control of pests, and disease control primarily through management practices 

(Kuepper, 2003; Heatherly et al., 2009; USDA-AMS, 2011). Utilizing 2006 ARMS data, 

McBride and Greene (2008) determined that more than 90% of organic soybean producers 

planted in standard rows (22-30”, (Coulter et al., 2010)), as compared to 60% of other soybean 

producers; further, organic soybean operations rotated crops more often, and 40% of the farmers 

incorporated a one-year fallow into their organic soybean rotation. 

Weed control in organic systems is accomplished with delayed seeding to avoid spring weeds, 

applying fertilizer to growing plants to outcompete weeds, increasing seeding rates, sowing 

cover crops, crop rotation, intercropping, flame weeding, hand weeding, and mechanical means 

(e.g., tillage) (Kuepper, 2003; Heatherly et al., 2009; Place et al., 2011). Organic crop 

production historically employed mulch and ridge tillage practices (NCAT, 2003); however, notill may be unsustainable in some long-term organic systems because of increasingly poor weed 

control (Teasdale et al., 2007). The latter cited study conducted field evaluations of several 

tillage systems over nine years, finding that in the organic system evaluated, factors contributing

to poor weed control included uneven seeding beds produced by chisel-tilling in a cover crop and 

animal manure, variable ground cover occurring in mowed cover crop residue, insufficient 

disruption of weed roots by sweep-type cultivators, and the short grain crop rotation system used 

was unsuitable for maintaining a low weed seedbank (Teasdale et al., 2007).

Pest control in organic systems is accomplished with application of natural pesticides, integrated 

pest management techniques such as introduction of beneficial organisms in the form of soil 

36
predator and parasitic organisms, and some of the practices described for weed control, such as 

crop rotation, intercropping, and use of cover crops (NCAT, 2003). 

Diseases are primarily controlled in organic systems by planting disease-resistant varieties and 

with management practices that promote healthy soil, rotating crops, diligently removing 

diseased plant material, and plant canopy management (NCAT, 2003). When physical, 

mechanical, or biological controls are not sufficient for controlling weeds, pests, or disease, only 

a biological, botanical, or synthetic substance approved on the national list may be used (USDAAMS, 2011).

USDA-NASS recently reported the organic crop production data collected in 2011 (USDANASS, 2012a) . In that year, 96,080 acres of organic soybeans in 28 states were harvested 

(Table 10), compared to approximately 73,636 million harvested acres of 

Table 10. U.S. certified organic soybean harvested acres by state, 20111

.

State Soybeans 

(acres)

State Soybeans 

(acres)

Illinois 6,633 North Dakota 3,288

Indiana 945 Ohio 5,634

Iowa 12,659 Pennsylvania 1,280

Kansas 1,311 South Dakota 3,962

Maryland 1,090 Vermont 527

Michigan 11,699 Virginia 150

Minnesota 16,150 Wisconsin 7,622

Missouri 5,505

Nebraska 6,211

New York 8,621

Source: USDA-NASS (2012a) 1 Table does not include certain states with confidential values due to low number of farms 

producing organic soybean.

conventionally produced soybean (USDA-NASS, 2011). In 2011, organic soybean production 

consisted of about 0.09% of total U.S. soybean production and was valued at approximately 

$49.4 million, capturing roughly 0.14% of the overall soybean crop value for that year (USDANASS, 2012i; USDA-NASS, 2012a). Organic soybean producers generally harvest lower yields 

than other producers (McBride and Greene, 2008; Heatherly et al., 2009). McBride and Greene 

(2008) also found total operating costs averaged $30 more per acre and capital costs averaged 

$60 per acre higher for organic soybean producers than for other conventional soybean 

producers. 

37
2.2 Physical Environment

2.2.1 Soil Quality

Soil consists of solids (minerals and organic matter), liquids, and gases. This body of inorganic 

and organic matter is home to a wide variety of fungi, bacteria, and arthropods, as well as the 

growth medium for terrestrial plant life (USDA-NRCS, 2004). Soil is characterized by its layers 

that can be distinguished from the initial parent material due to additions, losses, transfers, and 

transformations of energy and matter (USDA-NRCS, 1999b). It is further distinguished by its 

ability to support rooted plants in a natural environment. Soil plays a key role in determining the 

capacity of a site for biomass vigor and production in terms of physical support, air, water, 

temperature moderation, protection from toxins, and nutrient availability. Soils also determine a 

site’s susceptibility to erosion by wind and water, and a site’s flood attenuation capacity.

Soil properties change over time; temperature, pH, soluble salts, amount of organic matter, the 

carbon-nitrogen ratio, numbers of microorganisms and soil fauna all vary seasonally, as well as

over extended periods of time (USDA-NRCS, 1999b). Soil texture and organic matter levels 

directly influence its shear strength, nutrient holding capacity, and permeability. Soil taxonomy 

was established to classify soils according to the relationship between soils and the factors 

responsible for their character (USDA-NRCS, 1999b). Soils are organized into four levels of 

classification, the highest being the soil order. Soils are differentiated based on characteristics 

such as particle size, texture, and color, and classified taxonomically into soil orders based on 

observable properties such as organic matter content and degree of soil profile development 

(USDA-NRCS, 2010b). The Natural Resources Conservation Service (NRCS) maintains soil 

maps on a county level for the entire United States and its territories.

Soybeans are normally grown in agricultural fields managed for crop production and are best 

suited to fertile, well-drained medium-textured loam soils, yet can be produced in a wide range 

of soil types (Berglund and Helms, 2003; NSRL, No Date). Soybeans need a variety of 

macronutrients, such as nitrogen, phosphorus, potassium, calcium, magnesium, and sulfur, at

various levels (NSRL, No Date). They also require smaller amounts of micronutrients such as 

iron, zinc, copper, boron, manganese, molybdenum, cobalt, and chlorine. These micronutrients 

may be deficient in poor, weathered soils, sandy soils, alkaline soils, or soils excessively high in 

organic matter. As with proper nutrient levels, soil pH is critical for soybean development. 

Soybeans grow best in soil that is slightly acidic (pH 5.8 to 7.0); soil with a pH that is too high 

(7.3 or greater) negatively affects yield (Cox et al., 2003; NSRL, No Date). Similarly, soils that 

are high in clay and low in humus may impede plant emergence and development (NSRL, No 

Date). Soils with some clay content may increase moisture availability during periods of low 

precipitation (Cox et al., 2003). Soybean yield is highly dependent upon soil and climatic 

conditions. In the United States, the soil and climatic requirements for growing soybean are very 

similar to corn. The soils and climate in the Midwestern, Eastern, and portions of the Great 

Plains regions of the United States provide sufficient water under normal climatic conditions to 

produce a soybean crop. Soil texture and structure are key components in determining water 

availability in soils. Medium-textured soils hold more water, allowing soybean roots to penetrate 

deeper in medium-textured soils than in clay soils (Berglund and Helms, 2003; Cox et al., 2003).

38
Land management practices for soybean cultivation can affect soil quality. While practices such 

as tillage, fertilization, the use of pesticides and other management tools can improve soil health, 

they can also cause substantial damage if not properly used. Several concerns relating to 

agricultural practices include increased erosion, soil compaction, degradation of soil structure, 

nutrient loss, increased salinity, change in pH, and reduced biological activity (USDA-NRCS, 

2001). 

As discussed in Subsection 2.1.2, Agronomic Practices, conventional and conservation tillage 

may be used for the cultivation of soybean. Reducing excessive tillage through practices such as 

conservation tillage minimizes the loss of organic matter and protects the soil surface by leaving 

plant residue on the surface. Management of crop residue is one of the most effective 

conservation methods to reduce wind and water erosion, and also benefits air and water quality 

and wildlife (USDA-NRCS, 2006a). Residue management that uses intensive tillage and leaves 

low amounts of crop residue on the surface may result in greater losses of soil organic matter 

(SOM). Intensive tillage turns the soil over and buries the majority of the residue, stimulating 

microbial activity and increasing the rate of residue breakdown (USDA-NRCS, 1996). The 

residues left after conservation tillage increase organic matter and improve infiltration, soil 

stability and structure, and soil microorganism habitat (Fawcett and Caruana, 2001; USDANRCS, 2006b). Organic matter is probably the most vital component in maintaining quality soil; 

it is instrumental in maintaining soil stability and structure, reduces the potential for erosion, 

provides energy for microorganisms, improves infiltration and water holding capacity, and is 

important in nutrient cycling, cation exchange capacity4

, and the breakdown of pesticides 

(USDA-NRCS, 1996). 

The residue left over from conservation tillage practices increases SOM in the top three inches of 

the soil and protects the surface from erosion while maintaining water-conducting pores. Soil 

aggregates in conservation tillage systems are more stable than that of conventional tillage due to 

the products of SOM decomposition and the presence of soil bacteria and fungal hyphae 

(filamentous structures that compose the main growth) that bind aggregates and soil particles 

together (USDA-NRCS, 1996). Although soil erosion rates are dependent on numerous local 

conditions such as soil texture and crop, a comparison of 39 studies contrasting conventional and 

no-till practices illustrates that, on average, no-till practices reduce erosion 488 times over 

conventional tillage (Montgomery, 2007). This reduction is enough to bring soil production 

more in line with losses from erosion. From 1982 through 2003, erosion on U.S. cropland 

dropped from 3.1 billion tons per year to 1.7 billion tons per year (USDA-NRCS, 2006a). This 

can partially be attributed to the increased effectiveness of weed control through the use of 

herbicides and the corresponding reduction in the need for mechanical weed control (Carpenter 

et al., 2002). Conservation tillage also minimizes soil compaction due to the reduced number of 

tillage trips. 

Other methods to improve soil quality include careful management of fertilizers and pesticides; 

use of cover crops to increase plant diversity and limit the time soil is exposed to wind and rain; 

and, increased landscape diversity with buffer strips, contour strips, wind breaks, crop rotations, 

4 Cation Exchange Capacity is the ability of soil anions (negatively charged clay, organic matter and inorganic 

minerals such as phosphate, sulfate, and nitrate) to adsorb and store soil cation nutrients (positively charged ions 

such as potassium, calcium, and ammonium).

39

 
and varying tillage practices (USDA-NRCS, 2006b). In addition, the practice of using cover 

crops has been getting recent attention not only for limiting the time soil is exposed to wind and 

rain, but also for increasing plant diversity, reducing compaction, suppressing disease, 

controlling weeds, and enhancing soil nutrients (Hoorman et al., 2009b; USDA-NRCS, 2011b; 

MDA, 2012; NWF, 2012; SARE, 2012; USDA-NASS, 2012e; Corn and Soybean Digest, 2013; 

Lee et al., No Date)

While conservation tillage does have several benefits for soil health, some management concerns 

are associated with its use. Under no-till practices, soil compaction may become a problem as 

tillage is useful for breaking up compacted areas (USDA-NRCS, 1996). Likewise, not all soils 

(such as wet and heavy clay soils) are suited for no-till. Also, no-till practices may lead to 

increased pest occurrences that conventional tillage is better suited to managing (NRC, 2010). 

There are a multitude of organisms associated with soils ranging from microorganisms to larger 

organisms, such as worms and insects. The microorganisms that make up the soil community 

include bacteria, fungi, protozoa, and nematodes. These organisms are responsible for a wide 

range of activities that impact soil health and plant growth. Decomposers, such as bacteria, 

actinomycetes (filamentous bacteria), and saprophytic fungi, degrade plant and animal remains, 

organic materials, and some pesticides (USDA-NRCS, 2004). Other organisms, such as 

protozoa, mites and nematodes, will consume the decomposer microbes and release macro- and 

micronutrients, making them available for plant usage. Another important group of soil 

microorganisms are the mutualists. These are the mycorrhizal fungi, nitrogen-fixing bacteria, 

and some free-living microbes that have co-evolved with plants that supply nutrients to and 

obtain food from their plant hosts (USDA-NRCS, 2004). The B. japonicum bacteria associated 

with soybeans is a nitrogen-fixing rhizobium bacteria found in plant root nodules (Franzen, 

1999). Since neither soybean nor B. japonicum is native to North America, if a field has not 

been planted with soybean within three to five years, either the seed or seed zone must be 

inoculated with the rhizobium bacteria prior to soybean planting (Elmore, 1984; Pedersen, 2007). 

Pesticide use has the potential to affect soil quality due to the impact to the soil microbial 

community and is discussed further in Subsection 2.3.4, Microorganisms. The length of 

persistence of herbicides in the environment is dependent on the concentration and rate of 

degradation by biotic and abiotic processes (Carpenter et al., 2002). Persistence is measured by 

the half-life or dissipation time (DT50), which equates to the length of time needed for the 

herbicide to degrade to half of its original concentration. The degradation of pesticides and 

herbicides may be dependent on mineralization by microbes in soil, photodegradation in water, 

leaching (US-EPA, 2005). In soil, pesticide persistence may be strongly influenced by moisture, 

temperature, organic matter content and pH (FAO, 1997; Senseman, 2007). 

2.2.2 Water Resources

Water is essential for life and plays a vital role in the proper functioning of the Earth's 

ecosystems. Water pollution has a substantial impact on all living creatures, and can negatively 

affect the use of water for drinking, household needs, recreation, fishing, transportation and 

commerce. Surface water in rivers, streams, creeks, lakes, and reservoirs supports everyday life 

through the provision of water for drinking and other public uses. Surface runoff from rain, 

40
snowmelt, or irrigation water can affect surface water quality by depositing sediment, minerals, 

or other contaminants into surface water bodies. 

Surface water quality is determined by the natural, physical, and chemical properties of the land 

that surrounds the water body. The topography, soil type, vegetative cover, minerals, and climate

all influence water quality. Surface runoff is affected by meteorological factors such as rainfall 

intensity and duration, and physical factors such as vegetation, soil type, and topography. When 

land use affects one or more of these natural physical characteristics of the land, water quality is 

almost always impacted to some extent. These impacts may be positive or negative, depending 

on the type, duration and extent of land use. Agricultural practices have the potential to 

substantively impact water quality due to the vast amount of acreage devoted to farming 

nationwide and the physical and chemical demands that agricultural use imposes on the land. 

The most common types of agricultural pollutants include excess sediment, fertilizers, animal 

manure, pesticides and herbicides. Agricultural nonpoint source pollution is the leading source 

of impacts to surveyed rivers and lakes, the third largest source of impairment to estuaries, and a 

major source of impairment to groundwater and wetlands (USDA-NRCS, 2011c).

The principal law governing pollution of the nation’s water resources is the Federal Water 

Pollution Control Act of 1972, better known as the Clean Water Act (CWA). The EPA utilizes 

water quality standards, permitting requirements, and monitoring to protect water quality. The 

EPA sets the standards for water pollution abatement for all waters of the United States under 

CWA programs, but, in most cases, gives qualified states the authority to issue and enforce 

permits. The CWA provides the authority to establish water quality standards, control discharges 

into surface and subsurface waters (including groundwater), develop waste treatment 

management plans and practices, and issue permits for discharges under the National Pollutant 

Discharge Elimination System (NPDES). Section 303(d) of the CWA established a process for 

states to identify those waters within its boundaries that do not meet minimum water quality 

standards. Waters that do not meet clean water standards are classified under the CWA as 

“Impaired Waters.” Impaired Waters cannot support one or more designated uses (e.g., 

swimming, the protection and propagation of aquatic life, drinking, and agricultural or industrial 

supply). Common pollutants evaluated include sediment, chemicals, fuels, biological 

contaminants and pathogens, and characteristics such as oxygen availability, water temperature, 

and water clarity. Once a waterbody or stream segment is listed as impaired, the state must 

complete a plan to address the issue causing the impairment. States then develop total maximum 

daily loads (TMDLs) for priority waters that identify the amount of a specific pollutant from 

various sources that may be discharged to a water body, but still ensure that water quality 

standards are met for that body of water. Completion of the plan is generally all that is required 

to remove the stream segment from the 303(d) impaired water list and does not mean that water 

quality has changed. Once the TMDL is completed and approved by EPA (US-EPA, 2012b), the 

stream segment is placed on the 305(b) list of impaired streams with a completed TMDL.

Groundwater is water that flows underground and is stored in natural geologic formations called 

aquifers. It is ecologically important because it sustains ecosystems by releasing a constant 

supply of water into wetlands and contributes a sizeable amount of flow to permanent streams 

and rivers. Currently, the largest use of groundwater in the United States is irrigation, 

representing approximately 67.2% of all the groundwater pumped each day (McCray, 2012). 

41
In the United States, approximately 47% of the population depends on groundwater for its

drinking water supply. Drinking water is protected under the Safe Drinking Water Act of 1974 

(SDWA) (Public Law 93-523, 42 U.S.C. 300 et seq.). SDWA and subsequent amendments

authorize the EPA to set national health-based standards for drinking water from source water to 

the tap to protect against both naturally-occurring and man-made contaminants that may be 

found. In an effort to protect source water, the Sole Source Aquifer (SSA) Program was 

developed to protect drinking water supplies in areas where there are few or no alternative 

sources to the groundwater resource for drinking water and other needs. EPA defines a SSA as 

an aquifer that supplies at least 50% of the drinking water consumed in the area overlying the 

aquifer. There are 77 designated SSAs in the United States and its territories (US-EPA, 2011e). 

The designation protects an area's ground water resource by requiring EPA to review certain 

proposed projects receiving Federal funds or approval within the designated area to ensure that 

they do not endanger the water source.

The water needs of soybean are recounted in Section 2.1.2.1, along with the acreage that is 

irrigated and the states in which irrigation is common. Also previously noted is the important 

role of irrigation water in increasing soybean yield in those areas of marginal yearly snow- and 

rain-fall.

The presence of weeds in soybean fields is a primary detriment to soybean productivity. Weeds 

compete with soybean for light, nutrients, and soil moisture; can harbor insects and diseases;

and, can also interfere with harvest, causing extra wear on harvest equipment (Loux et al., 2008). 

Herbicides have been the primary tactic to manage weed communities in soybeans since the mid1960s and will continue to be an important feature of row crop weed management for the 

foreseeable future. Field crop production use of pesticides can introduce these chemicals to water 

through spray drift, cleaning of pesticide equipment, soil erosion, or filtration through soil to 

groundwater. Whether an herbicide has the potential to find its way into ground or surface water 

is dependent on a number of factors such as a chemical’s solubility (whether it readily dissolves 

in water), its adsorptive qualities (how tightly it binds to clay and humus particles in the soil), 

and its degradation (how fast it breaks down into harmless components) (WSU, 2010).

Approximately 93% of the soybean acreage in the United States is planted with GE herbicideresistant soybean varieties (USDA-ERS, 2012e) (see Table 2, Subsection 2.1.1, Acreage and 

Area of Soybean Production). Farms planting GE herbicide-resistant soybean varieties are more 

likely to use conservation tillage and no-till practices over conventional agricultural practices 

(Dill et al., 2008; Givens et al., 2009). This shift has resulted in reduced surface water runoff 

and soil erosion (Locke et al., 2008). As discussed in Subsection 2.2.1, Soil Quality, reduced 

tillage agricultural practices result in improved soil quality having high organic material that 

binds nutrients within the soil. An increased amount of plant residue on the soil surface reduces 

the effects of pesticide usage on water resources by forming a physical barrier to erosion and 

runoff, allowing more time for absorption into the soil, and slowing down soil moisture 

evaporation (Locke et al., 2008). The use of GE herbicide-resistant soybean varieties has also 

allowed a shift to herbicides that have lower environmental impact, such as glyphosate

(Fernandez-Cornejo and McBride, 2002).

Nutrient applications to soybean primarily include nitrogen, phosphorus (phosphate), potassium 

(potash), calcium, and sulfur, with other micronutrient supplements such as zinc, iron, and 

42
magnesium applied as needed (Whitney, 1997; USDA-NASS, 2007a; NSRL, No Date). Runoff 

from cropland areas receiving manure or fertilizer contributes to increased phosphorous and 

nitrogen delivery to streams and lakes. Phosphorus in fresh water systems is a limiting factor for 

eutrophication; therefore, an increase in phosphorus frequently leads to increased 

eutrophication5. Ammonium loss into surface waters can result in the poisoning of aquatic 

organisms. Nitrate in runoff from fields is carried into rivers and lakes. Elevated nitrate levels 

in the Gulf of Mexico contribute to the hypoxia zone, an area depleted of oxygen and marine life. 

Conservation tillage and other management practices are used to trap and control sediment and 

nutrient runoff. Water quality conservation practices benefit agricultural producers by lowering 

input costs and enhancing the productivity of working lands (USDA-NRCS, 2012).

2.2.3 Air Quality

The Clean Air Act (CAA) requires the maintenance of National Ambient Air Quality Standards 

(NAAQS). The NAAQS, developed by the EPA to protect public health, establish limits for six 

criteria pollutants: ozone (O3), nitrogen dioxide (NO2), carbon monoxide (CO), sulfur dioxide 

(SO2), lead (Pb), and inhalable particulates (coarse particulate matter [PM] greater than 2.5 

micrometers and less than 10 micrometers in diameter [PM10] and fine particles less than 2.5 

micrometers in diameter [PM2.5]). The CAA requires states to achieve and maintain the NAAQS 

within their jurisdiction. Each state may adopt requirements stricter than those of the national 

standard and each is also required by EPA to prepare a State Implementation Plan (SIP) 

containing strategies to achieve and maintain the national standard of air quality within the state. 

Areas that violate air quality standards are designated as non-attainment areas for the criteria

pollutant(s), whereas areas that comply with air quality standards are designated as attainment 

areas. Emissions contributing to greenhouse gases (GHGs) associated with global warming are 

discussed in Subsection 2.2.4, Climate Change.

Primary sources of emissions associated with crop production include exhaust from motorized 

equipment such as tractors and irrigation equipment, soil particulates from tillage and wind 

induced erosion, particulates from burning of fields, and sprayed herbicides and pesticides. 

As mentioned in Subsection 2.1.2, Agronomic Practices, the majority of soybean grown in the 

United States is rotated with corn on a two-year rotation. Soybean fields typically are tilled if 

under conventional tillage and the new rotation crop is planted in the following year. Use of 

herbicide-resistant soybeans has facilitated conservation tillage or no-till soybean production, as 

it diminishes the need to till for weed control. Decreased tillage with the consequence of

minimized earth disturbance reduces fuel use by emission-producing equipment. This is 

illustrated in Table 11using the NRCS Energy Estimator: Tillage Tool (USDA-NRCS, 2011a; 

USDA-NRCS, 2013a). The tool estimates potential fuel savings of 3,010 gallons or 60% savings 

per year based upon producing 1,000 acres of no-till soybean compared to conventional till 

soybean in the Urbana, Illinois postal code6

. NRCS is careful to note that this estimate is only 

approximate, as many variables could affect an individual operation’s actual savings. Reduced 

5 Eutrophication is the process by which a body of water becomes enriched in dissolved nutrients (as phosphates) 

that stimulate the growth of aquatic plant life usually resulting in the depletion of dissolved oxygen.

6 Postal codes are used in the NRCS Energy Estimator to estimate diesel fuel use and costs in the production of key 

crops for an area.

43

 
tillage also generates fewer particulates (dust) and potentially contributes to lower rates of wind 

erosion releasing soil particulates into the air, benefitting air quality (Towery and Werblow, 

2010). 

Table 11. Total farm diesel fuel consumption estimate (in gallons per year).

Estimate for 1,000 Acre 

Soybean Crop (Urbana, 

Illinois-61801)

Tillage Method

Conventional 

Tillage

Mulch-till Ridge-till No-till

Total fuel use 5,239 4,369 3,460 2,330

Potential fuel savings over 

conventional tillage -- 870 1,779 2,909

Total savings -- 17% 34% 56%

Source: USDA-NRCS (2013a)

Volatilization of fertilizers, herbicides and pesticides from soil and plant surfaces also introduces 

these chemicals to the air. The USDA Agricultural Research Service (ARS) is conducting a 

long-term study to identify factors that affect pesticide levels in the Chesapeake Bay region 

airshed (USDA-ARS, 2011). This study has determined volatilization is highly dependent upon 

exposure of disturbed unconsolidated soils and variability in measured compound levels is 

correlated with temperature and wind conditions. Another ARS study of volatilization of certain 

herbicides after application to fields has found moisture in dew and soils in higher temperature 

regimes significantly increases volatilization rates (USDA-ARS, 2011). 

Prescribed burning is a land treatment, used under controlled conditions, to accomplish resource 

management objectives. Open combustion produces particles of widely ranging size, depending 

to some extent on the rate of energy release of the fire (US-EPA, 2011a). The extent to which 

agricultural and other prescribed burning may occur is regulated by individual State 

Implementation Plans (SIPs) to achieve compliance with the NAAQS. Prescribed burning of 

fields would likely occur only as a pre-planting option for soybean production based on 

individual farm characteristics.

Pesticide and herbicide spraying may impact air quality from drift and diffusion. Drift is defined 

by EPA as “the movement of pesticide through air at the time of application or soon thereafter, to 

any site other than that intended for application” (US-EPA, 2000). Diffusion is gaseous 

transformation to the atmosphere (FOCUS, 2008). Factors affecting drift and diffusion include 

application equipment and method, weather conditions, topography, and the type of crop being 

sprayed (US-EPA, 2000). EPA is currently evaluating new regulations for pesticide drift 

labeling and the identification of best management practices to control such drift (US-EPA, 

2009b), as well as identifying scientific issues surrounding field volatility of conventional 

pesticides (US-EPA, 2010b).

Other conservation practices, as required by USDA to qualify for crop insurance and beneficial 

Federal loans and programs (USDA-ERS, 2009a), effectively reduce crop production impacts to 

air quality through the employment of windbreaks, shelterbelts, reduced tillage, and cover crops 

that promote soil protection on highly erodible lands. 

44
2.2.4 Climate Change

Climate change represents a significant and lasting statistical change in climate conditions that

may be measured across both time and space. The EPA has identified carbon dioxide (CO2), 

methane (CH4), and nitrous oxide (N2O) as the key GHGs affecting warming temperatures. 

While each of these gases occurs naturally in the atmosphere, human activity has significantly 

increased the concentration of these gases since the beginning of the industrial revolution. The 

level of human produced gases accelerated even more so after the end of the Second World War, 

when industrial and consumer consumption flourished. With the advent of the industrial age, 

there has been a 36% increase in the concentration of CO2, 148 % in CH4, and 18 % in N2O (USEPA, 2011b).

U.S. agriculture may influence climate change through various facets of the production process

(Horowitz and Gottlieb, 2010). The major sources of GHG emissions associated with crop

production are soil N2O emissions, soil CO2 and CH4 fluxes, and CO2 emissions associated with 

agricultural inputs and farm equipment operation (Robertson et al., 2000; Del Grosso et al., 

2002; West and Marland, 2002; Adler et al., 2007). Over the twenty-year period of 1990 to 

2009, total emissions from the agricultural sector grew by 8.7%, with 7% of the total U.S. GHG

emissions in 2009 generated from this sector (US-EPA, 2011b). 

CH4 and N2O are the primary GHGs emitted by agricultural activities. Emissions from intestinal 

(enteric) fermentation and manure management represent about 20% and 7% of total CH4

emissions from anthropogenic activities, respectively. Agricultural soil management activities 

including fertilizer application and cropping practices were the largest source of N2O emissions,

accounting for 69% of all U.S. N2O emissions (US-EPA, 2011b). Agricultural practices that 

produce CO2 emissions include liming and the application of urea fertilization to agricultural 

soils. The use of lime and urea fertilizers resulted in an increase of 11% of CO2 in 2009 relative 

to 1990 emissions (US-EPA, 2011b). The agricultural sector is also responsible for CO2

emissions from fossil fuel combustion by farm equipment such as tractors, as discussed in 

Subsection 2.2.3, Air Quality.

Since CO2 and CH4 are two of the key gases most responsible for the “Greenhouse Effect,” 

scientists and policy makers are interested in carbon (C) gases and how they may be removed 

from the atmosphere and stored. The process of C moving from the atmosphere to the earth and 

back is referred to as the carbon cycle. Simplified components of the carbon cycle are:

• Conversion of atmospheric C to carbohydrates through the process of photosynthesis;

• The consumption of carbohydrates and respiration of CO2;

• The oxidation of organic carbon creating CO2; and 

• The return of CO2 to the atmosphere.

Carbon can be stored in four main pools other than the atmosphere: (1) the earth’s crust, (locked 

up in fossil fuels and sedimentary rock deposits); (2) the oceans where CO2 is dissolved and 

marine life creates calcium carbonate shells; (3) in soil organic matter; and (4) within all living 

and dead organisms that have not been converted to soil organic matter. These pools can store or 

sink C for long periods, as in the case of C stored in sedimentary rock and in the oceans. 

Conversely, C may be held for as short a period as the life span of an individual organism. 

45
Humans can affect the carbon cycle through activities such as the burning of fossil fuels, 

deforestation, or releasing soil organic carbon through land disturbing activities. The process of 

storing C in the ecosystem is termed carbon sequestration. Carbon sequestration includes storing 

C in trees, plants and grasses (biomass) in both the above ground and the below ground plant 

tissues, and in the soil. Soil C can be found in the bodies of microorganisms (fungi, bacteria, 

etc.), in non-living organic matter, and attached to inorganic minerals in the soil.

Between 1990 and 2008, crop conservation tillage practices increased from approximately 30% 

of soybean acreage to 63% of soybean acreage in the United States (CTIC, 2011). Tillage is one 

agricultural practice that contributes to the release of GHG because of the loss of soil CO2 to the 

atmosphere; conversely, reductions in GHG emissions from lower exposure and oxidation of soil 

organic matter are often attributed to conservation tillage practices (Adler et al., 2007; CAST, 

2009b; US-EPA, 2009a; Towery and Werblow, 2010). Expected reductions in GHG emissions 

associated with the production of GE soybeans result from a reduction in fuel use due to less 

frequent herbicide applications and soil cultivation (Brookes and Barfoot, 2006).

As noted by EPA, the increase of conservation tillage is contributing to soil C sequestration (USEPA, 2011b); however, there is no evidence in EPA data that reductions or downward trends in 

overall GHG emissions have occurred as a result of GE soybeans becoming commercially 

available in the mid-1990s.

The impacts of GE crop varieties on climate change are dependent on many variables including 

cropping systems, production practices, geographic distribution of activities, and individual 

grower decisions. Agriculture influences emissions that may contribute to climate change, and 

climate change, in turn, potentially affects agriculture. In a review of several studies on corn, 

rice, sorghum, soybean, wheat, common forages, cotton, some fruits, and irrigated grains, Field 

et al. (2007) found that most studies projected likely climate-related yield increases of 5 to 20%; 

however, this positive impact would not be observed evenly across all regions as certain areas of 

the United States are expected to be negatively impacted by substantially reduced water 

resources. In addition, the current range of weeds and pests of agriculture is expected to change

in response to climate change (USGCRP, 2009). 

2.3 Biological Resources

2.3.1 Animal Communities

Animal communities in this discussion include wildlife species and their habitats. Wildlife refers 

to both native and introduced species of mammals, birds, amphibians, reptiles, invertebrates, and 

fish/shellfish. Agriculture dominates human uses of land (Robertson and Swinton, 2005). In 

2011, 917 million acres (approximately 47%) of the contiguous 48 states were devoted to 

farming, including: crop production, pasture, rangeland, Conservation Reserve Program, 

Wetlands Reserve Program, or other government program uses (Senseman, 2007; USDA-NASS, 

2012d). How these lands are maintained influences the function and integrity of ecosystems and 

the wildlife populations that they support.

A wide array of wildlife species occur within the 31 major soybean-producing U.S. states. 

During the spring and summer months, soybean fields provide browse for rabbits, deer, rodents, 

46
other mammals; birds such as upland gamebirds, while also providing a forage base for insects 

(Palmer et al., No Date). During the winter months, leftover and unharvested soybeans provide a 

food-source for wildlife; however, soybeans are poorly suited for meeting nutrient needs of 

wildlife, such as waterfowl, that require a high-energy diet (Krapu et al., 2004). 

As discussed in Subsection 2.1.2, Agronomic Practices, a shift from conventional agricultural 

practices to conservation tillage and no-till practices has occurred on farms planting GE 

herbicide-resistant soybean varieties (Dill et al., 2008; Givens et al., 2009). This increased use of 

conservation tillage practices has benefitted wildlife through improved water quality, availability 

of waste grain, retention of cover in fields, and increased populations of invertebrates (Brady, 

2007; Sharpe, 2010). Conservation tillage practices that leave greater amounts of crop residue 

serve to increase the diversity and density of birds and mammals (USDA-NRCS, 1999a). 

Increased residue also provides habitat for insects and other arthropods, consequently increasing 

this food source for insect predators. Insects are important during the spring and summer brood 

rearing season for many upland game birds and other birds, as they provide a protein-rich diet to 

fast growing young, as well as a nutrient-rich diet for migratory birds (USDA-NRCS, 2003).

Insects and other invertebrates can be beneficial to soybean production, providing services such 

as nutrient cycling and preying on plant pests. Conversely, there are many insects and 

invertebrates that are detrimental to soybean crops, including: bean leaf beetle (Cerotoma 

trifurcata); beet armyworm (Spodoptera exigua); blister beetle (Epicauta spp.); corn earworm 

(Helicoverpa zea); grasshopper (Acrididae spp.); green cloverworm (Hypena scabra); seed corn 

beetle (Stenolophus lecontei); seedcorn maggot (Delia platura); soybean aphid (Aphis glycines); 

soybean looper (Pseudoplusia includens); soybean stem borer (Dectes texanus); spider mites 

(Tetranychus urticae); stink bug (green [Acrosternum hiliare]; brown [Euschistus spp.]); and 

velvetbean caterpillar (Anticarsia gemmatalis) (Whitworth et al., 2011; Palmer et al., No Date). 

While insects are considered less problematic than weeds in U.S. soybean production, insect 

injury can impact yield, plant maturity, and seed quality. Consequently, insect pests are 

managed during the growth and development of soybean to enhance soybean yield (Higley and 

Boethel, 1994; Aref and Pike, 1998). 

Under FIFRA, all pesticides, (which is inclusive of herbicides) sold or distributed in the United 

States must be registered by the EPA (US-EPA, 2005). Registration decisions are based on 

scientific studies that assess the chemical’s potential toxicity and environmental impact. To be 

registered, a pesticide must be able to be used without posing unreasonable risks to the 

environment, including wildlife. All pesticides registered prior to November 1, 1984 must also 

be reregistered to ensure that they meet the current, more stringent standards. During the 

registration decision, the EPA must find that a pesticide does not cause unreasonable adverse 

effects to the environment if used in accordance with the approved label instructions (OSTP, 

2001). Additionally, growers must adhere to EPA label use restrictions for herbicides and 

pesticides. These measures help to minimize potential impacts of their use on non-target wildlife 

species. EPA is currently evaluating new regulations for pesticide drift labeling and the 

identification of best management practices to control such drift (US-EPA, 2009b), as well as 

identifying scientific issues surrounding field volatility of conventional pesticides (US-EPA, 

2010b).

47
2.3.2 Plant Communities

Soybeans are grown in 31 states (USDA-NASS, 2012b) throughout the Midwest, Delta, MidAtlantic, and Southeast regions of the United States (see Table 1, Figure 2), encompassing a 

wide range of physiographic regions, ecosystems, and climatic zones. The types of vegetation, 

including the variety of weeds, within and adjacent to soybean fields can vary greatly, depending 

on the geographic area in which the field occurs. Non-crop vegetation in soybean fields is 

limited by the extensive cultivation and weed control programs practiced by soybean producers. 

Plant communities bordering soybean fields can range from forests and woodlands to grasslands, 

aquatic habitats, or residential areas. Adjacent crops frequently include other soybean varieties, 

corn, cotton, or other crops.

Weeds are classified as annuals or perennials. An annual is a plant that completes its lifecycle in 

one year or less and reproduces only by seed. Perennials are plants that live for more than two

years. Weeds are also classified as broadleaf (dicots) or grass (monocots). Weeds can reproduce 

by seeds, rhizomes (underground creeping stems), or other underground parts. Annual grass and 

broadleaf weeds are considered the most common weed problems in soybeans (Krausz et al., 

2001; DAS, 2010); however, with increased rates of conservation tillage, increases in perennial, 

biennial, and winter annual weed species are being observed (Durgan and Gunsolus, 2003); 

(Green and Martin, 1996). Winter perennials are particularly competitive and difficult to control, 

as these weeds re-grow every year from rhizomes or root systems. At least 55 weed species have 

been identified as commonly occurring in soybean production (DAS, 2010; Monsanto, 2010b)

including common lambsquarter (Chenopodium album), morning glory species (Ipomoea spp.), 

velvetleaf (Abutilon theophrasti), pigweed, (Amaranthus spp.), common cocklebur (Xanthium 

strumarium), foxtail (Setaria spp.), ragweed species (Ambrosia spp.), crabgrass (Digitaria spp.), 

barynyard grass (Echinochloa crus-galli), Johnsongrass (Sorghum halepense), and thistle 

(Cirsium spp.). Recent surveys of U.S. agronomic crop producers suggest that pigweed species, 

Johnsongrass, foxtail species, and velvetleaf are among the most problematic weeds (Heatherly 

et al., 2009).

An important concept in weed control is the seed bank, which is the reservoir of seeds that are in 

the soil and have the potential to germinate. Agricultural soils contain reservoirs of weed seeds 

ranging from 4,100 to 137,700 seeds per square meter of soil (May and Wilson, 2006). Climate, 

soil characteristics, cultivation, crop selection, and weed management practices affect the seed 

bank composition and size (May and Wilson, 2006).

Herbicide resistance is described by the Weed Science Society of America as the “inherited 

ability of a plant to survive and reproduce following exposure to a dose of herbicide normally 

lethal to the wild type” (WSSA, 2011b). The first reports of weed resistance to herbicides were 

in the 1950s (WSSA, 2011a). Individual plants within a species can exhibit different responses 

to the same herbicide rate. Initially, herbicide rates are set to work effectively on the majority of 

the weed population under normal growing conditions. Genetic variability, including herbicide 

resistance, is exhibited naturally in normal weed populations, although at very low frequencies. 

When only one herbicide is used year after year as the primary means of weed control, the 

number of weeds resistant to that herbicide compared to those susceptible to the herbicide may 

change as the surviving resistant weeds reproduce (Figure 7). With no change in weed control 

48
strategies, in time, the weed population may be composed of more and more resistant weeds 

(WSSA, 2011a).

The adoption of glyphosate-resistant crops, including soybean, resulted in growers changing 

historical weed management strategies and relying on a single herbicide, glyphosate, to control

weeds in the field (Owen et al., 2011; Weirich et al., 2011). Reliance on a single management 

Source: Adapted from (Tharayil-Santhakumar, 2003)

Figure 7. The evolution of herbicide resistance.

technique for weed control resulted in the selection for weeds resistant to that technique (Owen 

et al., 2011; Weirich et al., 2011). The development of glyphosate-resistant weeds has 

necessitated a diversification of weed management strategies by growers. Faced with glyphosateresistant weeds, growers have responded to the problem by applying herbicides with different

modes of action, using tank mixes, increasing the frequency of glyphosate applications, and 

returning to tillage and other cultivation techniques to physically control these species when a 

specific herbicide proves to be ineffective (CAST, 2012).

As previously discussed in Subsection 2.1.2, Agronomic Practices, the widespread adoption of 

glyphosate-resistant GE crops has resulted in the increased use of glyphosate after 1995, and a 

decrease in the diversity of other herbicides applied in crop production to control weeds (Weirich 

49
et al., 2011). Glyphosate-resistant crops do not influence weeds any more than nontransgenic 

crops. It is the weed control methods selected by growers that create the ecological selection

pressure that ultimately changes the weed communities (Owen, 2008). The recurrent and 

exclusive use of glyphosate in the production of many GE crops has resulted in the selection for 

weed populations (e.g., Amaranthus tuberculatus) that are resistant to glyphosate. Currently

world-wide, 24 weed species, 14 in the United States, have evolved herbicide-resistant biotypes 

to the Glycines (G/9) herbicide group which includes glyphosate (Table 12); furthermore, weeds 

that had previously been agronomically unimportant (e.g., Commelina communis L. or Asiatic 

dayflower) but had natural tolerance to glyphosate have become major regional problems (Owen, 

2008; Heap, 2013b; Heap, 2013a). Glyphosate, however, is not the only herbicide to which 

weeds have developed resistance. There are currently 396 unique herbicide resistant biotypes 

with herbicide resistance in 21 Herbicide Resistance Action Committee (HRAC) herbicide 

groups (Heap, 2013a). In the United States, there are 142 unique herbicide resistant biotypes 

with herbicide resistance with a majority (approximately 89%) in eight herbicide groups (Heap, 

2013a).

The evolution of herbicide-resistant weeds has required that growers diversify weed management 

practices and use combinations of herbicides, tillage practices, and herbicide-resistant traits. 

Integrated weed management programs that use herbicides from different groups, vary cropping 

systems, rotate crops, and that use mechanical as well as chemical weed control methods, will 

delay or prevent the selection of herbicide-resistant weed populations (Gunsolus, 2002; Sellers et 

al., 2011).

Runoff, spray drift, and volatilization of herbicides have the potential to impact non-target plant 

communities growing in proximity to fields in which herbicides are used. The extent of damage 

to nontarget plants exposed to herbicide is determined by the overall vigor of the affected plant, 

the amount and type of herbicide to which the plant is exposed, and the growing conditions after 

contact (Ruhl et al., 2008).

The total rainfall the first few days after herbicide application can influence the amounts of 

leaching and runoff; however, it has been estimated that even after heavy rains, herbicide losses 

to runoff generally do not exceed 5- to 10% of the total applied (Tu et al., 2001; USDA-FS, 

2009). Planted vegetation, such as grass buffer strips, or crop residues can effectively reduce

runoff (IPPC, 2010). Volatilization typically occurs during application, but herbicide deposited 

on plants or soil can also volatilize. Most of the herbicides considered highly volatile are no 

longer used (Tu et al., 2001).

Spray drift is a concern for non-target susceptible plants growing adjacent to fields when 

herbicides are used in the production of soybeans. This potential impact relates to exposure of 

non-target susceptible plants to the off-target herbicide drift (US-EPA, 2010b). Damage from 

spray drift typically occurs at field edges or at shelterbelts (i.e., windbreaks), but highly volatile 

herbicides may drift further into a field. The risk of off-target herbicide drift is recognized by the 

EPA, which has incorporated both equipment and management restrictions to address drift in the 

EPA-approved herbicide labels. These EPA label restrictions include requirements that the 

grower manage droplet size, spray boom height above the crop canopy, restricted applications 

under certain wind speeds and environmental conditions, and using drift control agents (USEPA, 2010b).

50
Volunteer soybean is not a widespread problem, and when they occur, it is most often in parts of 

the Delta and the southeastern United States. In production systems where soybean is rotated, 

such as corn or cotton, it has shown up as a volunteer weed, yet was not generally seen as a 

serious problem by farmers (Owen and Zelaya, 2005). Volunteer soybean is not considered

difficult to manage, as soybean seeds rarely remain viable the following season and any 

interference they may pose to subsequent crops are minimal; furthermore, herbicides usually 

used for weed control in corn are also effective at controlling volunteer soybean (Owen and 

Zelaya, 2005).

Conversely, volunteer glyphosate-resistant corn in soybean is a greater concern (Owen and 

Zelaya, 2005). Glyphosate has been used to control all weeds, including corn in soybean; yet, the 

increase in cultivation of glyphosate-resistant corn has created problems for growers in the 

Midwest managing volunteer corn with glyphosate. Growers must now often include 

graminicides (herbicides to control weedy grasses) as part of their weed management strategy 

(Owen and Zelaya, 2005). 

Table 12. Summary of world-wide herbicide-resistant weeds by herbicide group

HRAC Group1 Herbicide Group Example Herbicide Total

A ACCase inhibitors Diclofop-methyl 42

B ALS inhibitors Chlorsulfuron 129

C1 Photosystem II inhibitors Atrazine 69

C2 Ureas and amides Chlorotoluron 22

C3 Nitriles and others Bromoxynil 4

D Bipyridiliums Paraquat 28

E PPO inhibitors Oxyfluorfen 6

F1 Carotenoid biosynthesis inhibitors Flurtamone 3

F2 4-HPPD inhibitors Isoxaflutole 2

F3 Triazoles, ureas, isoxazolidiones Amitrole 5

G Glycines Glyphosate 24

H Glutamine synthase inhibitors Glufosinate-ammonium 2

K1 Dinitroanilines and others Trifluralin 11

K2 Mitosis inhibitors Propham 1

K3 Chloroacetamides and others Butachlor 4

L Cellulose inhibitors Dichlobenil 1

N Thiocarbamates and others Triallate 8

O Synthetic Auxins 2,4-D 30

Z Arylaminopropionic acids Flamprop-methyl 2

Z Organoarsenicals MSMA 1

Z Unknown (chloro) - flurenol 2

Total Number of Unique Herbicide Resistant Biotypes 396

Source: Heap (2013a)

1

Herbicide Resistance Action Committee (HRAC)

51
2.3.3 Gene Flow and Weediness

Gene flow is a biological process that facilitates the production of hybrid plants, introgression of 

novel alleles (i.e., versions of a gene) into a population, and evolution of new plant genotypes. 

Gene flow to and from an agroecosystem can occur on both spatial and temporal scales. In 

general, plant pollen tends to represent the major reproductive method for moving across areas, 

while both seed and vegetative propagation tend to promote the movement of genes across time 

and space.

The rate and success of gene flow is dependent on numerous external factors in addition to the 

donor and recipient plant. General external factors related to pollen-mediated gene flow include 

the presence, abundance, and distance of sexually-compatible plant species; overlap of flowering 

phenology between populations; the method of pollination; the biology and amount of pollen 

produced; and weather conditions, including temperature, wind, and humidity (Zapiola et al., 

2008). Seed-mediated gene flow also depends on many factors, including the presence, and 

magnitude of seed dormancy, contribution and participation in various dispersal pathways, and 

environmental conditions and events.

Soybean is not native to the United States and there are no feral or weedy relatives. Soybean is 

considered a highly self-pollinated species, propagated by seed (OECD, 2000). Pollination 

typically takes place on the day the flower opens. The soybean flower stigma is receptive to 

pollen approximately 24 hours before anthesis (i.e., the period in which a flower is fully open 

and functional) and remains receptive for 48 hours after anthesis. Anthesis normally occurs in 

late morning, depending on the environmental conditions. The pollen usually remains viable for 

two to four hours, and no viable pollen can be detected by late afternoon. Natural or artificial 

cross-pollination can only take place during the short time when the pollen is viable. 

Additionally, soybean’s reproductive characteristics (e.g., flower orientation that reduces its 

exposure to wind, internal anthers, and clumping and stickiness of the pollen) decreases the 

dispersion ability of pollen (Yoshimura, 2011). 

As a highly self-pollinated species, cross-pollination of soybean plants to adjacent plants of other 

soybean varieties occurs at a relatively low frequency (0 to 6.3%) (Caviness, 1966; Ray et al., 

2003; Yoshimura et al., 2006; USDA-APHIS, 2011b). A study of soybeans grown in Arkansas 

found that cross-pollination of soybeans in adjacent rows averaged between 0.1% and 1.6%, but 

may be as high as 2.5% (Ahrent and Caviness, 1994). Abud et al. (2007) illustrated that as 

distance is increased from the soybean pollination source, the chance of cross-pollination is 

decreased. This study found that at a distance of 1 meter (3.28 feet), outcrossing averaged about 

0.5%, at 2 meters (approximately 6.5 feet) outcrossing averaged about 0.1%, at 4 meters 

(approximately 13 feet) it declined to approximately 0.05%, and at 10 meters (approximately 33 

feet) the potential for outcrossing was less than 0.01%.

Generally, gene flow by seed is dependent on natural dispersal mechanisms, such as water, wind, 

or animals, or by human actions and is favored by characteristics such as small and lightweight 

seed size, prolific production, seed longevity and dormancy, and long distance seed transport 

(Mallory-Smith and Zapiola, 2008). Soybean seeds do not possess the characteristics for 

efficient seed-mediated gene flow. Soybean seeds are heavy and, therefore, are not readily or 

naturally dispersed by wind or water (Mallory-Smith and Zapiola, 2008). Similarly, soybean 

52
seeds and seedpods do not have physical characteristics that encourage animal transport (OECD, 

2000). In addition, soybeans lack dormancy, a characteristic that allows dispersal in time by 

maintaining seeds and their genes within the soil for several years (OECD, 2000; Mallory-Smith 

and Zapiola, 2008). As already mentioned, there are no wild populations of soybean within the 

United States. Crop seeds that remain on the field after harvest and remain viable to germinate 

the following year in rotation crops are termed volunteers (Carpenter et al., 2002). Volunteer 

soybeans are limited by the geography in which soybean is planted. Soybean requires specific 

environmental conditions to grow as a volunteer (OECD, 2000). Mature soybean seeds are 

sensitive to cold and rarely survive in freezing winter conditions (Raper and Kramer, 1987); 

however, if temperature and moisture conditions are suitable, seeds may remain viable, 

germinate and become volunteers (Mallory-Smith and Zapiola, 2008). Volunteer soybeans can 

occur in regions with warmer climates where conditions for germination can occur year round, 

such as the Mississippi Delta and the southeast United States, but as discussed in Subsection 

2.1.2, Agronomic Practices, volunteer soybeans do not easily compete with other crops and are 

easily controlled with common agronomic practices. In addition, as discussed above, since 

soybean is principally self-pollinating, the potential for transgene movement from volunteers as a 

result of pollen movement is negligible (Owen and Zelaya, 2005).

Horizontal gene transfer and expression of DNA from a plant species to bacteria is unlikely to 

occur (Keese, 2008). Many bacteria (or parts thereof) that are closely associated with plants 

have been sequenced, including Agrobacterium and Rhizobium (Kaneko et al., 2000; Wood et 

al., 2001; Kaneko et al., 2002). There is no evidence that these organisms contain genes derived 

from plants; further, in cases where review of sequence data implied that horizontal gene transfer 

occurred, these events are inferred to occur on an evolutionary time scale on the order of millions 

of years (Koonin et al., 2001; Brown, 2003). The FDA has also evaluated horizontal gene 

transfer from the use of antibiotic resistance marker genes, and concluded that the likelihood of 

transfer of antibiotic resistance genes from plant genomes to microorganisms in the 

gastrointestinal tract of humans or animals, or in the environment, is remote (US-FDA, 1998).

2.3.4 Microorganisms

Soil microorganisms play a key role in soil structure formation, decomposition of organic matter, 

toxin removal, nutrient cycling, and most biochemical soil processes (Garbeva et al., 2004). 

They also suppress soil-borne plant diseases and promote plant growth (Doran et al., 1996). 

Estimates of the number of bacterial species that may be found in a gram of soil range from 

6,000 to 50,000 (Curtis et al., 2002). In a study of soil suppressive to Rhizoctonia solani, a fungal 

pathogen in crops such as potatoes, sugar beets, and rice, Mendes et al. (2011) found that over 

33,000 prokaryotic7 species were present in the rhizosphere. The soil microbial community 

include nitrogen-fixing microbes such as the soybean mutualist B. japonicum, mycorrhizal fungi, 

and free-living bacteria8; bacteria, actinomycetes (filamentous bacteria), and saprophytic fungi 

responsible for decomposition; denitrifying bacteria and fungi; phosphorus-solubilizing bacteria 

and fungi; as well as pathogenic and parasitic microbes (USDA-NRCS, 2004).

7 Prokaryotes are, for the most part, single celled organisms that lack a nucleus or other membrane-bound organelles 

and include bacteria and archaea.

8 Organisms that are able to obtain food without the need for a host organism.

53

 
The main factors affecting microbial population size and diversity include soil type (texture, 

structure, organic matter, aggregate stability, pH, and nutrient content), plant type (providers of 

specific carbon and energy sources into the soil), agricultural management practices (crop 

rotation, tillage, herbicide and fertilizer application, and irrigation) and cropping history 

(Garbeva et al., 2004; Garbeva et al., 2008). Some types of soil micro-organisms share 

metabolic pathways with plants, and might be affected by herbicides. Tillage disrupts 

multicellular relationships among microorganisms, and crop rotation changes soil conditions in 

ways that favor different microbial communities.

Plant roots, including those of soybean, release a variety of compounds into the soil creating a 

unique environment for microorganisms in the rhizosphere (root zone). Microbial diversity in 

the rhizosphere may be extensive and differs from the microbial community in the bulk soil 

(Garbeva et al., 2004). The following briefly focuses on the soybean, GE crops, and herbicide 

use factors with the potential to affect microbial population size and diversity. 

Soybeans

An important group of soil microorganisms associated with legumes, including soybean, are the 

mutualists. These include mycorrhizal fungi, nitrogen-fixing bacteria, and some free-living 

microbes that have co-evolved with plants that supply nutrients to and obtain food from their 

plant hosts (USDA-NRCS, 2004). Legumes have developed symbiotic relationships with 

specific nitrogen-fixing bacteria in the family Rhizobiaceae that induce the formation of root 

nodules where bacteria may carry out the reduction of atmospheric nitrogen into ammonia (NH3) 

that is usable by the plant (Gage, 2004). Bradyrhizobium japonicum is the rhizobium bacteria 

specifically associated with soybeans (Franzen, 1999). Since neither soybean nor B. japonicum 

is native to North America, if a field has not been planted with soybean within three to five 

years, either the seed or seed zone must be inoculated with B. japonicum prior to soybean 

planting (Berglund and Helms, 2003; Pedersen, 2007). 

In addition to beneficial microorganisms, there are also several microbial pathogens that cause 

disease in soybean and vary somewhat depending on the region. These include fungal pathogens 

such as Rhizoctonia Stem Rot (Rhizoctonia solani), Brown Stem Rot (Phialophora gregata), 

Sudden Death Syndrome (Fusarium solani race A), and Charcoal Root Rot (Macrophomina 

phaseolina); bacterial pathogens Bacterial Blight (Pseudomonas syringae) and Bacterial Pustule 

(Xanthomonas campestri); and viral pathogens Soybean Mosaic Virus and the Tobacco Ringspot 

Virus (Ruhl, 2007; SSDW, No Date). The Soybean Cyst Nematode (Heterodera glycines) is a 

microscopic parasite that infects the roots of soybeans. Management to control disease outbreaks 

varies by region, and pathogen, and parasite, but include common practices such as crop rotation, 

weed control, planting resistant cultivars, and proper planting and tillage practices.

GE crops

Identifying and gauging the effects of GE crops on soil microbes in the rhizosphere can be 

challenging, as agricultural soils are complex and dynamic and numerous other factors can 

potentially influence the soil-borne ecosystem. Changes in agricultural practices and inputs and 

natural variations in season, weather, plant development stages, geographic location, soil type, 

and plant species or cultivars can all impact the microbial community (Kowalchuk et al., 2003; 

US-EPA, 2009c). It is assumed that direct impacts may include changes to the structure (species 

richness and diversity) and function of the microbial community in the rhizosphere due to the 

54
biological activity of the inserted gene(s). Indirect impacts may result from changes in the 

composition of root exudates, plant litter, or agricultural practices (Kowalchuk et al., 2003; USEPA, 2009c). Several reviews of the investigations into the impact of GE plants on microbial soil 

communities found that most of the studies examining distinctive microbial traits concluded 

there was either minor or no detectable non-target effects (Kowalchuk et al., 2003; Hart, 2006; 

US-EPA, 2009c).

Herbicides

Herbicides have a wide variety of formulations, constituents, and recommended uses and 

concentrations that play a role in how herbicides affect microorganism communities. 

Understanding and quantifying the effects of their use is further compounded by differences in 

environment factors, including the main factors affecting microbial population size and diversity 

listed in Subsection 2.3.4, Microorganisms. As mentioned previously, some types of soil microorganisms share metabolic pathways with plants, and might be negatively affected by herbicides. 

Alternatively, many microorganisms feed on herbicides or produce enzymes that break-down 

herbicides (Tu et al., 2001; Haney et al., 2002; Araujo et al., 2003; Senseman, 2007; US-EPA, 

2008). This microorganism activity is instrumental to herbicide degradation in the soil. As a 

result, herbicides have both positive and negative effects on microorganism groups that may 

increase the population of some while reducing the population of others.

Identifying and quantifying the specific impacts of herbicides on the soil microbial community is 

difficult and is subject to a multitude of variables. Several studies have documented an array of 

potential impacts associated with 2,4-D ranging from no detectable impact to substantial changes 

to the microbial community (Breazeale and Camper, 1970; Rai, 1992; Xia et al., 1995; FAO, 

1997). Field studies have determined there were no differences in agronomic performance (i.e.,

plant growth and phenotypic characteristics, disease and insect susceptibility) between 2,4-D and 

glufosinate sprayed and unsprayed control soybean genetically modified to resist these two 

herbicides (DAS, 2010; USDA-APHIS, 2010), suggesting no meaningful changes to the 

microbial community that influence soybean growth and health. Similarly, investigations of the 

impact of glyphosate on microorganisms are mixed (Weaver et al., 2007). Haney et al. (2002)

and Araujo et al. (2003) report that glyphosate is mineralized by microorganisms which leads to 

an increase in their population and activity, while Busse et al. (2001) and Weaver et al. (2007)

found little evidence of changes to soil microorganism’s population and activity and any declines 

recorded were small and not consistent throughout the season. It also has been reported that the 

use of glyphosate increases the colonization of soil borne fungal pathogens such as Fusarium 

spp. (Fernandez et al., 2009; Kremer and Means, 2009; Huber, 2010); however, peer reviewed 

research that report a direct correlation of glyphosate use to an increase in plant disease is limited 

and any connection to impacts on yield has not been established (Camberato et al., 2011).

2.3.5 Biodiversity

Biodiversity refers to all plants, animals, and microorganisms interacting in an ecosystem 

(Wilson, 1988). Biodiversity provides valuable genetic resources for crop improvement (Harlan, 

1975) and also provides other functions beyond food, fiber, fuel, and income. These include 

pollination, genetic introgression, biological control, nutrient recycling, competition against 

natural enemies, soil structure, soil and water conservation, disease suppression, control of local 

microclimate, control of local hydrological processes, and detoxification of noxious chemicals 

55
(Altieri, 1999). The loss of biodiversity can result in a need for costly management practices in 

order to provide these functions to the crop (Altieri, 1999). 

The degree of biodiversity in an agroecosystem depends on four primary characteristics: (1) 

diversity of vegetation within and around the agroecosystem; (2) permanence of various crops 

within the system; (3) intensity of management; and (4) extent of isolation of the agroecosystem 

from natural vegetation (Altieri, 1999). Agricultural land subject to intensive farming practices, 

such as that used in crop production, generally has low levels of biodiversity compared with 

adjacent natural areas. Tillage, seed bed preparation, planting of a monoculture crop, pesticide 

use, fertilizer use, and harvesting limit the diversity of plants and animals (Lovett et al., 2003). 

Biodiversity can be maintained or reintroduced into agroecosystems through the use of woodlots, 

fencerows, hedgerows, and wetlands. Agronomic practices that may be employed to support 

biodiversity include intercropping (the planting of two or more crops simultaneously to occupy 

the same field), agroforestry, crop rotations, cover crops, no-tillage, composting, green manuring 

(growing a crop specifically for the purpose of incorporating it into the soil in order to provide 

nutrients and organic matter), addition of organic matter (compost, green manure, animal 

manure, etc.), and hedgerows and windbreaks (Altieri, 1999). Integrated pest management 

strategies include several practices that increase biodiversity such as retaining small, diverse 

natural plant refuges and minimal management of field borders.

The potential impacts to biodiversity associated with the agricultural production of crops include 

a loss of diversity, which can occur at the crop, farm, and/or landscape level (Visser, 1998; 

Ammann, 2005; Carpenter, 2011). In this EA, crop diversity refers to the genetic uniformity 

within crops, farm-scale diversity refers to the level of complexity of organisms within the 

boundaries of a farm, and landscape level diversity refers to potential changes in land use and the 

impacts of area-wide weed suppression beyond the farm boundaries (Carpenter, 2011).

Crop Diversity

Genetic diversity in crops is beneficial as it may improve yields, pest and disease resistance, and 

quality in agricultural systems, and that greater varietal and species diversity enable growers to 

maintain productivity over a wide range of conditions (Krishna et al., 2009). There is concern 

that the adoption of GE technology potentially reduces grower-demand for crop genetic diversity 

because breeding programs could concentrate on a smaller number of high value cultivars, which 

could reduce the availability of, and demand for, non-GE varieties (Carpenter, 2011). In 

contrast, several studies involving GE soybeans and cotton have found this not to be the case, 

indicating the introduction of GE crops has not decreased crop species diversity (Ammann, 2005; 

Carpenter, 2011). 

Concern for the loss of genetic variability has led to the establishment of a worldwide network of 

genebanks (van de Wouw et al., 2010). The USDA Soybean Germplasm Collection, which is 

part of the National Plant Germplasm System, acquires, maintains, and evaluates soybean 

germplasm and distributes seed samples to scientists in 35 states (University of Illinois, 2003). 

Nationwide, there are over 23,190 soybean varieties (USDA-ARS, 2013) that provide a vast 

reservoir of genetic diversity for crop development.

56
Farm-scale Diversity

As noted previously, agricultural practices have the potential to impact diversity at the farm level 

by affecting a farm’s biota, including birds, wildlife, invertebrates, soil microorganisms, and 

weed populations. For example, an increase in adoption of conservation tillage practices is 

associated with the use of GE herbicide-resistant crops (Givens et al., 2009). Less tillage 

provides more wildlife habitat by allowing other plants to establish between crop rows in either 

stubble or weeds. Conservation tillage also leaves a higher rate of plant residue and increases 

soil organic matter (Hussain et al., 1999), which benefit soil biota by providing additional food 

sources (energy) (USDA-NRCS, 1996) and increase the diversity of soil microorganisms, as 

discussed in Subsection 2.3.4, Microorganisms. In addition, invertebrates that feed on plant 

detritus and their predators and, in turn, birds and other wildlife that prey on them, may benefit 

from increased conservation tillage practices (Towery and Werblow, 2010; Carpenter, 2011). 

Ground-nesting and seed-eating birds, in particular, have been found to benefit from greater food 

and cover associated with conservation tillage (SOWAP, 2007).

Herbicide use in agricultural fields may impact biodiversity by decreasing weed quantities or 

causing a shift in weed species present in the field, which would affect those insects, birds, and 

mammals that feed on or find shelter in these weeds. The quantity and type of herbicide use 

associated with conventional and GE crops is dependent on many variables, including cropping 

systems, type and abundance of weeds, production practices, and individual grower decisions.

Landscape-scale Diversity 

The greatest direct impact of agriculture on biodiversity on the landscape scale results from the 

loss of natural habitats caused by the conversion of natural ecosystems into agricultural land 

(Ammann, 2005). Increases in crop yields, such as has been observed in the last 10 years in 

soybean production, have the potential to reduce impacts to biodiversity by allowing less land to 

be converted to agriculture than would otherwise be necessary (Carpenter, 2011); however, 

substantial gains in yields have generally not been obtained by herbicide-resistant cultivars 

unless higher yielding cultivars are modified with an herbicide-resistant trait (NRC, 2010). 

Similar to that discussed in farm-scale diversity, the use of herbicides at the landscape-level also 

has the potential to impact biodiversity. Increased conservation tillage practices associated with 

herbicide-resistant crops over large areas may increase certain populations of invertebrates and 

wildlife that benefit from conservation tillage, whereas those species dependent on the targeted 

weeds may be negatively impacted. Potential impacts to landscape-scale diversity can also be 

related to the effects of herbicides on non-target plant and animal species.

Several recent studies (Hartzler, 2010b; Brower et al., 2012; Pleasants and Oberhauser, 2012)

have examined the potential causes of observed decreases in overwintering monarch butterfly 

(Danaus plexippus) populations, namely the reduced infestations of common milkweed 

(Asclepias syriaca), a perennial weed, in Corn Belt agricultural fields. The loss of host milkweed 

plants in agricultural fields is assumed to be a result of the increased use of glyphosate associated 

with the high adoption rate of GE crops (Brower et al., 2012), although slight declines in 

milkweed abundance in non-agricultural areas not related to glyphosate use were also observed. 

However, it was concluded that the observed reduced monarch abundance is likely based on 

several contributing factors including: degradation of the forest in the overwintering areas; the 

loss of breeding habitat (i.e., milkweed host plants) in the United States, resulting from the use of 

57
herbicide associated with the expansion of GE herbicide-resistant crop acreage and from 

continued land development; and severe weather (Hartzler, 2010b; Brower et al., 2012; Pleasants 

and Oberhauser, 2012).

While herbicide use potentially affects biodiversity, the application of pesticides in accordance 

with EPA-registered label uses and careful management of chemical spray drift minimizes the 

potential biodiversity impacts from their use.

2.4 Human Health

2.4.1 Consumer Health

Human health concerns surrounding GE soybean focus primarily on human and animal 

consumption. Soybeans yield both solid (meal) and liquid (oil) products. Soybean meal is high 

in protein and is used for products such as tofu, soymilk, meat replacements, and protein powder; 

it also provides a natural source of dietary fiber (USB, 2009). Nearly 98% of soybean meal 

produced in the United States is used as animal feed, while less than 2% is used to produce soy 

flour and proteins for food use (Soyatech, 2011). Extracted soybean liquid oils are used to 

produce salad and cooking oils, baking and frying fat, and margarine. Soy oil is low in saturated 

fats, high in poly and monounsaturated fats, and contains essential omega-3 fatty acids. Soybean 

oil comprises nearly 70% of the oils consumed in U.S. households (ASA, 2010b).

Non-GE soybean varieties, both those developed for conventional use and for use in organic 

production systems, are not a subject for mandatory evaluation by any regulatory agency in the 

United States for human food or animal feed safety prior to release in the market. Under the 

FFDCA, it is the responsibility of food and feed manufacturers to ensure that the products they 

market are safe and properly labeled. As a GE product, however, food and feed derived from 

MON 87712-4 soybean must be in compliance with all applicable legal and regulatory 

requirements.

GE organisms for food and feed may undergo a voluntary consultation process with the FDA 

prior to release onto the market. Although a voluntary process, thus far, all applicants who have 

wished to commercialize a GE variety that would be included in the food supply have completed 

a consultation with the FDA. In such a consultation, a developer who intends to commercialize a 

bioengineered food meets with the agency to identify and discuss relevant safety, nutritional, or 

other regulatory issues regarding the bioengineered food and then submits to FDA a summary of 

its scientific and regulatory assessment of the food. This process includes: (1) an evaluation of 

the amino acid sequence introduced into the food crop to confirm whether the protein is related 

to known toxins and allergens; (2) an assessment of the protein’s potential for digestion; and (3) 

an evaluation of the history of safe use in food (Hammond and Jez, 2011). FDA evaluates the 

submission and responds to the developer by letter with any concerns it may have or additional 

information it may require. Several international agencies also review food safety associated 

with GE-derived food items, including the European Food Safety Agency (EFSA) and the 

Australia and New Zealand Food Standards Agency (ANZFS). 

Foods derived through biotechnology also undergo a comprehensive safety evaluation before 

entering the market, including reviews under the Codex Alimentarius, the EFSA, and the World 

58
Health Organization (WHO) (FAO, 2009; Hammond and Jez, 2011). Food safety reviews 

frequently will compare the compositional characteristics of the GE crop with nontransgenic, 

conventional varieties of that crop; moreover, this comparison also evaluates the composition of 

the modified crop under actual agronomic conditions, including various agronomic inputs

(Aumaitre et al., 2002; FAO, 2009). Composition characteristics evaluated in these comparative 

tests include moisture, protein, fat, carbohydrates, ash, minerals, dietary fiber, essential and nonessential amino acids, fatty acids, vitamins, and antinutrients.

There are multiple ways in which organisms can be genetically modified through human 

intervention. Traditional methods include breeding or crossing an organism to elicit the 

expression of a desired trait, while more contemporary approaches include the use of 

biotechnology such as genetic engineering to produce new organisms (NRC, 2004). As noted by 

the National Research Council (NRC), unexpected and unintended compositional changes arise 

with all forms of genetic modification, including both conventional hybridizing and genetic 

engineering (NRC, 2004). The NRC also noted that at the time, no adverse health effects 

attributed to genetic engineering had been documented in the human population. Reviews on the 

nutritional quality of GE foods have generally concluded that there are no significant nutritional 

differences in conventional versus GE plants for food or animal feed (Faust, 2002; Flachowsky 

et al., 2005).

Pursuant to FFDCA, before a pesticide can be used on a food crop EPA must establish the 

tolerance value, which is the maximum amount of pesticide residue that can remain on the crop 

or in foods processed from that crop (US-EPA, 2010a). In addition, the FDA and the USDA 

monitor foods for pesticide residues and enforce these tolerances (USDA-AMS, 2011). If 

pesticide residues are found to exceed the tolerance value, the food is considered adulterated and 

may be seized. The USDA has implemented the Pesticide Data Program (PDP) in order to collect 

data on pesticides residues on food (USDA-AMS, 2010). The EPA uses PDP data to prepare 

pesticide dietary exposure assessments pursuant to the 1996 Food Quality Protection Act

(FQPA). Pesticide tolerance levels for various pesticides have been established for a wide 

variety of commodities, including soybean, and are published in the Federal Register, CFR, and 

the Indexes to Part 180 Tolerance Information for Pesticide Chemicals in Food and Feed 

Commodities (US-EPA, 2011c).

2.4.2 Occupational Health and Safety

Agriculture is one of the most hazardous industries for U.S. workers. As a result, Congress 

directed the National Institute of Occupational Safety and Health to develop a program to 

address high-risk issues related to occupational workers. In consideration of the risk of pesticide 

exposure to field workers, EPA’s Worker Protection Standard (WPS) (40 CFR Part170) was 

published in 1992 to require actions to reduce the risk of pesticide poisonings and injuries among 

agricultural workers and pesticide handlers. The WPS offers protections to more than two and a 

half million agricultural workers who work with pesticides at more than 560,000 workplaces on 

farms, forests, nurseries, and greenhouses. The WPS contains requirements for pesticide safety 

training, notification of pesticide applications, use of personal protective equipment, restricted 

entry intervals following pesticide application, decontamination supplies, and emergency 

medical assistance; furthermore, the Occupational Safety and Health Administration (OSHA) 

59
require all employers to protect their employees from hazards associated with pesticides and 

herbicides.

Pesticides, which include herbicides, are used on most soybean acreage in the United States, and 

changes in acreage, crops, or farming practices can affect the amounts and types of pesticides 

used and thus the potential risks to farm workers. The EPA pesticide registration process, 

however, involves the design of use restrictions that, if followed, have been determined to be 

protective of worker health. Under FIFRA, all pesticides, (which is inclusive of herbicides) sold 

or distributed in the United States must be registered by the EPA (US-EPA, 2005). Registration 

decisions are based on scientific studies that assess the chemical’s potential toxicity and 

environmental impact. To be registered, a pesticide must be able to be used without posing 

unreasonable risks to people or the environment. All pesticides registered prior to November 1, 

1984 must also be reregistered to ensure that they meet the current, more stringent standards. 

During the registration decision, the EPA must find that a pesticide does not cause unreasonable 

adverse effects to human health or the environment if used in accordance with the approved label 

instructions (OSTP, 2001).

EPA labels for herbicides include use restrictions and safety measures to mitigate exposure risks. 

Growers are required to use registered pesticides consistent with the application instructions 

provided on the EPA-approved pesticide labels. Worker safety precautions and use restrictions 

are clearly noted on pesticide registration labels. These restrictions provide instructions as to the 

appropriate levels of personal protection required for agricultural workers to use herbicides. 

These may include instructions on personal protective equipment, specific handling 

requirements, and field reentry procedures. EPA labels for registered herbicides have been 

designed to reduce the risks of illness or injury resulting from workers' and handlers' 

occupational exposures to pesticides used in the production of agricultural plants on farms or in 

nurseries, greenhouses, and forests and also from the accidental exposure of workers and other 

persons to such pesticides.

2.5 Animal Feed

Animal agriculture consumes 98% of the U.S. soybean meal produced (Soyatech, 2011) and 70% 

of soybeans worldwide (USB, 2011c). Poultry consume more than 48% of domestic soybean 

meal or 11.92 million MT of the U.S. soybean crop, with soy oil increasingly replacing animal 

fats and oils in broiler diets (USB, 2011b; ASA, 2012b). Soybean can be the dominant 

component of livestock diets, such as in poultry, where upwards of 66% of their protein intake is 

derived from soy (Waldroup and Smith, No Date). Other animals fed domestic soybean by crop 

volumes consumed include swine (26%), beef cattle (12%), dairy cattle (9%), other (e.g., farmraised fish 3%), and household pets (3%) (ASA, 2010a; USB, 2011a).

Although the soybean market is dominated by seed production, soybean has a long history and a 

standing in the United States as a nutritious grazing forage, hay, and silage crop for livestock 

(Blount et al., 2009). Soybean may be harvested for hay or grazed from the flowering stage to 

near maturity; the best soybean for forage is in the beginning pod stage (Johnson et al., 2007). 

For silage, it should be harvested at maturity before leaf loss, and mixed with a carbohydrate 

source, such as corn, for optimal fermentation characteristics (Blount et al., 2009). Varieties of 

soybean have been developed specifically for grazing and hay, but use of the standard grain 

60
varieties are recommended by some because of the whole plant feeding value (Weiderholt and 

Albrecht, 2003). 

Similar to the regulatory oversight for direct human consumption of soybean under the FFDCA, 

it is the responsibility of feed manufacturers to ensure that the products they market are safe and 

properly labeled. Feed derived from GE soybean must comply with all applicable legal and 

regulatory requirements, which in turn protects human health. To help ensure compliance, GE 

organisms used for feed may undergo a voluntary consultation process with FDA before release 

onto the market, which provides the applicant with any needed direction about the need for 

additional data or analysis, and allows for interagency discussions regarding possible issues.

Although a voluntary process, thus far all applicants who wish to commercialize a GE 

variety that will be included in the food supply have completed a consultation with the FDA. 

A developer who intends to commercialize a bioengineered food consults with the agency to 

identify and discuss relevant safety, nutritional, or other regulatory issues regarding the 

bioengineered food and then submits to FDA a summary of its scientific and regulatory 

assessment of the food. Monsanto began the process of consultation, and received questions 

from FDA on July 18, 2012, and responded to those on August 9, 2012. When complete, the

decision memo will be published as BNF No. 131. 

Growers must adhere to EPA label use restrictions for pesticides used to produce a soybean 

crop before using it as forage, hay, or silage. Under Section 408 of FFDCA, EPA regulates 

the levels of pesticide residues that can remain on food or food commodities from pesticide 

applications (US-EPA, 2010a). These tolerances are the maximum amount of pesticide residue 

that can legally be present in food or feed, and if pesticide residues are found to exceed the 

tolerance value, the food is considered adulterated and may be seized.

2.6 Socioeconomic

2.6.1 Domestic Economic Environment

The value of U.S. soybean production exceeded $35.8 billion in 2011, which was 20.8% of the 

value of all field crops (USDA-NASS, 2012j; USDA-NASS, 2012c) (Figure 8). The top ten 

producing states (Iowa, Illinois, Minnesota, Nebraska, Indiana, Ohio, Missouri, South Dakota, 

Arkansas, and North Dakota) accounted for approximately 80% of this production (Table 13). 

These North Central states fall into the USDA-ERS’s Heartland (Iowa, Illinois, Indiana, 

Minnesota, Missouri, Nebraska, Ohio, and South Dakota), Northern Crescent (Minnesota and 

Ohio), Northern Great Plains (Nebraska, Minnesota, North Dakota, and South Dakota), Prairie 

Gateway (Nebraska), and Eastern Uplands (Missouri and Ohio) resource regions (FernandezCornejo and McBride, 2002), which vary in terms of land productivity and cost of production 

(Figure 9). The most productive of these regions are the Heartland and Northern Crescent. 

While these regions have higher production cost, their higher productivity still results in greater 

profitability. In 2011, the U.S. total gross average value of soybean production per planted acre 

was $525.36 and the average price of a bushel of soybeans at harvest was $11.94 (USDA-ERS, 

2012k).

61
Production cost data are provided by USDA-ERS and collected in surveys conducted every four 

to eight years for each commodity as part of the annual ARMS (USDA-ERS, 2011c). In 2011, 

typical operating costs are reported in dollars per planted acre and included purchased seed 

($55.55), fertilizer and soil amendments ($22.84), other chemicals ($16.42), and irrigation water 

($0.15) (USDA-ERS, 2012k). Total 2011operating costs were $136.87 per planted soybean acre 

(USDA-ERS, 2012k). In comparison, forecasted 2012 typical U.S. soybean production 

operating costs per planted acre total $143.16, including $59.87 for purchased seed, $23.41 for 

fertilizer and soil amendments, and $17.25 for other chemicals; costs for irrigation water were 

not estimated (USDA-ERS, 2011d; USDA-ERS, 2012d). 

Source: USDA-NASS (2012c)

Figure 8. Distribution of crop value in 2012.

62
Source: USDA-ERS (2012c)

Figure 9. U.S. soybean cost and value of production estimates for 2011 (excluding 

government payments).

Cost

Per Acre

Value

63
Table 13. Soybean crop value by state.

State Crop Value (1,000,000 dollars) State’s Percent of Total U.S. 

Soybean Crop Value 

2009 2010 2011 2009 2010 2011

Alabama 172 100 110 0.5 0.3 0.31

Arkansas 1,185 1,246 1,491 3.7 3.2 4.17

Delaware 74 66 75 0.2 0.2 0.21

Florida 12 8 5 0.04 0.02 0.01

Georgia 155 76 35 0.5 0.2 0.10

Illinois 4,215 5,779 4,955 13.1 14.9 13.85

Indiana 2,612 3,050 2,761 8.1 7.8 7.72

Iowa 4,627 5,806 5,500 14.4 14.9 15.37

Kansas 1,506 1,658 1,154 4.7 4.3 3.23

Kentucky 675 572 693 2.1 1.5 1.94

Louisiana 354 456 408 1.1 1.2 1.14

Maryland 190 188 204 0.6 0.5 0.57

Michigan 759 1,012 990 2.4 2.6 2.77

Minnesota 2,674 3,717 3,108 8.3 9.6 8.69

Mississippi 713 846 835 2.2 2.2 2.33

Missouri 2,216 2,546 2,259 6.9 6.5 6.31

Nebraska 2,459 3,026 2,972 7.7 7.8 8.30

New Jersey 34 25 37 0.1 0.1 0.10

New York 99 147 137 0.3 0.4 0.38

North Carolina 571 496 469 1.8 1.3 1.31

North Dakota 1,075 1,564 1,283 3.3 4.0 3.59

Ohio 2,171 2,600 2,566 6.8 6.7 7.17

Oklahoma 114 132 40 0.4 0.3 0.11

Pennsylvania 192 245 259 0.6 0.6 0.72

South Carolina 132 120 102 0.4 0.3 0.28

South Dakota 1,615 1,762 1,717 5.0 4.5 4.80

Tennessee 671 507 480 2.1 1.3 1.34

Texas 44 56 21 0.1 0.1 0.06

Virginia 198 166 247 0.6 0.4 0.69

West Virginia 7 7 10 0.02 0.02 0.03

Wisconsin 623 938 861 1.9 2.4 2.41

United States 32,145 38,915 35,784 100 100 100

Source:USDA-NASS (2012c)

Almost all of the U.S. soybean supply is either exported or crushed for meal and oil (Table 14). 

In any given year, the resulting meal and oil is modestly supplemented with carryover stocks and 

imports before being consumed domestically or exported. In the United States, almost all of the 

soybean meal is used for animal feed (97.5% in 2002/03) (Soybean Meal Information Center, 

2011). The vast majority of the oil (79% in 2011) is used for human consumption, with the 

64
balance going to industrial products. Soybean oil represents almost 70% of the oils consumed by 

U.S. households. It is notable that higher petroleum prices and an increased interest in biofuels 

Table 14. U.S. soybean supply and disappearance1 2011/12.

Soybeans2 Soybean Meal Soybean Oil

(Million Metric Tons)

Total 81.94 35.47 8.52

------------------------------------Supply--------------------------------------

Beginning Stocks 5.85 0.32 1.1

Production 83.17 35.28 8.440

Imports --3 0.15 0.08

-------------------------------Disappearance---------------------------------

Crush 43.95 -- --

Feed, Seed & Residual 3.29 -- --

Domestic -- 27.40 7.98

Exports 34.69 8.07 0.54

Ending Stocks 7.48 0.27 1.10

Source: USDA-ERS (2012f; USDA-ERS, 2012g; USDA-ERS, 2012h)

1

Disappearance is the consumed supply 

2

Total supply includes imports

3

No data

are increasing the demand for soybean-based biodiesel. From 1999 to 2009, the consumption of 

soybean biodiesel has increased from 0.5 to 1,070 million gallons (ASA, 2012a).

There is consistent evidence that farmers obtain substantial financial and non-financial benefits 

as a result of adoption of GE crops. These benefits include an opportunity to increase income 

from off-farm labor; increased flexibility and simplicity in the application of pesticides; an 

ability to adopt more environmentally friendly farming practices; increased consistency of weed 

control; increased human safety; equipment savings; and labor savings (Fernandez-Cornejo and 

McBride, 2000; Fernandez-Cornejo and McBride, 2002; Marra et al., 2004; Fernandez-Cornejo 

et al., 2005; Duke and Powles, 2009; Hurley et al., 2009).

According to a USDA-Economic Research Service (ERS) analysis, total economic costs for 

organic soybean operations are substantially higher than for conventional operations (see Section 

2.1.4, Organic Soybean Production). Nevertheless, organic soybeans are more profitable 

because price premiums paid for organic soybeans compensate for higher production costs 

(USDA-ERS, 2009b). The USDA-ERS (2012i) reports that consumer demand for organic foods 

has shown double-digit growth for well over a decade. As discussed in Section 2.1.4, organic 

soybean production accounted for 0.09% of total U.S. production, and accounted for about 

0.14% of the overall soybean crop value in 2011. The majority of organic soybeans were

produced in midwestern states (see Table 10, U.S. certified organic soybean acres by state, 2011)

(USDA-NASS, 2012i; USDA-NASS, 2012a). 

65
Consumers attitudes towards GE products are driven by three main elements: perceived risks 

and benefits, individual values, and knowledge of the product (Costa-Font et al., 2008). In some 

countries, such as the United States, a majority of consumers find that the benefits of GE foods 

potentially outweigh the risk. In other countries such as much of the EU-27, the perceived risks 

outweigh any potential benefits (USDA-ERS, 2001; Costa-Font et al., 2008). From a review of 

surveys taken between 1992 and 2000, USDA-ERS found that consumer attitudes in the United 

States ranged between 51% and 75% favorable towards the use of biotechnology to improve 

foods, make foods taste better, stay fresh longer, or prevent crop disease (USDA-ERS, 2001). A 

2010 survey of U.S. households found that 93% of respondents believe that GE food should be 

labeled and 60% are willing to consume GE vegetables, fruits, and grains (Thomson-Reuters, 

2010). 

2.6.2 Trade Economic Environment

Soybean exports in the form of bulk beans, meal, and oil are a major share of the total 

agricultural exports for the United States, representing 20.1% of the total value of U.S. exports. 

The value of U.S. agricultural exports was $135.8 billion in 2012 (USDA-ERS, 2012n). Bulk 

soybeans accounted for $19.8 billion of this total, ranking first among all agricultural 

commodities, and soybean meal, at a value of $3.8 billion, ranked 10th (USDA-ERS, 2012l). 

Table 15presents the United States and the rest of the world’s soybean supply and disappearance 

for 2011/12. The United States was responsible for 38.2% of the world’s bulk soybean exports, 

13.4% of the world’s soybean meal exports, and 6.4% of the world’s soybean oil exports

(USDA-ERS, 2012b).

Table 15. United States and rest of world (ROW) soybean supply and disappearance1

2011/12.

Soybeans Soybean Meal Soybean Oil

U.S. ROW U.S. ROW U.S. ROW

(Million Metric Tons)

---------------------------------Supply--------------------------

Beginning Stocks 5.85 62.90 0.32 7.75 1.10 1.90

Imports 0.41 88.85 0.15 57.76 0.08 8.07

Production 83.17 161.89 35.28 142.60 8.44 33.59

----------------------------Disappearance1--------------------

Crush/Domestic Use 47.24 207.66 27.40 148.85 7.98 34.09

Exports 34.7 56.19 8.08 52.12 0.54 7.84

Ending Stocks 7.49 49.80 0.27 7.13 1.10 1.64

Source: USDA-ERS (2012b)

1

Disappearance is the consumed supply

In the 2012/13 market year, soybean meal represented 68% of the protein meal produced 

worldwide, though soybean ranked behind palm in terms of worldwide vegetable oil production 

(USDA-FAS, 2013). Similarly, soybean held the largest share of protein meal consumed 

worldwide mainly as animal feed (USDA-FAS, 2013), with soybean oil again coming in second 

behind palm oil in terms of worldwide vegetable oil consumption (USDA-FAS, 2013). In 

2011/12, the United States, Brazil, and Argentina were the major producers of soybean, 

66
producing 190.8 million metric tons (80.0%) of the world’s soybeans Table 16). The United 

States was responsible for 33.9% of the world’s soybean production, 19.8% of world’s soybean 

meal production, and 20.1% of the world’s soybean oil production (USDA-ERS, 2012b). The 

United States, China, Argentina, and Brazil are the major producers of soybean meal and 

soybean oil. 

Table 16. World soybean production in 2011/12.

Location Soybean Soybean Meal Soybean Oil

(Million Metric Tons)

Argentina 40.1 27.9 6.8

Brazil 66.5 28.6 7.1

Canada 4 --1 --

China 14.5 48.2 10.9

EU-272 -- 9.6 2.2

India 11.0 7.7 1.7

Mexico -- 2.8 0.6

Paraguay 4.4 -- --

United States 84.2 37.2 9.0

Other 13.8 17.2 4.0

Source:USDA-FAS (2013)

1

No Data

2

European Union 27 member countries

The United States, along with Brazil, Argentina, Paraguay, and Canada, account for 96.1% of the 

bulk soybean exported, while Argentina, Brazil, the United States, India, and Paraguay account 

for 90.4% of the soybean meal exported Table 17). Argentina, the European Union 27 member 

countries (EU-27), and Brazil are the dominant countries in terms of soybean oil exports 

accounting for 75.4% (Table 17). Table 18presents the top 10 U.S. export markets for soybean 

by volume in two periods spanning 2011 and 2012, of which China, Mexico, and EU-27 

countries are the top three importers (USDA-ERS, 2013d). In FY 2012, U.S. exports of soybean 

were valued at $19.80 billion, soybean meal approximately $3.88 billion, and soybean oil 

approximately $0.83 billion (USDA-ERS, 2012j). 

China, the EU-27, Mexico, and Japan are the major importers of world bulk soybean, accounting 

for 82.9% of total imports, whereas the EU-27, Indonesia, Thailand, Japan and Vietnam are the 

largest importers of soybean meal with a world share of 55.0% (USDA-FAS, 2013). For 

soybean oil, China and India are the major importers with a world share of 35.8% (USDA-FAS, 

2013). U.S. soybean exports are projected to increase to approximately 1.6 billion bushels (43.4 

million MT) for the 2021/22 market year (USDA-OCE, 2012).

.

67
Table 17. World soybean exports in 2011/12.

Location Soybean Bulk Soybean Meal Soybean Oil

(Million Metric Tons)

Argentina 7.4 26.0 3.8

Bolivia --1 -- 0.3

Brazil 36.3 14.7 1.9

Canada 2.9 -- --

EU-272 -- -- 0.7

India -- 4.5 --

Paraguay 3.2 0.7 0.2

Russia -- -- 0.1

United States 37.1 8.8 0.7

Other 3.5 4.0 0.8

Source: USDA-FAS (2013)

1

No Data

2

European Union 27 member countries 

Table 18. Top 10 U.S. soybean export markets in 2011/12.

Location

JanuaryNovember 2011JanuaryNovember 2012 November 2011 November 2012

(Million Metric Tons)

China 17.76 23.09 3.91 4.95

Mexico 2.98 3.08 0.22 0.23

EU-27 1.50 2.12 0.18 0.47

Japan 1.54 1.81 0.15 0.21

Indonesia 1.56 1.64 0.14 0.06

Taiwan 1.20 1.24 0.09 0.20

Egypt 0.58 1.23 0.01 0.09

Turkey 0.20 0.65 0.02 0.09

Thailand 0.31 0.65 0.08 0.16

South Korea 0.43 0.58 0.01 0.05

World Total 30.26 38.30 5.01 6.91

Source:USDA-ERS (2013d)

1

European Union 27 member countries

2

No data

Worldwide prices for grain and oilseed crops such as soybean are influenced not only by supply 

and demand forces, but also a multitude of other factors. In 2008, world market prices on food 

commodities such as grains and vegetable oils rose sharply (Trostle, 2008b). There were many 

factors that contributed to the rise in prices, including an increased growth in demand outpacing 

the growth in production that tightened world balances of grain and oilseeds, increased demand

for biofuel feedstocks, weather conditions, the value of the U.S. dollar, increasing costs for 

energy, increasing costs for agricultural production, a rise in foreign exchange holdings by major 

food-importing countries, and policies adopted by exporting and importing countries to relieve 

food price inflation. Later in 2008, however, soybean prices declined considerably, influenced by 

factors such as a larger yield than expected after floods in the Midwest and problems with the 

68
United States and world credit markets (Trostle, 2008b; Trostle, 2008a; Irwin and Good, 2009). 

The recent influx of hedge, index, and sovereign wealth fund investors and the increased practice 

of trend-following trading practices by some of these fund managers has increased agricultural 

product price volatility (Trostle, 2008a). Other factors contributing to grain and oilseed price 

includes competition for plantings from other crops, fluctuations in livestock production, world

population growth, per capita income, water availability, the influx of new seed varieties and 

new biotechnology, and climate change (Trostle, 2008b; Irwin and Good, 2009; USDA-OCE, 

2012).

Between 1996 and 2011, 28 countries, besides the United States, adopted the use of GE crops, 

the largest being Brazil, Argentina, India, and Canada (Clive, 2011). Prior to exporting MON 

87712-4 soybean, Monsanto would seek biotechnology regulatory approvals in all major import 

countries that have a functioning regulatory system to assure global compliance and support of 

international trade (Monsanto, 2011). Furthermore, all trade actions will be consistent with the 

Biotechnology Industry Organization’s Guide for Project Launch. Some countries will not allow 

the seed availability for GE crop production from U.S. companies until a non-regulated status 

has been approved by APHIS; however, APHIS does not influence in which countries a 

particular crop will be marketed.

69
3 ALTERNATIVES

This document analyzes the potential environmental consequences of a determination of 

nonregulated status of MON 87712 soybean. To respond favorably to a request for a 

determination of nonregulated status, APHIS must determine that MON 87712 soybean is 

unlikely to pose a plant pest risk. Based on its PPRA (USDA-APHIS, 2011a), APHIS has 

concluded that MON 87712 soybean is similar to its antecedent A3525 and other commercially 

available soybean cultivars, and is unlikely to pose a plant pest risk. Therefore APHIS must 

determine that MON 87712 soybean is no longer subject to 7 CFR part 340 or the plant pest 

provisions of the Plant Protection Act. 

Two alternatives are evaluated in this EA: (1) no action and (2) determination of nonregulated 

status of MON 87712 soybean. APHIS has assessed the potential for environmental impacts for 

each alternative in the Environmental Consequences section.

3.1 No Action Alternative: Continuation as a Regulated Article

Under the No Action Alternative, APHIS would deny the request. MON 87712 soybean and 

progeny derived from MON 87712 soybean would continue to be regulated articles under the 

regulations at 7 CFR part 340. Permits issued or notifications acknowledged by APHIS would 

still be required for introductions of MON 87712 soybean and measures to ensure physical and 

reproductive confinement would continue to be implemented. APHIS might choose this 

alternative if there were insufficient evidence to demonstrate that unconfined cultivation of MON 

87712 soybean does not pose a plant pest risk. 

This alternative is not the Preferred Alternative because APHIS has concluded through a Plant 

Pest Risk Assessment that MON 87712 soybean is unlikely to pose a plant pest risk (USDAAPHIS, 2011a). Choosing this alternative would not satisfy the purpose and need of making a 

determination of plant pest risk status and responding to the request for nonregulated status. 

3.2 Preferred Alternative: Approve the Request for Nonregulated Status to MON 87712-

4 Soybean

Under this alternative, MON 87712 soybean and progeny derived from it would no longer be 

regulated articles under the regulations at 7 CFR part 340. MON 87712 is unlikely to pose a 

plant pest risk (USDA-APHIS, 2011a). Permits issued or notifications acknowledged by APHIS 

would no longer be required for introductions of MON 87712 soybean and progeny derived from 

this event. This alternative best meets the purpose and need to respond appropriately to a request 

for nonregulated status based on the requirements in 7 CFR part 340 and the agency’s authority 

under the plant pest provisions of the Plant Protection Act. Because the agency has concluded 

that MON 87712 is unlikely to pose a plant pest risk, a determination of nonregulated status of 

MON 87712 soybean is a response that is consistent with the plant pest provisions of the Plant 

Protection Act, the regulations codified in 7 CFR part 340, and the biotechnology regulatory 

policies in the Coordinated Framework.

70
Under this alternative, growers may have future access to MON 87712 soybean and progeny 

derived from this event if the developer decides to commercialize MON 87712 soybean. 

3.3 Alternatives Considered But Rejected from Further Consideration

APHIS assembled a list of alternatives that might be considered for MON 87712 soybean. The 

agency evaluated these alternatives, in light of the agency's authority under the plant pest 

provisions of the Plant Protection Act, and the regulations at 7 CFR part 340, with respect to 

environmental safety, efficacy, and practicality to identify which alternatives would be further 

considered for MON 87712 soybean. Based on this evaluation, APHIS rejected several 

alternatives. These alternatives are discussed briefly below along with the specific reasons for 

rejecting each.

3.3.1 Prohibit Any MON 87712 Soybean from Being Released

In response to public comments that stated a preference that no GE organisms enter the 

marketplace, APHIS considered prohibiting the release of MON-87712 soybean, including 

denying any permits associated with the field testing. APHIS determined that this alternative is 

not appropriate given that APHIS has concluded that MON 87712 soybean is unlikely to pose a 

plant pest risk (USDA-APHIS, 2011a).

In enacting the Plant Protection Act, Congress found that 

[D]ecisions affecting imports, exports, and interstate movement of products 

regulated under [the Plant Protection Act] shall be based on sound science...§402(4).

On March 11, 2011, in a Memorandum for the Heads of Executive Departments and Agencies, 

the White House Emerging Technologies Interagency Policy Coordination Committee developed 

broad principles, consistent with Executive Order (EO) 13563, to guide the development and 

implementation of policies for oversight of emerging technologies (such as genetic engineering) 

at the agency level. In accordance with this memorandum, agencies should adhere to EO 13563 

and, consistent with that EO, the following principle, among others, to the extent permitted by 

law, when regulating emerging technologies: 

“[D]ecisions should be based on the best reasonably obtainable scientific, technical, 

economic, and other information, within the boundaries of the authorities and 

mandates of each agency” 

Based on the PPRA (USDA-APHIS, 2011a) and the scientific data evaluated therein, APHIS 

concluded that MON 87712 soybean is unlikely to pose a plant pest risk. Accordingly, there is 

no basis in science for prohibiting the release of MON 87712 soybean. 

3.3.2 Isolation Distance between MON 87712 Soybean and Non-GE Soybean Production and 

Geographical Restrictions

In response to public concerns of gene movement between GE and non-GE plants, APHIS 

considered requiring an isolation distance separating MON 87712 soybean from conventional or 

specialty soybean production. However, because APHIS has concluded that MON 87712

71
soybean is unlikely to pose a plant pest risk (USDA-APHIS, 2011a), an alternative based on 

requiring isolation distances would be inconsistent with the statutory authority under the plant 

pest provisions of the Plant Protection Act and regulations in 7 CFR part 340. 

APHIS also considered geographically restricting the production of MON 87712 soybean based 

on the location of production of non-GE soybean in organic production systems or production 

systems for GE-sensitive markets in response to public concerns regarding possible gene 

movement between GE and non-GE plants. However, as presented in APHIS’ PPRA for MON 

87712 soybean, there are no geographic differences associated with any identifiable plant pest 

risks for MON 87712 soybean (USDA-APHIS, 2011a). This alternative was rejected and not 

analyzed in detail because APHIS has concluded that MON 87712 soybean does not pose a plant 

pest risk and will not exhibit a greater plant pest risk in any geographically restricted area. 

Therefore, such an alternative would not be consistent with APHIS’ statutory authority under the 

plant pest provisions of the Plant Protection Act and regulations in Part 340 and the 

biotechnology regulatory policies embodied in the Coordinated Framework.

Based on the foregoing, the imposition of isolation distances or geographic restrictions would not 

meet APHIS’ purpose and need to respond appropriately to a request for nonregulated status

based on the requirements in 7 CFR part 340 and the agency’s authority under the plant pest 

provisions of the Plant Protection Act. However, individuals might choose on their own to 

geographically isolate their non-GE soybean production systems from MON 87712 soybean or to 

use isolation distances and other management practices to minimize gene movement between 

soybean fields. Information to assist growers in making informed management decisions for 

MON 87712 soybean is available from AOSCA (AOSCA, 2010).

3.3.3 Requirement of Testing for MON 87712 Soybean

During the comment periods for other petitions for nonregulated status, some commenters 

requested USDA to require and provide testing for GE products in non-GE production systems. 

APHIS notes there are no nationally-established regulations involving testing, criteria, or limits 

of GE material in non-GE systems. Such a requirement would be extremely difficult to 

implement and maintain. Additionally, because MON 87712 soybean does not pose a plant pest 

risk (USDA-APHIS, 2011a), the imposition of any type of testing requirements is inconsistent 

with the plant pest provisions of the Plant Protection Act, the regulations at 7 CFR part 340 and 

biotechnology regulatory policies embodied in the Coordinated Framework. Therefore, 

imposing such a requirement for MON 87712 soybean would not meet APHIS’ purpose and 

need to respond appropriately to the request in accordance with its regulatory authorities. 

3.4 Comparison of Alternatives 

Table 19presents a summary of the potential impacts associated with selection of either of the 

alternatives evaluated in this EA. The impact assessment is presented in Section 4, 

Environmental Consequences of this EA. 

72
Table 19. Summary of issues of potential impacts and consequences of alternatives.

Attribute /

Measure

Alternative A: No Action Alternative B: Determination of 

Nonregulated Status

Meets Purpose 

and Need and 

Objectives

No Yes

Unlikely to 

pose a plant 

pest risk

Satisfied through use of regulated field 

trials

Satisfied – risk assessment

(USDA-APHIS, 2011a)

Management Practices

Acreage and 

Areas of 

Soybean 

Production

Current trends in cultivation and the 

proportion of crop acreage planted 

with soybean would continue. The 

majority of soybean produced in the 

United States would be in the same 31 

states as today. The trend of planting 

primarily GE soybeans would likely 

continue. Average U.S. soybean yield 

is expected to continue to increase 

without expansion of soybean acreage.

The acreage and area of production 

would remain unchanged from that of 

the No Action Alternative. There are no 

substantial agronomic or phenotypic 

differences between MON 87712

soybean and its comparators and it is 

subject to the same variables that 

influence yield in other varieties. The 

increased yields are the result of changes 

during the reproductive growth stages 

that lead to an increased number of seeds 

and seed weight. Soybean acreage is 

expected to remain relatively stable 

through 2021/2022 while soybean yield 

is expected to increase by about 11% 

over the same period.

Agronomic 

Practices

Soybean management practices and 

methods that increase yield such as 

tillage methods, fertilization, crop 

rotation, irrigation, pest management, 

and plant residue management would 

be expected to continue.

Testing indicates the agronomic 

characteristics and cultivation practices 

used for the production of MON 87712

soybean are essentially the same as those 

used for the cultivation of other 

commercially available soybean and 

would remain unchanged from the No 

Action Alternative. MON 87712

soybean does deplete higher amounts of 

potassium and phosphorus from the soil, 

yet the need for fertilization would be

similar to those of other high-yield 

varieties or the production strategies

used by growers to maximize the yields 

of any typically average yielding 

conventional or GE varieties.

73
Attribute /

Measure

Alternative A: No Action Alternative B: Determination of 

Nonregulated Status

Pesticide Use

Pest management practices would 

continue to rely on the use of pesticides

and fungicides to control insect, fungal, 

and weed pests. It is expected the use of 

glyphosate on glyphosate-resistant 

soybeans would remain the principle 

method for weed management

Testing shows MON 87712 soybean is 

vulnerable to the same pests that effect 

other commercially available 

conventional and GE soybean varieties 

and as such pest management practices 

would not change from those used 

under the No Action Alternative. 

Soybean Seed 

Production

The production of foundation, 

registered, certified, or quality control 

seed would still require biological, 

technical, and quality control factors to 

ensure varietal purity. 

Practices to ensure varietal purity 

would remain the same as those of the 

No Action Alternative. Tests would be 

available and easily accomplished to 

determine the presence of the gene 

which conveys the increased yield 

traits of MON 87712 soybean.

Organic 

Soybean 

Production

The methods applied in certified seed 

production systems designed to 

maintain soybean seed identity and 

meet National Organic Standards as 

established by the NOP would continue 

to be practiced by farmers producing 

organic soybean. The availability of GE 

soybean is unrelated to proportion of 

organic soybean market share. 

Measures used by organic soybean 

producers to manage, identify, and 

preserve organic production systems 

would not change. Similar to other 

commercially available GE soybean 

varieties, MON 87712 soybean does 

not present any new or different issues 

or impacts for organic soybean 

producers or consumers.

Physical Environment

Soil Quality

Cropping practices that impact soil such 

as tillage, contouring, cover crops; 

agricultural chemical management, and 

crop rotation would continue. The 

fertility of some U.S. cropland is 

declining as a result of increasing crop 

yields without proper fertilization.

Production of MON 87712 soybean is 

not expected to change cropping 

practices. Root exudates from MON 

87712 soybean are not expected to 

change soil physicochemical 

characteristics. Similar to current high 

yield production strategies, increased 

depletion of nutrients such as 

phosphorus and potassium from the 

production of MON 87712 soybean 

can be mitigated through the common 

practices of regular testing of soil 

fertility and application of nutrients as 

needed. 

74
Attribute /

Measure

Alternative A: No Action Alternative B: Determination of 

Nonregulated Status

Water 

Resources

Agronomic practices that could impact 

water resources (e.g., irrigation, tillage 

practices, and the application of 

pesticides and fertilizers) would be 

expected to continue. The use of 

pesticides in accordance with EPAapproved label directions assure no

unreasonable risks to water quality from 

their use. The historic trend of increased 

soybean yields on existing cropland 

would likely continue, minimizing 

potential impacts to water resources 

from expanding cultivation. 

The production of MON 87712

soybean is not expected to change 

current agronomic practices, acreage, 

or range of production that may impact 

water resources. 

Air Quality

Soybean agronomic practices having 

potential to impact air quality such as 

tillage, the application of pesticides and 

fertilizer, and use of particulate- and 

pollutant -emitting agricultural 

equipment would continue. The use of 

pesticides in accordance with EPAapproved labels minimizes drift and 

reduces environmental impacts. 

Conservation tillage or no-till practices 

associated with the adoption of 

herbicide-resistant soybean is expected 

to continue.

No changes to agronomic practices for 

the production of MON 87712 soybean 

are expected that would impact air 

quality. The application of pesticides 

and use of conservation tillage and notill practices would likely be similar to 

the No Action Alternative. 

Climate Change

Agronomic practices having the 

potential to impact climate change, such 

as the release of CO2 to the atmosphere 

from tillage, machinery powered by 

fossil fuel, and NO2 emissions 

associated with nitrogen fertilizers 

would continue. The trend towards 

conservation tillage practices that 

contribute to carbon sequestration and 

application of more phosphorous and 

potassium associated with high yield 

soybean production would also likely 

continue.

The production of MON 87712

soybean is not expected to change 

current soybean cropping practices that 

may impact GHG emissions. The 

potential increased application of 

phosphorus and potassium associated 

with the production of high yield 

soybean would not impact climate 

change.

Biological Resources

75
Attribute /

Measure

Alternative A: No Action Alternative B: Determination of 

Nonregulated Status

Animal

Communities

Conventional and nonregulated GE 

soybean have been determined to have 

no allergenic or toxicity to animal 

communities. Soybean agronomic 

practices such as such as tillage, 

cultivation, pesticide, herbicide and 

fertilizer applications, and the use of 

agricultural equipment would continue 

to impact animal communities. The use 

of EPA-registered pesticides and 

herbicides in accordance with EPAapproved labels minimize potential 

impacts to animal communities.

Testing demonstrates consumption of 

MON 87712 soybean poses no 

allergenic or toxicity risk to animal 

communities. As field trials 

demonstrate growth and disease 

characteristics of MON 87712 are 

similar to other conventional soybean. 

No change to soybean agronomic 

practices that may impacting animal 

communities would be needed to 

cultivate MON 87712 soybean.

76
Attribute /

Measure

Alternative A: No Action Alternative B: Determination of 

Nonregulated Status

Plant Communities

The majority of soybean acres would 

likely continue to be planted with GE 

varieties. Plant species typically 

competing with soybean production 

would be managed through the use of 

mechanical, cultural, and chemical control 

methods. Multiple herbicides would likely 

continue to be used for weed control in 

soybean fields and glyphosate would 

continue to be the primary herbicide 

applied in the near term; however, 

diversification of herbicide use and 

agronomic measures to deter development 

of herbicide-resistant weeds would likely 

increase. Herbicide use in accordance 

with EPA-approved labels containing 

measures to reduce herbicide drift and 

volatilization potentially impacting plant 

communities minimize potential adverse 

impacts to plant communities. Soybean 

volunteers would continue to be 

controlled with mechanical and herbicidal 

practices. Weeds competing with soybean 

production would be managed through the 

use of mechanical, cultural, and chemical 

control methods. Multiple herbicides 

would likely continue to be used for weed 

control in soybean fields and glyphosate 

would continue to be the primary 

herbicide applied in the near term; 

however, diversification of herbicide use 

and agronomic measures to deter 

development of herbicide-resistant weeds 

would likely increase. Herbicide use in 

accordance with EPA-approved labels 

containing measures to reduce herbicide 

drift and volatilization potentially 

impacting plant communities minimize 

potential adverse impacts to plant 

communities. Soybean volunteers would 

continue to be controlled with mechanical 

and herbicidal practices. 

No changes to agronomic practices 

potentially impacting plant communities 

would be needed to cultivate MON 87712

soybean. Field trials and laboratory 

analyses show no differences between 

MON 87712 soybean and other GE and 

non-GE soybean in growth, reproduction, 

or interactions with pests and diseases

that may impact plant communities. 

Volunteers of MON 87712 soybean 

would be managed similar to other 

nonregulated soybean varieties. 

77
Attribute /

Measure

Alternative A: No Action Alternative B: Determination of 

Nonregulated Status

Gene 

Movement

MON 87712 would continue to be 

cultivated only under regulated 

conditions. The availability of GE, nonGE and organic soybeans would not 

change as a result of the continued 

regulation of MON 87712 soybean. 

Because soybean is highly selfpollinated and its pollination rate 

significantly decreases with distance, it 

is not frost tolerant, does not reproduce 

vegetatively, its seed is not easily 

dispersed, any volunteers that persist in 

warmer U.S. climates can be easily 

controlled with common agronomic 

practices, and there are no wild soybean 

species or near relatives in the U.S., 

gene flow and introgression from 

soybean to wild or weedy species are 

highly unlikely.

Field and laboratory tests demonstrate 

no significant differences among the 

parameters that may lead to an 

increased potential for gene flow or 

weediness between MON 87712

soybean and the conventional control.

MON 87712 soybean would not persist 

in unmanaged environments and does 

not demonstrate a competitive 

advantage compared to conventional 

soybean. The trait for increased yield is 

not expected to contribute to increased

weediness without changes in a 

combination of other characteristics 

associated with weediness. 

Soil 

Microorganisms

MON 87712 soybean would remain 

under APHIS regulation. The 

availability of GE, non-GE and organic 

soybeans would not change as a result 

of the continued regulation of MON 

87712 soybean. Agronomic practices 

used for soybean production, such as 

soil inoculation, tillage and the 

application of agricultural chemicals 

(pesticides and fertilizers) that 

potentially impact microorganisms 

would continue. 

Nonregulated status of MON 87712

soybean is not expected to result in 

changes in current soybean cropping 

practices that may impact 

microorganisms. Field and greenhouse 

tests show no significant differences

from other nonregulated soybean 

varieties in the parameters measured to 

assess the symbiotic relationship of 

MON 87712 and rhizobia or its 

responses to abiotic stressors, 

suggesting no different impact to the 

microbial community.

Biological 

Diversity

MON 87712 would remain under 

APHIS regulation; the availability of 

GE, non-GE and organic soybeans 

would not change. Agronomic practices 

used for soybean production and yield 

optimization, such as tillage, the 

application of agricultural chemicals 

(pesticides and fertilizers), timing of 

planting, row spacing, and scouting 

would be expected to continue. 

Agronomic practices that benefit 

biodiversity both on cropland (e.g., 

intercropping, agroforestry, crop 

rotations, cover crops, and no-tillage) 

and on adjacent non-cropland (e.g., 

woodlots, fencerows, hedgerows, and 

Nonregulated status of MON 87712

would not cause changes in current 

soybean cropping practices that may 

impact biodiversity as field and 

laboratory testing demonstrate its 

growth, reproduction, and interactions 

with pests and diseases are similar to 

other nonregulated varieties. MON 

87712 soybean poses no potential for 

naturally occurring, pollen-mediated 

gene flow and transgene introgression 

and as such is not expected to affect 

genetic diversity.

78
Attribute /

Measure

Alternative A: No Action Alternative B: Determination of 

Nonregulated Status

wetlands) would continue.

Human and Animal Health

Human Health

MON 87712 soybean would remain 

under APHIS regulation and no change 

to human exposure to existing GE and 

non-GE soybean varieties would occur. 

Compositional and nutritional 

characteristics of nonregulated GE 

soybean varieties have been determined 

to pose no risk to human health. A 

variety of EPA-approved pesticides 

would continue to be used for pest 

management in both GE and non-GE 

soybean cultivation. Use of registered 

pesticides in accordance with EPAapproved labels protects human health 

and worker safety. EPA also establishes 

tolerances for pesticide residue that give

a reasonable certainty of no harm to the 

general population and any subgroup 

from the use of pesticides at the 

approved levels and methods of 

application.

Testing shows the MON 87712 BBX32 

protein has no amino acid sequence 

similar to known allergens, lacks toxic 

potential to mammals, and was 

degraded rapidly and completely in 

simulated gastric fluid. Monsanto has 

initiated a food/feed safety consultation 

on MON 87712 soybean with the FDA 

and a final decision from 

FDA is pending. Laboratory and field 

testing also demonstrate no 

biologically meaningful differences for 

compositional and nutritional 

characteristics between the MON 

87712 soybean and conventional 

soybean varieties. Field testing shows 

MON 87712 is similar in growth and 

habit to other conventional soybean 

and no change to agronomic practices 

would be required for its cultivation. 

No change to human health or worker 

safety would occur from determining 

MON 87712 nonregulated.

Animal Feed

MON 87712 would remain regulated 

and not be allowed for distribution to 

the animal feed market. Soybean-based 

animal feed would still be available 

from currently cultivated soybean 

crops, including both GE and non-GE 

soybean varieties. Nonregulated GE 

soybean varieties used as animal feed 

have been previously determined to 

pose no risk to animal health. 

Safety testing of MON 87712 soybean 

BBX32 protein shows it has no amino 

acid sequence similar to known 

allergens, lacks toxic potential to 

mammals, and was degraded rapidly 

and completely in simulated gastric 

fluid, indicating no potential risk for 

its use as animal feed. Monsanto has 

initiated a food/feed safety 

consultation on MON 87712 soybean 

with the FDA and a final decision 

from FDA is pending. Testing shows 

compositional and nutritional 

characteristics of MON 87712 soybean 

grain and forage are similar to 

currently available soybean varieties 

and no adverse impacts to animal feed 

would occur upon its nonregulated 

status. Impacts to animal feed safety 

would therefore be similar to the No 

Action Alternative.

Socioeconomic 

79
Attribute /

Measure

Alternative A: No Action Alternative B: Determination of 

Nonregulated Status

Domestic 

Economic 

Environment

MON 88712-4 soybean would remain 

regulated by APHIS. Domestic growers 

would continue to utilize GE and nonGE soybean varieties based upon 

availability and market demand. U.S. 

soybeans would likely continue to be

used domestically for animal feed, with 

lesser amounts and byproducts used for 

oil or fresh consumption. Agronomic 

practices and conventional breeding

techniques using GE herbicide- and 

pest-resistant cultivars currently used to 

optimize yield and reduce production 

costs would be expected to continue. 

Average soybean yield is expected to 

continue to increase without expansion 

of soybean acreage while grower net 

returns are estimated to increase.

Field tests show the performance and 

composition of MON 87712 is not 

substantially different from that of 

other conventional soybean reference 

varieties. Although yield potential is 

increased, it would be similar to other 

commercially available soybean 

varieties with a multigenic high yield 

trait; both are subject to the same 

variables affecting agronomic practices

and yields as other varieties. MON 

87712 soybean would likely replace 

other varieties of GE soybean on 

existing cropland and not impact 

organic soybean production or markets. 

As MON 87712 is a GE soybean 

variety potentially increasing soybean

productivity without altering soybean’s 

nutritional value, potential 

allergenicity, or toxicity. If planted in 

favorable environments, soybean 

growers could potentially have greater 

yield for similar inputs. No change to

U.S. consumer attitudes towards GE 

crops is expected. No adverse impact to 

the domestic economic environment 

would occur under this alternative. 

Trade Economic 

Environment

U.S. soybeans will continue to play a 

role in global soybean production, and 

the United States will continue to be a 

supplier in the international market if 

MON 87712 remains regulated by 

APHIS. Although U.S. global exports 

are expected to increase overall, 

increasing foreign competition is 

expected to reduce U.S. export share by 

5% in the next 20 years.

A determination of nonregulated status 

of MON 87712 soybean is not expected 

to adversely impact the current trends 

affecting the trade economic 

environment. However, the 

determination may have an impact 

through increased yields and higher US 

production of soybean. Any impact to 

soybean market prices from the 

potential increase to yield from the 

production of MON 87712 soybean 

would likely be small because the 

increased yield of MON 87712 is 

similar to production of other high 

yielding soybeans already in the 

market, and is subject to the same 

variables that affect yield in other 

commercially available cultivars. If 

however, there is an immediate and 

general incorporation of the trait into 

much of the developer’s varieties, and a 

80
Attribute /

Measure

Alternative A: No Action Alternative B: Determination of 

Nonregulated Status

uniform positive yield response across 

many environments, there may be an 

important increase in U.S. soybean 

production. However, because there 

are presently high yield varieties 

available, and these have not resulted in 

an apparent or large incremental

increase in soybean productivity, 

APHIS does not expect that 

nonregulated status for MON 87712 

will importantly increase overall bulk 

soybean production, at least not one 

that greatly exceeds the general annual 

trend for increased soybean yield.

Monsanto plans to seek biotechnology 

regulatory approvals for MON 87712

soybean from all key soybean import 

countries that have a functioning 

regulatory system.

Other Regulatory Approvals

U.S.

Final FDA food safety consultation in 

progress. EPA tolerance exemptions 

and conditional pesticide registrations 

granted.

Final FDA food safety consultation in 

progress. EPA tolerance exemptions 

and conditional pesticide registrations 

granted.

Other countries Unchanged China, Japan, Canada, Mexico, 

European Food Safety Authority

Compliance with Other Laws

CWA, CAA, 

EOs 

Fully compliant Fully compliant

4 ENVIRONMENTAL CONSEQUENCES

Potential environmental impacts from the No Action Alternative and the Preferred Alternative 

for MON 87712 soybean are described in detail throughout this section. An impact would be the 

result of any change, positive or negative, from the existing (baseline) conditions of the affected 

environment (described for each resource area in Section 2.0). Impacts may be categorized as 

direct, indirect or cumulative. A direct impact is an effect that results solely from a proposed 

action without intermediate steps or processes. Examples include soil disturbance, air emissions, 

and water use. An indirect impact may be an effect that is related to but removed from a 

proposed action by an intermediate step or process. Examples include surface water quality 

changes resulting from soil erosion due to increased tillage, and worker safety impacts resulting 

from an increase in herbicide use.

A cumulative impacts analysis is also included for each environmental issue and is presented in 

Section 5. A cumulative impact may be a consequence for the human environment which results 

from the incremental impact of the proposed action when added to other past, present, and 

reasonably foreseeable future actions. Examples include breeding MON 87712 soybean with 

81
other events previously approved for nonregulated status. If there are no direct or indirect 

impacts identified for a resource area, then there can be no cumulative impacts. Cumulative 

impacts are discussed in Section 5.

Where it is not possible to quantify impacts, APHIS provides a qualitative assessment of 

potential impacts. Certain aspects of the MON 87712 soybean and its cultivation may be no 

different between the alternatives; those are described below.

4.1 Scope of Analysis

For the discussion of environmental consequences, this section addresses the following principal 

areas of potential environmental concern:

• Agricultural Production of Soybean (Subsection 4.2);

• Physical Environment (Subsection 4.3);

• Biological Resources (Subsection 4.4);

• Human Health (Subsection 4.5);

• Animal Feed (Subsection 4.6); and

• Socioeconomic Impacts (Subsection 4.7).

Under the Preferred Alternative, MON 87712 soybean could be planted anywhere in the United 

States; however, APHIS has limited the environmental analysis to those areas that currently 

support soybean production. According to USDA annual crop statistics, soybean-producing 

states in the United States include 31 states that largely encompass the southeast and midwest 

regions (USDA-NASS, 2012l) (see Subsection 2.1.1, Acreage and Area of Soybean Production, 

Table 1).

The environmental consequences of the different alternatives described above are analyzed under 

the assumption that farmers who produce conventional soybean, MON 87712 soybean or 

soybean using organic methods are using reasonable, commonly accepted best management 

practices for their chosen system and varieties during agricultural soybean production; however, 

APHIS recognizes that not all farmers follow these best management practices for soybean. 

Thus, the analyses of potential environmental impacts will also include the assumption that some 

farmers do not follow these best management practices.

Monsanto plans to stack varieties of soybean wherein the MON 87712 soybean is combined 

using traditional hybridization techniques with other non-GE traits or previously nonregulated 

GE soybean varieties. The range of potential stacked varieties could include stacked hybrids 

incorporating glyphosate herbicide resistance, or other defensive traits. APHIS does not have 

jurisdiction under the PPA and Part 340 to review such hybrids expressing stacked traits from 

nonregulated articles developed using conventional hybridization techniques where there is no 

evidence of a plant pest risk. APHIS considers the future development of these stacked hybrids a 

speculative event, and, accordingly, evaluates these stacked varieties only in the cumulative 

impacts analyses where appropriate. Issues associated with potential future stacking are 

presented and discussed in the cumulative impacts analyses where appropriate.

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4.2 Agricultural Production of Soybean

Best management practices are commonly accepted, practical ways to grow soybean, regardless 

of whether the soybean farmer is using organic practices or conventional practices with non-GE 

or GE varieties. These management practices consider crop-specific planting dates, seeding 

rates, and harvest times, among others. Over the years, soybean production has resulted in wellestablished management practices that are available through state Cooperative Extension Service 

offices and their respective websites9. 

4.2.1 Acreage and Area of Soybean Production

No Action Alternative

Under the No Action Alternative, MON 87712 soybean would remain regulated and would not 

be commercially available for production. Soybeans will continue to be a major crop in the 

United States for the foreseeable future (USDA-OCE, 2012). Existing trends related to the 

cultivation and proportions of crop acreage planted with soybean in the United States are 

expected to continue as discussed in Section 2.1.1, Acreage and Area of Soybean Production and 

below. Soybean is a quantitative (facultative) short-day plant, flowering more quickly under 

short days (OECD, 2000), thus responses to photoperiod and temperature are important in 

determining where specific cultivars will be adapted. Soybean cultivars are identified based on 

geographic bands of adaptation that run east-west, determined by latitude and day length. In 

North America, there are 13 maturity groups within which cultivars are described as early, 

medium, or late maturing (OECD, 2000).

Under the No Action Alternative, the majority of soybean is expected to continue to be 

commercially produced in the same 31 states as today. U.S. soybean acreage is concentrated 

where soybean yields are highest, primarily in the Midwest (USDA-ERS, 2006c). More 

recently, soybean acreage has expanded to the northern and western parts of the country. 

Stagnant yields in wheat coupled with better yielding short-season soybeans adapted to the 

climate in these areas are newly available to growers (USDA-ERS, 2010b). These factors have

increased the overall acreage devoted to soybean production in the U.S. Soybean production 

acreage increased 31% from 1992 to 2012, but has remained relatively level the last several years 

at approximately 75 million acres (USDA-NASS, 2012h). The USDA projects U.S. soybean 

acreage will remain relatively steady at approximately 76 million acres from 2013/2014 to 

2021/2022. While US exports will be decreasing because of increased foreign competition, 

rising domestic demand for soybean oil to manufactured biodiesel is noted (USDA-OCE, 2012); 

the trend is also balanced by increasing foreign demand because of rising income and population 

in Latin America and other parts of the world (USDA-OCE, 2012). 

Since the introduction of GE soybeans in the United States in 1996 (Fernandez-Cornejo and 

Caswell, 2006; USDA-ERS, 2011a), the proportion of GE soybean planted has increased to 93% 

of all planted soybean acreage (USDA-ERS, 2012e) because of the benefits gained from 

improved weed control from herbicide and pest-resistant varieties. The trend of planting 

9

For example, see the soybean crop management websites of Purdue University 

(http://www.agry.purdue.edu/ext/soybean/index.html), the University of Illinois-Urbana Crop Science and Research 

Education (http://web.extension.illinois.edu/csrec/), and Mississippi State University 

(http://msucares.com/crops/soybeans/index.html).

83

 
primarily GE soybeans in the United States will likely continue under the No Action Alternative 

as new cultivars are developed with new traits or that combine traits desired by growers and 

consumers. For example, petitions submitted to APHIS for approval of nonregulated status of 

cultivars that combine resistance to multiple herbicides, provide insect resistance, or change 

nutritional properties of soybean are currently pending (USDA-APHIS, 2013). 

With continuation of these trends, the number of states and areas of the United States involved in 

soybean cultivation is not expected to change. Additionally, acreage devoted to U.S. soybean 

production is expected to remain relatively stable for the foreseeable future, and the majority of 

soybeans planted would likely remain GE.

Preferred Alternative

Monsanto conducted phenotypic, agronomic, and environmental interaction trials with MON 

87712 soybean and its non-transgenic soybean control parental line having a genetic background 

similar to MON 87712 soybean, but without the BBX32 gene (variety A3525) (Monsanto, 2011). 

Multiple commercial reference varieties were also included in the study to provide a range of 

comparative values representative of existing commercial soybean varieties for phenotypic, 

agronomic, and environmental interaction measurements. Tests included a combination of field, 

greenhouse, and laboratory studies and encompassed seven general data categories: (1) seed 

germination, dormancy, and emergence; (2) vegetative growth; (3) reproductive development 

(including pollen characteristics); (4) seed retention on the plant and lodging; (5) plant response 

to abiotic stress and interactions with diseases and arthropods; (6) plant-symbiont interactions; 

and, (7) volunteer potential and persistence outside of cultivation characteristics (Monsanto, 

2011; USDA-APHIS, 2011b). 

MON 87712 soybean has been genetically modified to extend its diurnal activity that allows it to 

increase nutrient assimilation and production of plant compounds, such as starches, as well as 

increased days to senescence (terminal events in development) that result in increased yield. 

Increased yields are the result of these changes during the reproductive growth stages (R1 

through R7) that lead to an increased number of seeds and seed weight. The results of the 

combined trials, however, demonstrated that overall there were no substantial agronomic or 

phenotypic differences between MON 87712 soybean and its comparator control or other 

commercial soybean varieties. No statistically significant differences were detected (α = 0.05) 

between MON 87712 soybean and the conventional control A3525 except for early stand count, 

days to 50% senescence, days to physiological maturity, final stand count, and yield (52.6 vs. 

49.0 bushels per acre) (Monsanto, 2011). Although significantly different from the conventional 

control A3525, the mean values of MON 87712 soybean for early stand count and final stand 

count were within the range of commercial reference varieties for each characteristic. 

Differences in days to 50% senescence, days to physiological maturity, and yield were consistent 

with the mode of action of the introduced trait in MON 87712 soybean (Monsanto, 2011; USDAAPHIS, 2011b). 

The increased yield of MON 87712 is within the range of variability of other conventionally 

high-yield varieties, is subject to the same variables that influence yield as other varieties, and 

would continue to have similar variability from year to year, as described in Section 2.2.2, 

Agronomic Practices. The increased stand count found during test trials was not a factor in the 

increased yield (Monsanto, 2011). Although MON 87712 soybean has extended diurnal activity 

84
compared to other soybean varieties, Monsanto has indicated it will be adopted into existing 

maturation groups to match the area in which it would be cultivated. No meaningful phenotypic, 

agronomic, or environmental interaction differences between MON 87712 soybean and other 

commercial varieties were found in test results (Monsanto, 2011), therefore, no change to area of 

U.S. soybean production is expected from approval of its nonregulated status.

Because MON 87712 soybean is anticipated to increase yields, it might be expected to be bred 

into many varieties of soybean currently grown. Since the mid-20th century, changes in soybean 

cultivars have contributed to increased yields, as have improved management practices (Specht 

et al., 2006; Egli, 2008; Pedersen, 2008). From 1991 to 2011, average soybean yield increased 

approximately 17.6% from 34.2 bushels per acre in 1991 to 41.5 bushels per acre in 2011, and 

slightly declined nationally in 2012 to 39.3 bushels per acre compared to 2011 average yields 

(USDA-NASS, 2012j). Since 1991, U.S. soybean production acreage has increased 31%, partly 

due to new cultivars facilitating expansion into northern and western states, but largely due to 

soybean replacing other crops, and more double-cropping of soybean (USDA-ERS, 2011f). 

Since 1949, however, total U.S. cropland has not changed very much, ranging from 478 million 

acres at the beginning of the period down to 408 million acres in 2007, the lowest of the period 

(USDA-ERS, 2011e). As explained in Section 2.1.1, Acreage and Area of Soybean Production, 

the steep decline in soybean acreage in 2007 is partially attributed to a change in land use 

classification by USDA in the 2007 Agricultural Census (USDA-ERS, 2011e). Based on this 

data, historically, the majority of the gains in soybean acreage have been at the expense of other 

crops on existing cropland and increased production from double-cropping, not converting land 

to new soybean production. As described in the No Action Alternative, the USDA has projected 

that soybean acreage will remain relatively steady at approximately 76 million acres until 

2021/2022, while soybean yield is estimated to increase 11% during the period (USDA-OCE, 

2012). Although the yield potential of MON 87712 soybean is higher than its comparator, it is 

well within the range of variation of other commercially available conventional cultivars such as 

non-GMO high yield varieties developed by Albert Lea Seeds, D.F. Seeds, eMerge Genetics and 

several State University Extension Services, as well as high yield cultivars that have been 

conventionally crossed with herbicide- resistant GE varieties by companies such as Monsanto, 

Bayer, and Pioneer (see Subsection 2.1.2.5, Soybean Yield). Based upon its phenotypic and 

agronomic similarity to other soybean cultivars, MON 87712 soybean is also subject to the same 

variables affecting yield in other soybean varieties, such as management practices and weather 

(see Section 2.1.2.4, Agronomic Inputs). If the developer generally incorporates the MON 

87112 trait into much of its seed offerings, and the trait responds uniformly to the grower’s agroenvironment, there may be yield increases in both individual farms and a potential for increase in 

overall soybean production. If a trend of such increased production becomes evident, and 

soybean demand does not increase, then there may be the possibility that acreage planted to 

soybean actually declines. If these assumptions are realized, then under the Preferred Alternative 

there could be changes that may not occur under the No Action Alternative.

4.2.2 Agronomic Practices

As discussed in Subsection 2.1.2, soybean cultivation requires significant management attention 

to tillage, rotation strategy, agricultural inputs, and pesticide inputs. Decisions concerning 

soybean agronomic practice are dependent on grower want and need, and ultimately reflective of 

external factors including geography, weed and disease pressure, economics of management of 

85
yield, and production system (rotation) flexibility (Heiniger, 2000; Farnham, 2001; University of 

Arkansas, 2006). Increasing yield depends on the optimization of all manageable variables and 

sound agronomic decisions.

No Action Alternative

Under the No Action Alternative, MON 87712 soybean would continue to be subject to the 

regulatory requirements of 7 CFR part 340 and plant pest provisions of the Plant Protection Act. 

Growers will continue to have access to existing nonregulated GE soybean varieties, as well as 

conventional soybean varieties. Current soybean management practices and methods that 

increase yield would be expected to continue under the No Action Alternative. These include 

conventional and conservation tillage, soil and foliar fertilization, crop rotation, irrigation, pest 

(insects and weeds) and disease management with herbicides, pesticides, and fungicides, and 

crop residue management. Methods to increase soybean yield include selecting the right variety, 

taking steps early to manage cyst nematodes, optimizing planting time, choosing optimal row 

spacing, managing weeds carefully, scouting for pests, and ensuring appropriate soil fertility 

(Pedersen, 2008). 

Approximately one third of planted soybean seed in the U.S. is inoculated with B. japonicum to 

increase yield (Seed Today, 2009). In the 1990s, row spacing for planting soybean narrowed to 

7 inches to achieve greater yields and then more recently expanded to 15 inches to promote 

greater air circulation to combat increased disease impacting yields (USDA-ERS, 2010b). The 

majority of U.S. soybean acreage is rotated to corn except in the south, where soybean is more 

often rotated to soybean (see Subsection 2.1.2.2, Crop Rotation). With the recent high corn 

prices, many producers in the Midwest are turning to a corn-corn-soybean rotation (Hart, 2006). 

Recent higher international demand for soybean (primarily China) and domestic need for 

soybean oil for producing biodiesel may spur planting of more soybean. Demand may also have

prompted more soybean to soybean rotations, and double-cropping of soybean (USDA-ERS, 

2011f). Other major crops following soybean are wheat (approximately 11.2% of soybean 

acreage), with cotton, rice, and sorghum the next largest rotational crops (combined 4.6% of 

soybean acreage) (Monsanto, 2010a). Approximately 88% of U.S. soybean acreage is under 

conservation tillage management where tillage is minimized and greater crop residue is 

maintained (USDA-ERS, 2006b). In regions of the United States that experience low amounts of 

rainfall during the growing season or during drought, soybean yields benefit from proper 

irrigation; in 2006 and 2008, approximately 9% of U.S. soybean acreage was irrigated, primarily 

in the Missouri and Lower Mississippi watersheds (USDA-NASS, 2010; USDA-ERS, 2011b; 

USDA-NASS, 2011). 

A wide variety of pests can hinder soybean production and many require agricultural pesticidal 

inputs for their control. As discussed in Subsection 2.1.2.4, Agricultural Inputs, pesticides were 

applied to 16% of the 72.9 million soybean acres planted in certain surveyed states in 2006. Of 

the 12 reported insecticides, the three most common, lambda-cyhalothrin, chlorpyrifos, and 

esfenvalerate, were applied to 6%, 5%, and 3% of the planted acres, respectively (USDA-NASS, 

2007a). However, a major pest is the soybean cyst nematode which cannot be controlled by 

pesticides, but transgenic soybean cultivars have been engineered to resist this pest. Other 

methods to control insect pests include tillage and crop rotation. While augmenting beneficial 

insect populations that prey on targeted pests would be useful, effectiveness of this strategy has 

not been demonstrated; thoughtful use of insecticides to conserve beneficials is nevertheless an 

86
important strategy. Diseases that afflict soybean include fungal, bacterial, and viral (Jardine, 

1997). Diseases of major concern in soybean are Cercospora foliar blight, purple seed stain, 

aerial blight, soybean rust, pod and stem blight, and anthracnose (Padgett et al., 2011). When 

disease does occur in soybean, despite implementing best management practices, chemical 

treatment options are fairly limited to those of fungal origin (Jardine, 1997; Padgett et al., 2011). 

USDA NASS (2007a) found that the most commonly applied fungicides on soybean 

(azoxystrobin, propiconazole, pyraclostrobin, tebuconazole, and trifloxystrobin) were applied to 

only 4% of the 2006 U.S. soybean planted acreage in the 19 states surveyed (see Subsection 

2.1.2.4, Agronomic Inputs). 

Weeds are a major pest in agriculture and a primary detriment to soybean productivity 

(Heatherly et al., 2009). Herbicides have been the primary tactic to manage weed communities 

in soybeans since the mid-1960s and are applied to the majority of soybean acres (USDA-NASS, 

2007b). Herbicides may be applied to soybean pre-plant (termed “burndown” in no-till), preemergence, post-emergence and post-harvest. With the advent of glyphosate-resistant GE 

soybeans, glyphosate has become the most often-used herbicide on U.S. soybean, while the use 

of other herbicides has decreased (Young, 2006; NRC, 2010). 

In soybean seed production, most of the nutrients taken up from the soil by the plant is removed 

when harvesting the seed (Snyder, 2000). As described in Section 2.1.2.4, Agricultural Inputs, 

application of key nutrients such as potassium and phosphorous is not uncommon in U.S. 

soybean production; nitrogen is also applied, but at a much lower rate than other crops (USDANASS, 2007a). These supplements were applied on average only about once per crop year. In 

the midwestern United States it has been most economical to apply nitrogen, phosphate 

(phosphorous), and potash (potassium) soil fertilizer prior to planting corn in a two-year rotation 

with soybean, as usually the soybean crop can be produced the following year without additional 

soil fertilizer (Bender et al., 2013). However, in the south where soybean to soybean rotation is 

more common, soil nitrogen fertilizer is applied annually (Heatherly, 2012). Soil fertilizer is 

often tilled into the soil, or broadcast on the surface, or injected below the surface, with the latter

practices used more often in conservation tillage production of soybean. However, because 

nutrients frequently become stratified in conservation tillage production systems, more farmers 

are turning to strip tillage to incorporate supplemental nutrients (Fernandez and White, 2012). 

Recent research has found the fertility of some U.S. and Canadian cropland is declining in the 

last five years, with soils dropping to levels near or below critical phosphorous, potassium, sulfur 

and zinc levels. The decline is attributed to producing increased yields of field crops without 

proper fertilization (Fixen et al., 2010). As discussed in Subsection 2.1.2.4, Agronomic Inputs, it 

is widely recognized that the higher the crop yield per acre, the more nutrients are removed from 

the soil (Snyder, 2000; Specht et al., 2006; Pedersen, 2008; CAST, 2009a; Mallarino et al., 2011; 

Silva, 2011), and many agricultural extensions recommend regularly testing the soil for nutrients 

and soybean fertilization levels based upon bushels per acre produced to support increased yields 

(CAST, 2009a) (for example, see recommendations for Iowa at 

http://www.extension.iastate.edu/Publications/PM1688.pdf and http://msucares.com/pubs

/publications/p2647.pdf for Mississippi) (Pedersen, 2008; Naeve, 2012). Yields in soybean 

cultivars not bred to be high yielding may be improved by increasing the plant population of a 

field through increased seeding rates and narrower rows, and the application of fertilizer in 

undernourished soils, among other measures (Pedersen, 2008).

87
Bender et al. (2013) have recently evaluated the nutrient uptake of modern, higher yielding 

transgenic insect-resistant corn varieties in Iowa and found average applications of phosphorous 

to these modern varieties would deplete this nutrient to inadequate levels for following soybean 

crops if not supplemented. As discussed in Subsection 2.1.2.4, Agronomic Inputs, soybean 

yields have steadily increased since first reported in 1924, and have increased 17.6% from 1991 

to 2012 (USDA-NASS, 2012j), attributed to improved cultivars and agronomic practices, 

including those addressing adequate application of fertilizer (Specht et al., 2006; Pedersen, 2008; 

Naeve, 2012). 

Preferred Alternative

A determination of nonregulated status of MON 87712 soybean is not expected to result in 

changes to current soybean cropping practices as described under the No Action Alternative. As 

discussed in Subsection 4.2.1, Acreage and Area of Production, Monsanto’s studies demonstrate 

MON 87712 soybean is essentially the same as other commercial soybean varieties in terms of 

agronomic characteristics and cultivation practices (Monsanto, 2011; USDA-APHIS, 2011b). 

While MON 87712 soybean did have an approximately 1.6% higher earlier plant stand count, 

reached senescence 2 days later and physiological maturity 2.5 days later, had an approximately 

3.3% higher final plant stand, and a 7.3% higher yield than variety A3525, none of these 

characteristics are expected to require changes to agronomic practices such as tillage, crop 

residue management, crop rotation, irrigation, pest (insects and weeds) and disease management, 

harvest and storage practices for cultivation of MON 87712 soybean (Monsanto, 2011; USDAAPHIS, 2011b). Monsanto has also indicated MON 87712 soybean will be adopted into existing 

maturation groups to match the area in which it would be cultivated, thus soybean planting 

practices would not change. As noted earlier however, successive crops following the MON 

87112 may possibly require additional fertilization, but that would depend upon the soil and its 

typical constituents, as well as the depletion rate of nutrients.

As discussed under the No Action Alternative, producing higher grain crop yields often requires 

additional fertilization to be applied to replace the nutrients removed from the soil by harvesting 

the grain. The grain takes up the majority of nutrients, whether or not the cultivar grown is bred 

to be high yielding. In two-year rotations of corn and soybean, a common practice is to fertilize 

the previous year’s corn crop with enough phosphorus and potassium to allow for the subsequent 

soybean crop to be grown with no supplemental fertilizer as it is more economical than two 

separate applications (Franzen, 1999; Berglund and Helms, 2003; Ebelhar et al., 2004). 

Approximately 68.6% of U.S. soybean is grown in rotation with corn (Monsanto, 2010a). 

However, as discussed under the No Action Alternative, annual supplementation of nutrients is 

common in soybean to soybean rotations in the southern United States. Like any other higher 

yielding soybean variety or production strategy designed to maximize yields utilizing lower 

yielding conventional or GE varieties, MON 87712 soybean would deplete more potassium and 

phosphorus from the soil (Monsanto, 2011). Levels of these nutrients may need to be checked 

and corrected if needed prior to MON 87712 soybean planting. Regular testing of soil fertility 

levels and supplementation if needed is already widely recommended in soybean production for 

achieving optimal yields. Application of additional nutrients to support production of this 

soybean would not be different from current practices where up to 23% of soybean acreage has 

been annually supplemented with phosphate (phosphorous) and 25% has been annually 

supplemented with potash (potassium) (USDA-NASS, 2007a). As soybean yields have been 

88
steadily increasing since the 1920s (Egli, 2008), and variations of yields are experienced field-tofield and year-to-year in GE and non-GE soybean production (USDA-NASS, 2012j; USDANASS, 2012f), growers are accustomed to harvesting and storing possibly increased yields.

Based upon the above, changes in U.S. agronomic practices such as tillage, crop rotation, 

irrigation, pest management, soybean cultivation, geographic range, seasonality or insect 

susceptibility, are not expected to occur under the Preferred Alternative, although growers may 

need to increase the frequency of soil nutrient augmentation, dependent upon specific needs of 

specific fields. 

4.2.3 Soybean Seed Production

As discussed in Subsection 2.1.3, soybean seed production is conducted under standard 

procedures specified by AOSCA to prevent gene flow between varieties (AOSCA, No Date). 

Several best management practices to preserve varietal identity include:

• Maintaining isolation intervals to prevent pollen movement from other soybean sources;

• Planting border rows to capture any pollen present or employing natural pollen barriers; 

and

• Field monitoring for off types, other crops, etc.

Soybean is considered to be highly self-pollinated; therefore, cross-pollination to adjacent 

soybean plants occurs at a very low frequency (Caviness, 1966; OECD, 2000; Ray et al., 2003;

Abud et al., 2007). Other research has also demonstrated that soybean pollen dispersal is 

restricted to small areas and wind mediated pollination is negligible (Yoshimura, 2011).

No Action Alternative

Under the No Action Alternative, current soybean seed production practices are not expected to 

change. Several factors influence optimal planting rate for soybean such as row spacing, seed 

germination rate, soil conditions, climate, disease and pest pressure, past tillage practices and 

crop rotation (Robinson and Conley, 2007). Seeding rate is also determined by the plant 

population desired by the grower. Growers may plant certified soybean seed, uncertified seed, 

and “binrun” soybean seed that is grown and stored on individual farms (Oplinger and 

Amberson, 1986). Approximately 93% of the soybean acres planted in the United States in 2012 

were GE varieties (USDA-ERS, 2012e), about 71.8 million acres were planted with certified 

seeds, and an estimated 1.3 to 2.7 million tons of certified soybean planting seeds were required 

in 2012. 

As discussed in Subsection 2.1.3, Soybean Seed Production, the production of soybean for 

foundation, registered, certified, or quality control seed require biological, technical, and quality 

control factors required to maintain varietal purity above that required for soybean production for 

grain. The production and certification of soybean seed is regulated by state or regional crop 

improvement agencies and are chartered under the laws of the state(s) they serve (e.g., see 

Mississippi Crop Improvement Association, 2008; Illinois Crop Improvement Association, 2013; 

SSCA, No Date-a; Virginia Crop Improvement Association, No Date). The procedures followed 

by certified seed producers to ensure varietal purity and identity during the cultivation, harvest, 

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storage, and transportation of soybean seed are not expected to change under the No Action 

Alternative.

Seed genetic purity is maintained to maximize the value of a new variety or cultivar (Sundstrom

et al., 2002), of which a seed certification process ensures the desired traits remain within purity 

standards (Bradford, 2006) (see Subsection 2.1.3, Soybean Seed Production). Seed producers 

routinely submit applications to the AOSCA National Variety Review Boards for review and 

recommendation for inclusion into seed certification programs. For example, in September 2012, 

AOSCA recommended the inclusion of 60 varieties of soybean expressing high yield traits by 

three seed producing companies for certification (AOSCA, 2012a; AOSCA, 2012b). It is 

expected that soybean seed producers would continue to implement measures to preserve the 

identity of their seed varieties.

Preferred Alternative

Field trials conducted by Monsanto have not demonstrated any agronomic or phenotypic 

differences between MON 87712 soybean and conventional soybean varieties that would require 

changes to soybean seed production practices (Monsanto, 2011). Based on the data provided, 

APHIS has concluded that the availability of MON 87712 soybean under the Preferred 

Alternative would not alter the agronomic practices, cultivation locations, seed production 

practices or quality characteristics of conventional and non-GE soybean seed production 

(USDA-APHIS, 2011b). Monsanto has also indicated MON 87712 soybean will be adopted into 

existing maturation groups to match the area in which it would be cultivated, thus its adoption 

would not alter planting practices of soybean grown for seed. Various state agencies affiliated 

with AOSCA will continue to provide seed certification services. Monsanto has indicated that 

tests would be available and easily accomplished to determine the presence of the BBX32 gene in 

seed stock. The potential impacts to soybean seed production associated with the Preferred 

Alternative would not be any different than practices under the No Action Alternative.

4.2.4 Organic Soybean Production

Organic production plans prepared pursuant to the NOP include practical methods to prevent the 

unintended presence of GE materials. Typically, organic growers use multiple methods to 

prevent unwanted material from entering their fields, many of them following the same system 

used for the cultivation of certified seed under the AOSCA procedures. These include planting 

organic seed only, planting at times earlier or later than neighbors, and using field isolation 

practices (NCAT, 2003).

APHIS recognizes that producers of non-GE soybean, particularly producers who sell their 

products to markets sensitive to GE traits (e.g., organic or some export markets), can be 

reasonably assumed to use practices on their farms that protect their crop from unwanted 

substances. APHIS’s baseline for analysis of the alternatives will therefore assume that growers 

of organic soybean are already using, or have the ability to use, these common practices.

No Action Alternative

Under the No Action Alternative, MON 87712 soybean would remain subject to the regulatory 

requirements of 7 CFR part 340 and the plant pest provisions of the Plant Protection Act. 

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Availability of GE, non-GE and organic soybean seed would not change as a result of the 

continued regulation of MON 87712 soybean. Organic soybean farmers would continue to use 

the same methods as applied in certified seed production systems designed to maintain soybean 

seed identity and meet National Organic Standards as established by the NOP. Acreage devoted 

to organic soybean production is small relative to that of GE varieties and has remained 

relatively steady, only fluctuating between 96,080 to 126,000 acres between 2005 and 2011

(USDA-ERS, 2010a; USDA-NASS, 2012a). As described in Subsection 2.1.4, Organic Soybean 

Production, organic soybean production is a very small portion of the soybean market which 

would not be expected to change under the No Action Alternative. Also, agronomic practices 

employed to produce organic soybean would remain unaffected by selection of the No Action 

Alternative.

It is important to note that the current NOP regulations do not specify an acceptable threshold 

level for the adventitious presence of GE materials in an organic-labeled product. The 

unintentional presence of the products of excluded methods will not affect the status of an 

organic product or operation when the operation has not used excluded methods and has taken 

reasonable steps to avoid contact with the products of excluded methods. These methods to 

exclude nonorganic methods and avoid certain substances are detailed in the grower’s approved 

organic system plan (Ronald and Fouche, 2006; USDA-AMS, 2008). However, certain markets 

or contracts may have defined thresholds for content of GE soybean (Non-GMO Project, 2012).

Preferred Alternative

GE soybean lines are already extensively used by farmers, while organic soybean production 

represents a small percentage (less than 1.0%) of the total U.S. soybean acreage (USDA-NASS, 

2012a) . Under the Preferred Alternative, MON 87112 is not likely to substantially increase the 

ratio of conventional soybean to organic soybean Similar to the No Action Alternative, organic 

soybean acreage is likely to remain small, regardless of whether new varieties of GE or non-GE 

soybean varieties, including MON 87712 soybean, become available for commercial soybean 

production.

When compared to other GE varieties of soybean, MON 87712 soybean should not present any 

new and different issues and impacts for organic and other specialty soybean producers and 

consumers. Organic producers employ a variety of measures to manage, identify and preserve 

the integrity of organic production systems (NCAT, 2003). Agronomic tests conducted by 

Monsanto found MON 87712 soybean substantially equivalent to the non-GE control variety 

(Monsanto, 2011); hence, pollination characteristics would be similar to other soybean varieties 

currently available to growers. Given the largely self-fertilized nature and the limited pollen 

movement of soybean (Caviness, 1966; OECD, 2000; Ray et al., 2003; Abud et al., 2007; 

Yoshimura, 2011), it is not likely that organic farmers will be substantially affected by a 

determination of nonregulated status of MON 87712 soybean when organic soybeans are 

produced in accordance with agronomic practices designed to meet National Organic Standards. 

The trend in the cultivation of GE soybean, non-GE, and organic soybean varieties, and the 

corresponding production systems to maintain varietal integrity are likely to remain the same as 

the No Action Alternative. Accordingly, impacts of a determination of nonregulated status of 

MON 87712 soybean on organic soybean production would be similar to the No Action 

Alternative.

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4.3 Physical Environment

4.3.1 Soil Quality

No Action Alternative

Under the No Action Alternative, current soybean management practices that benefit soil quality 

would be expected to continue. These agronomic practices include contouring; use of cover 

crops to limit the time soil is exposed to wind and rain, reduce erosion and compaction, control 

weeds, and enhance nutrients; careful management of fertilizers and pesticides; crop rotation; 

and windbreaks (Hoorman et al., 2009b; USDA-NRCS, 2011b; MDA, 2012; NWF, 2012; SARE, 

2012; USDA-NASS, 2012e; Corn and Soybean Digest, 2013; Lee et al., No Date) (see 

Subsection 2.1.2, Agronomic Practices). Tillage has beneficial impacts to soil quality by 

incorporating organic material and oxygen, but also exposes soil to increased erosion from 

precipitation and wind, and if done improperly, compacts soil, reduces nutrients, impacts soil 

structure, and reduces biological activity(USDA-NRCS, 2001). Agronomic practices affecting 

soil would not change as a result of the continued regulated status of MON 87712 soybean. 

Growers would continue to choose certain pesticides based on weed, insect and disease 

pressures, cost of seed and other inputs, technology fees, human safety, potential for crop injury, 

and ease and flexibility of the production system (Heiniger, 2000; Farnham, 2001; University of 

Arkansas, 2006). The environmental risks of pesticide use are assessed by EPA in the pesticide 

registration process and are regularly reevaluated by EPA for each pesticide to maintain its 

registered status under FIFRA. When used according to label directions, pesticides can be used 

without posing unreasonable risks to soil quality. 

Recent research has found the fertility of some U.S. and Canadian cropland is declining in the 

last five years, with soils dropping to levels near or below critical phosphorous, potassium, sulfur 

and zinc levels; these observations are attributed to producing increased yields of field crops 

without proper fertilization (Fixen et al., 2010). Increased soybean yields may be obtained by 

increasing the plant population in a field (i.e., more seed in narrower rows) among other 

management practices, as well as selecting varieties bred to be higher yielding (Pedersen, 2008). 

Application of key nutrients to soil to replace those taken up by crops is not uncommon in 

soybean production, fertilization is widely recommended as a means to increase yields of all 

soybean cultivars, and regular testing of soil fertility is widely recommended (see discussion in 

Subsection 4.2.2.1, No Action Alternative – Agronomic Practices). 

Preferred Alternative

A determination of nonregulated status of MON 87712 soybean is not expected to result in 

changes in current soybean cropping practices that may impact soil quality. Monsanto studies 

demonstrate MON 87712 soybean is essentially indistinguishable from other GE and non-GE 

soybean varieties in terms of agronomic characteristics and cultivation practices (Monsanto, 

2011; USDA-APHIS, 2011b). As MON 87712 soybean is essentially equivalent to conventional 

soybeans, no changes in agronomic practices (other than crop fertilization), cultivation, 

geographic range, seasonality or insect susceptibility, are expected to occur. Although MON 

87712 soybean is a higher yielding cultivar and like other commercially available high yielding 

cultivars or production systems designed to achieve improved yields from lower-yielding 

conventional and GE cultivars, it would remove phosphorous and potassium from soil at a higher 

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rate. The application of these nutrients is not uncommon in soybean production (USDA-NASS, 

2007a) and regular testing of soil fertility is widely recommended in soybean production.

MON 87712 soybean and the associated production of the BBX32 protein is not expected to 

cause an impact to the physicochemical characteristics of the soil. The BBX32 gene, which has 

been introduced into MON 87712 soybean, is derived from A. thaliana (mouseear cress) 

(Monsanto, 2011), a common introduced forb found in all of the soybean producing states except 

North Dakota (USDA-NRCS, 2013c). The BBX32 protein allows for greater plant nutrient 

assimilation and utilization to drive yield improvement. Soil quality may be impacted by a 

soybean crop through direct interaction with soil fauna via the root system and by the 

degradation of remaining plant tissue after harvest. Compositional analysis of MON 87712

soybean forage tissue (i.e., stems and leaves) revealed no significant or consistent differences 

between it and the conventional control variety A3525 (Monsanto, 2011). In addition, there were 

no significant differences between MON 87712 soybean and the A3525 conventional control 

variety in plant-environment interactions or plant symbiont interactions (Monsanto, 2011; 

USDA-APHIS, 2011b). Recognizing the compositional similarities between MON 87712

soybean and conventional soybean, and also the examined safety of the MON 87712 gene 

products, it is not anticipated that MON 87712 soybean interaction with soil fauna or degradation 

of its tissue following harvest would significantly impact soil quality compared to conventional 

soybean.

Based on this information, overall impacts to soil under the Preferred Alternative are expected to 

be similar to the No Action Alternative.

4.3.2 Water Resources

No Action Alternative

Under the No Action Alternative, current soybean management practices, including irrigation, 

pesticide use and fertilizer application would be expected to continue. The environmental risks 

of pesticide use are assessed by EPA in the pesticide registration process and are regularly 

reevaluated by EPA for each pesticide to maintain its registered status under FIFRA. Pesticide 

use according to EPA-approved label directions would not pose unreasonable risks to water 

resources.

The trend towards conservation tillage or no-tillage practices with the adoption of GE herbicidetolerant soybean varieties is expected to continue, resulting in reduced surface water run-off and 

soil erosion (Dill et al., 2008; Givens et al., 2009). Conservation tillage and other management 

practices are used to trap and control sediment and nutrient runoff. Water quality conservation 

practices benefit agricultural producers by lowering input costs and enhancing the productivity of 

working lands (USDA-NRCS, 2012). 

As of 2006, nitrogen was applied to 18%, potassium to 25%, and phosphorous to 23% of 

soybean acreage in 19 surveyed states (USDA-NASS, 2007a). High yield production practices 

for any soybean cultivar and cultivars bred for high yield remove more nutrients from soils 

(Pedersen, 2008). Regular testing of soil fertility is required and application of nutrients is not 

uncommon in soybean production (USDA-NASS, 2007a). As discussed in Subsection 2.1.2.1, 

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Cultivation, nitrogen is not usually applied to soybean since soybean fixes nitrogen in the soil in 

symbiosis with rhizobial bacteria (CAST, 2009a).

Preferred Alternative

No differences in morphological characteristics and agronomic requirements were found 

between MON 87712 soybean and its parent A3525 soybean (Monsanto, 2011); therefore, 

cultivation of MON 87712 soybean would not necessitate changes in current agronomic practices 

for soybean production that may impact water quality. Monsanto evaluated on a site specific 

basis abiotic stressors such as drought and flood, and found no difference between MON 87712

and its comparator (Monsanto, 2011). Also, as previously discussed, the use of MON 87712

soybean would not increase the total acres and range of U.S. soybean production areas. For these 

reasons, a determination of nonregulated status of MON 87712 soybean is unlikely to change the 

current irrigation practices in commercial soybean production. 

As discussed in Subsection 2.2.2, Water Resources, runoff from cropland areas receiving manure 

or fertilizer contributes to increase phosphorous and nitrogen delivery to streams and lakes, and 

in fresh water systems phosphorus is a limiting factor for eutrophication. However, regular 

testing of soil fertility levels and supplementation if needed is already a common

recommendation in soybean production for achieving optimal yields; additionally, as of 2006, up 

to 23% of soybean acreage has been annually supplemented with phosphorous (USDA-NASS, 

2007a).

The adoption of herbicide-tolerant crops is associated with increased use of no-till and reduced 

till practices that benefit water quality through reductions in soil, nutrient and herbicide loaded 

runoff (Dill et al., 2008; Givens et al., 2009). The adoption rate of herbicide-tolerant soybean has 

steadily increased since its introduction in 1996, comprising up to 93% of the cultivated soybean 

in the United States in 2012 (see Subsection 2.1.1, Area and Acreage). This trend is not likely to 

change with the commercial availability of MON-87712 soybean. Some farmers practice no-till 

or reduced till even though they plant soybean varieties with no herbicide tolerance. Also, no-till 

soybean production is not suitable for all producers or areas. For example, no-till soybean 

production is less successful in heavier, cooler soils more typical of northern latitudes (Kok et 

al., 1997; NRC, 2010) where the potential for increased weeds, insect pests, and disease requires 

careful management (Peterson, 1997; Pedersen et al., 2001) . 

Because MON 87712 soybean is expected to simply replace soybean varieties already in use and 

no changes to agronomic practices are required for its cultivation, the effects of the Preferred 

Alternative on water use and water quality would be the same as the No Action Alternative.

4.3.3 Air Quality

No Action Alternative

Under the No Action Alternative, air quality would continue to be affected by current agronomic 

practices associated with soybean production, such as tillage, cultivation, pesticide and fertilizer 

applications, and the use of agricultural equipment. Growers would continue use of 

agrochemicals such as pesticides and herbicides which are EPA-registered products. 

Environmental risks of their application are assessed by EPA in the pesticide registration 

process. Further, each pesticide is regularly reevaluated by EPA to maintain registered status 

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under FIFRA. In this process, steps to reduce pesticide drift are included on a pesticide’s label 

and approved by the EPA. Use of pesticides according to the EPA-approved label would not 

pose unreasonable risk to air quality. The trend towards conservation tillage or no-till practices 

with the adoption of GE herbicide-tolerant soybean varieties would likely continue, which could 

result in reduced emissions from agricultural equipment and fugitive dust from soil disturbance 

(Dill et al., 2008; Givens et al., 2009).

Preferred Alternative

No differences in morphological characteristics and agronomic requirements were found 

between MON 87712 soybean and its comparator parent A3525 soybean (Monsanto, 2011); 

therefore, cultivation of MON 87712 soybean would not necessitate changes in current 

agronomic practices for soybean production. Also, as discussed in Subsection 4.2.1, Acreage 

and Area of Soybean Production, the use of MON 87712 soybean would neither increase the 

total acres nor range of U.S. soybean production areas. Moreover, since no changes to agronomic 

practices for the cultivation of MON 87712 soybean are expected, the trend towards conservation 

tillage or no-till practices would likely be similar to the No Action Alternative. However, in 

those areas in which soil fertility does not normally require frequent nutrient augmentation, there 

may be additional tractor trips to apply fertilizer to the soil. Thus, potential exists for increased 

amounts of exhaust gases, should the need arise for additional fertilization of soybean fields, but 

this depends on existing soil resources, and would not be needed in all locations. Routine soil 

testing would reveal any deficiencies that required soil interventions. It should be noted that 

fertilization is often done for the previous crop to soybean, such as corn, and that additional 

tractor trips for soybean rotation would not likely be common.

Between 1990 and 2010, residue burning occurred on less than 0.5% of soybean acreage (USEPA, 2012a). As discussed in Subsection 2.2.3, Air Quality, prescribed burning would likely 

only occur as a pre-planting option based on individual farm needs and not the variety produced. 

For these reasons, a determination of nonregulated status of MON 87712 soybean is unlikely to 

change the effect of commercial soybean production on air quality and the impacts to air quality 

from a determination of nonregulated status of MON 87712 soybean are expected to be similar 

to the No Action Alternative. 

4.3.4 Climate Change

No Action Alternative

Under the No Action Alternative, agronomic practices associated with soybean production 

contributing to GHG emissions, including tillage, cultivation, irrigation, fertilizer applications, 

and use of agriculture equipment, are expected to continue. Tillage contributes to the release of 

GHG as a result of the loss of soil CO2 to the atmosphere from the oxidation of soil organic 

carbon. Conservation tillage practices contribute to soil carbon sequestration through the 

reduction of soil aeration and microbial activity; loss of soil carbon from conventional tillage is 

estimated to be five times greater than no-till systems (CAST, 2009b) (see Subsection 2.2.4, 

Climate Change). Conservation tillage also reduces the number of trips across a field which 

translates into a reduction of fuel usage and GHG emissions from farm equipment. Reduced 

tillage also contributes to reducing the loss of nutrients from runoff and subsequent reductions in

the need for fertilizer (Oregon State University, 2012). 

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Cropping practices and soil management also account for 69% of U.S. NO2 emissions, with 

application of nitrogen fertilizer in particular contributing to NO2 emissions (US-EPA, 2011b). 

As of 2006, nitrogen was applied to 18%, potassium to 25%, and phosphorous to 23% of 

soybean acreage in 19 surveyed states (USDA-NASS, 2007a). High yield production practices 

for any soybean cultivar and cultivars bred for high yield remove more nutrients from soils 

(Pedersen, 2008). Regular testing of soil fertility is required and application of nutrients is not 

uncommon in soybean production (USDA-NASS, 2007a). As discussed in Subsection 2.1.2.1, 

Cultivation, soybean fixes nitrogen in the soil in symbiosis with rhizobial bacteria, hence, 

nitrogen is not usually applied to soybean (CAST, 2009a).

The trend towards conservation tillage or no-tillage practices with the adoption of GE herbicideresistant soybean varieties would continue, which could result in reduced GHG emissions from 

agricultural equipment (Dill et al., 2008; Givens et al., 2009). 

Preferred Alternative

A determination of nonregulated status of MON 87712 soybean is not expected to result in 

changes in the current soybean cropping practices that potentially impact GHG emissions 

contributing to climate change. Apart from increased yield, no differences in morphological 

characteristics and agronomic requirements were found between MON 87712 soybean and its 

A3525 parent cultivar (Monsanto, 2011). Similar to other high yield soybean cultivars and 

soybeans produced using high yield maximization practices, MON 87712 soybean would require 

more potassium and phosphorous than other lower yield cultivars. Application of these 

fertilizers is not uncommon, and they do not emit GHG. 

As MON 87712 soybean is essentially equivalent to other GE herbicide-resistant and non-GE 

soybeans, no changes in agronomic practices (such as crop rotation), cultivation, geographic 

range, seasonality or insect susceptibility, are expected to occur; therefore, cultivation of MON 

87712 soybean would not necessitate changes in current agronomic practices for soybean 

production that may impact GHG emissions. In addition, cultivation of MON 87712 soybean 

would not likely impact the decision by producers to minimize conventional tillage and adopt 

conservation tillage practices that reduce CO2 and NO2 emissions. For these reasons, a 

determination of nonregulated status of MON 87712 soybean is unlikely to change the effect of 

commercial soybean production on GHG emissions impacting climate change.

4.4 Biological Resources

4.4.1 Animal Communities

No Action Alternative

Under the No Action Alternative, terrestrial (insect, bird, and mammal) and aquatic (fish, benthic 

invertebrate, and herptile) species would continue to be affected by current agronomic practices 

associated with soybean production, such as tillage, cultivation, pesticide and fertilizer 

applications, and the use of agricultural equipment (USDA-NRCS, 1999a; Brady, 2007; Sharpe, 

2010; Palmer et al., No Date). Some of these practices may have potential to impact animal 

communities. For example, if tillage rates were to increase as a means of weed suppression, it 

could possibly diminish the benefits to wildlife provided by conservation tillage practices. 

Growers would continue to choose certain pesticides based on weed, insect and disease 

96
pressures, cost of seed and other inputs, technology fees, human safety, potential for crop injury, 

and ease and flexibility of the production system (Heiniger, 2000; Farnham, 2001; University of 

Arkansas, 2008). The environmental risks of pesticide use on wildlife and wildlife habitat are 

assessed by EPA in the pesticide registration process and are regularly reevaluated by EPA for 

each pesticide to maintain its registered status under FIFRA. EPA’s process ensures that each 

registered pesticide, when used according to label directions, can be used with a reasonable 

certainty of no harm to human health and without posing unreasonable risks to the environment.

Preferred Alternative

A determination of nonregulated status of MON 87712 soybean is not expected to result in 

changes to current soybean cropping practices. Monsanto’s studies demonstrate MON 87712

soybean is essentially indistinguishable from other soybean varieties in terms of agronomic 

characteristics and cultivation practices (Monsanto, 2011; USDA-APHIS, 2011b). MON 87712

soybean improves the potential for increased yield, and would be another option to assist 

growers to optimize production. Because MON 87712 soybean is essentially equivalent to other 

GE and non-GE soybeans in terms of agronomic practices (such as crop rotation or weed 

management, cultivation, geographic range, seasonality), no impacts to wildlife are expected to 

occur among that use soybean fields for cover and forage (discussed in Subsection 2.3.1, Animal 

Communities). Similarly, field trials demonstrated that MON 87712 soybean does not confer any 

biologically meaningful increased susceptibility or tolerance to insect pests (Monsanto, 2011).

Monsanto has evaluated the potential allergenicity and toxicity of the BBX32 protein. The 

developer followed Codex Alimentarius Commission guidelines to assess potential adverse 

effects to animals from environmental release or consumption of MON 87712 soybean 

(Monsanto, 2011). These evaluations determined that the BBX32 protein does not share any 

amino acid sequence similarities with known allergens, gliadins, glutenins, or protein toxins 

(Monsanto, 2011). In addition, the BBX32 protein is degraded rapidly and completely in 

simulated gastric fluid and simulated intestinal fluid, and the protein makes up only a very small 

portion (less than 0.001%) of the total plant protein (Monsanto, 2011). The results presented by 

Monsanto suggest that the BBX32 protein is unlikely to be a toxin in animal diets. Monsanto has 

initiated a food/feed safety consultation with FDA on MON 87712 soybean. FDA has evaluated 

the submission and responded with questions on July 18, 2012, and Monsanto responded to those 

on August 9, 2012. When complete, FDA will announce whether it could identify any safety or 

regulatory issues under the FD&C Act that would require further evaluation. The decision 

memo will be published as BNF No. 131.

Based on the above information, there are no expected hazards associated with the consumption 

of MON 87712 soybean and therefore it is unlikely to pose a hazard to wildlife species. Further 

discussion on the potential impacts from the consumption of MON 87712 soybean is presented 

in Subsection 4.6, Animal Feed.

4.4.2 Plant Communities

Plant communities within agroecosystems are generally less diverse than the plant communities 

that border crop fields. This lack of diversity is attributable to ecological selection that is 

imposed by crop production practices such as tillage and herbicide use (Owen, 2008). The plant 

communities that inhabit crop production fields are represented by plants (including weeds) that 

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are able to adapt and thrive in an environment that is directed specifically to the production of 

crops, such as soybean. In crop production systems, the plant community is controlled using a 

number of tactics to maximize the production of food, fiber, and fuel (Green and Owen, 2011). 

However, along with cultivation and tillage, herbicides are a common and frequently adopted 

tactic to manage plant communities within agroecosystems (Gianessi and Reigner, 2007). The 

landscape surrounding a soybean field may be bordered by other soybean (or other crop) fields 

or may also be surrounded by woodland, rangelands, or pasture and grassland areas. These plant 

communities represent natural or managed plant buffers for the control of soil and wind erosion 

and also serve as habitats for a variety of transient and non-transient wildlife species. The 

potential impacts to off-site plant communities are discussed in Subsection 4.4.5, Biodiversity.

Weed control programs are important aspects of soybean cultivation. In this context, weeds are 

those plants which, when growing in the soybean field, compete with the soybean for space, 

water, nutrients, and sunlight, and may thus include native species (US-EPA, 2007). The types of 

weeds in and around a soybean field will vary depending on the geographic region where the 

soybean is grown. Common weeds in soybean include grasses, broad-leaf weeds, and sedges 

(Cyperus spp.). Some of these have been discussed in Subsection 2.3.2, Plant Communities.

No Action Alternative

Under the No Action Alternative, MON 87712 soybean would remain under APHIS regulation. 

Soybean production would likely continue as it does today, with the majority of acres being 

planted with GE soybean. Growers would likely continue to select the agronomic practices such 

as tillage, irrigation, row spacing, timing of planting, and weed management that optimize 

soybean yield and efficiency.

Plant species that typically compete with soybean production would be managed through the use 

of mechanical, cultural, and chemical control methods. Multiple herbicides would likely continue 

to be used for weed control in soybean fields. Glyphosate, by far, is the most used herbicide in 

soybean production, followed by 2,4-D, pendimethalin, trifluralin, S-metolachlor and several 

others (USDA-NASS, 2007a). Runoff, spray drift, and volatilization of herbicides have the 

potential to impact non-target plant communities growing in proximity to fields in which 

herbicides are used. The environmental risks of pesticide use are assessed by EPA in the 

pesticide registration process and are regularly reevaluated by EPA for each pesticide to maintain 

its registered status under FIFRA. In this process, where appropriate, steps to reduce pesticide 

drift and volatilization are included on a pesticide’s label approved by EPA.

Volunteer soybeans are typically not a major problem in agroecosystems and regionally where 

volunteer soybean populations can develop, the volunteer plants are manageable and do not 

represent a serious weed threat (York et al., 2005). 

Preferred Alternative

A determination of nonregulated status of MON 87712 soybean is not expected to result in 

changes in current soybean cropping practices. Field trials and laboratory analyses conducted by 

Monsanto showed no differences between MON 87712 soybean and other GE and non-GE 

soybean in growth, reproduction, or interactions with pests and diseases (Monsanto, 2011). The 

expression of the BBX32 protein in MON 87712 soybean is not expected to cause plant disease 

98
or affect susceptibility of MON 87712 soybean or its progeny to diseases or other pests (USDAAPHIS, 2011b).

Similar to the No Action Alternative, weeds within fields of MON 87712 soybean could be 

managed using mechanical, cultural, and chemical control. There are no differences expected to 

the use of herbicides or other pesticides in the production of MON 87712 soybean when 

compared to other GE and non-GE soybean varieties (Monsanto, 2011; USDA-APHIS, 2011b). 

In addition, there were no differences in the occurrence of volunteer soybean between MON 

87712 soybean and the conventional control A3525; moreover, the herbicides that are effective 

for the control of volunteer soybean are equally effective for MON 87712 soybean (Monsanto, 

2011). 

Based on the above information, APHIS has determined that the impacts to plant communities 

from a determination of nonregulated status of MON 87712 soybean are similar to those under 

the No Action Alternative.

4.4.3 Gene Flow and Weediness

No Action Alternative

Under the No Action Alternative, MON 87712 soybean would remain under APHIS regulation. 

The availability of GE, non-GE and organic soybeans would not change as a result of the 

continued regulation of MON 87712 soybean. Because soybean is highly self-pollinated and its 

pollination rate significantly decreases with distance, it does not have a high outcrossing rate 

and there are no wild soybean species or near relatives in the U.S., gene flow and introgression 

from soybean to wild or weedy species are highly unlikely (USDA-APHIS, 2011a). Soybean is 

not frost tolerant, does not reproduce vegetatively, its seed is not easily dispersed, any volunteers 

that persist in warmer U.S. climates can be easily controlled with common agronomic practices,

and does not establish itself outside of farmed fields. Potential for weediness is nonexistent in 

commercial soybean. 

Preferred Alternative

A determination of nonregulated status of MON 87712 soybean is not expected to pose greater 

pollen- or seed-mediated gene flow, or increased potential for weediness than that of currently 

cultivated soybean varieties. There were no significant differences among the parameters that 

may lead to an increased potential for gene flow or weediness between MON 87712 soybean and 

the A3525 conventional control. 

The BBX32 gene, derived from A. thaliana, was inserted into the MON 87712 soybean gene 

sequence and interacts with one or more of the soybean’s endogenous transcription factors that 

regulate day/night processes to increase plant nutrient assimilation (Monsanto, 2011). An 

increase in nutrient assimilation is believed to increase yield in MON 87712 soybean. 

Assimilates increase as a result of an increased period of photosynthetic activity and evidence of 

changes in diurnal metabolism during the soybean’s reproductive phase compared to the 

conventional control A3525 (Monsanto, 2011). MON 87712 soybean is equally susceptible to 

all cultural variables affecting yield as other GE and non-GE soybean varieties.

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APHIS evaluated information in its PPRA on the inserted genetic material, the potential for 

vertical and horizontal gene transfer, and weedy characteristics of MON 87712 soybean and 

concluded it would not represent any plant pest risk (USDA-APHIS, 2011b). Field trials and 

laboratory data collected on MON 87712 soybean indicate no plant pathogenic properties or 

weediness characteristics. Based on agronomic data and compositional analyses, MON 87712

soybean was found to be substantially equivalent to conventional soybean and would no more 

likely become a plant pest than conventional soybean. 

The reproductive characteristics of MON 87712 soybean are substantially equivalent to other GE 

and non-GE soybean varieties (Monsanto, 2011). The field study to assess the potential for 

persistence outside cultivation calculated the replacement value for both MON 87712 soybean 

and the conventional control A3525 (Monsanto, 2011). The replacement value is the ratio of the 

number of seeds produced to the number of seeds sown; a replacement value less than one 

indicates that fewer seeds were produced than sown, meaning the plant will not replace itself and 

not persist; a value greater than one means more seeds were produced than were sown indicating 

the population has the potential to increase. At three of the four sites the replacement value was 

zero, whereas one site had replacement values for MON 87712 soybean and the conventional 

control A3525 of 2.72 and 2.63 respectively at the end of the first growing season; however, no 

plants emerged during the second growing season and as such the replacement value at that site 

was zero. This study demonstrates that MON 87712 soybean would not persist in unmanaged 

environments and does not demonstrate a competitive advantage compared to conventional 

soybean. The trait for increased yield is not expected to contribute to increased weediness 

without changes in a combination of other characteristics associated with weediness, such as 

hard seed and dormancy, among other characteristics. Given the reproductive nature of soybean, 

the potential for cross-pollination of MON 87712 soybean with other soybean cultivars is highly 

unlikely.

Studies have indicated horizontal gene transfer and expression of DNA from a plant species to 

bacteria is unlikely to occur (Keese, 2008). Furthermore, there is no evidence that bacteria 

closely associated with plants or their constituent parts contain genes derived from plants 

(Kaneko et al., 2000; Wood et al., 2001; Kaneko et al., 2002) and when horizontal gene transfer 

has been found to occur, it has been on an evolutionary time scale of millions of years (Koonin et 

al., 2001; Brown, 2003). Finally, FDA has determined the chance of transfer of antibiotic 

resistance genes from plant genomes to microorganisms in the gastrointestinal tract of humans or 

animals, or in the environment, is remote (US-FDA, 1998). Based on this information, APHIS 

has concluded that horizontal gene flow from MON 87712 soybean to other unrelated organisms 

would be highly unlikely (USDA-APHIS, 2011b).

In the event of a determination of nonregulated status of MON 87712 soybean, the risks to wild 

plants and agricultural productivity from weedy MON 87712 soybean populations are low, as 

volunteer soybean populations can be easily managed and there are no feral or weedy relatives in 

the United States (Carpenter et al., 2002). If present as volunteer soybean, MON 87712 soybean 

would not be considered difficult to control, as soybean seeds rarely remain viable the following 

season and are easily managed with cultivation or hand weeding, or the application of herbicides. 

In addition, since no feral or weedy species of soybean exist in the United States (Ellstrand et al., 

1999; OECD, 2000), MON 87712 soybean poses no potential for either naturally occurring, 

pollen-mediated gene flow or transgene introgression (USDA-APHIS, 2011b).

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Based on the above information, APHIS has determined that the impacts to other vegetation in 

soybean fields and the surrounding landscapes from a determination of nonregulated status of 

MON 87712 soybean are similar to those under the No Action Alternative.

4.4.4 Microorganisms

No Action Alternative

Under the No Action Alternative, MON 87712 soybean would remain under APHIS regulation. 

The availability of GE, non-GE and organic soybeans would not change as a result of the 

continued regulation of MON 87712 soybean. Agronomic practices used for soybean production, 

such as soil inoculation, tillage and the application of agricultural chemicals (pesticides and 

fertilizers) that potentially impact microorganisms, would continue. 

As discussed in Subsection 2.3.4, soil microorganisms play a key role in soil structure formation, 

decomposition of organic matter, toxin removal, nutrient cycling, and most biochemical soil 

processes (Garbeva et al., 2004). They also suppress soil-borne plant diseases and promote plant 

growth (Doran et al., 1996). One gram of soil may contain upwards of 50,000 bacterial species 

(Curtis et al., 2002; Mendes et al., 2011). In addition, the composition of the microbial 

community is dependent on factors such as soil type, plant type, and agricultural practices 

(Garbeva et al., 2004; Garbeva et al., 2008). It has been demonstrated that plants are able to 

influence the rhizosphere microbial community through exudates that stimulate or inhibit certain 

microbes (Berensen et al., 2012). 

One main factor affecting microbial population size and diversity is soil type and characteristics, 

including texture, structure, organic matter, aggregate stability, pH, and nutrient content. 

Additional factors include plant type (providers of specific carbon and energy sources into the 

soil), agricultural management practices (crop rotation, tillage, herbicide and fertilizer 

application, and irrigation) (Garbeva et al., 2004) and cropping history (Garbeva et al., 2008). 

Repeated tillage can reduce the amount of SOM that fuels function of the soil ecosystem and

possibly by decreasing aggregate size and stability, and changing soil pH, salinity, and sodium 

concentration; these may impact bacterial populations (University of Minnesota, 2002; FAO, 

2013). Inorganic fertilizers do provide some nutrients needed by soil microorganisms and favor 

those species that can best use the forms of nutrients found in fertilizers; however, the acidity, 

alkalinity, or salt found in certain fertilizers may reduce populations of fungi, nematodes, and 

protozoans (USDA-NRCS, 2004). Provided inorganic fertilizers are used carefully, they can 

benefit soil ecosystem functioning by increasing plant growth and the input of organic matter 

into the soil. Methods to manage soil biology and mitigate impacts from tillage and other 

practices would benefit the microbial community, and these include maximizing crop residue, 

installing cover crops, altering crop rotations, and reducing tillage (University of Minnesota, 

2002).

Growers would continue to choose certain pesticides based on weed, insect and disease 

pressures, along with considering other related costs for seed and other inputs, technology fees, 

human safety, potential for crop injury, and ease and flexibility of the production system 

(Heiniger, 2000; Farnham, 2001; University of Arkansas, 2008). The impact of herbicides on 

microorganisms is dependent on a wide variety of factors such as formulations, constituents, 

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concentrations, and environmental factors (e.g., soil type, plant type, agricultural management 

practices) (Garbeva et al., 2004; Garbeva et al., 2008). Identifying and quantifying the specific 

impacts of herbicides on the soil microbial community is difficult and is subject to a multitude of 

variables (see Subsection 2.3.4, Microorganisms). The environmental risks of pesticide use are 

assessed by EPA in the pesticide registration process and are regularly reevaluated by EPA for 

each pesticide to maintain its registered status under FIFRA. Pesticide use according to label 

directions approved by the EPA would have a reasonable certainty of not posing unreasonable 

risks to the environment, including microorganisms. 

In a review of studies of the below ground impacts of GE plants, Kowalchuk et al. (2003) found 

that GE crops investigated to date had minor to no detectable effects on the size, composition, or 

activity of important soil microorganisms, and the effects that had been observed were minimal 

when compared to “normal” sources of variation such as agricultural practices (e.g., tillage, 

planting, fertilization), season, weather, plant development, location and plant genotype.

As discussed in Subsection 4.2.2.1, agronomic practices used for soybean production, such as 

soil inoculation, tillage, irrigation and the application of agricultural chemicals (pesticides and 

fertilizers) that potentially impact microorganisms are expected to continue under the No Action 

Alternative.

Preferred Alternative

A determination of nonregulated status of MON 87712 soybean is not expected to result in 

changes in current soybean cropping practices that may impact microorganisms.

Similar to other GE crops, MON 87712 soybean has the potential to directly and indirectly 

impact microbial communities. MON 87712 soybean could have some impact on the structure 

of the soil microbial community in which it is planted, which could include nitrogen-fixing 

bacteria and mycorrhizal fungi; bacteria, actinomycetes (filamentous bacteria), and saprophytic 

fungi responsible for decomposition; denitrifying bacteria and fungi; phosphorus-solubilizing 

bacteria and fungi; as well as pathogenic and parasitic microbes (see Subsection 2.3.4, 

Microorganisms) (USDA-NRCS, 2004). Greenhouse testing by Monsanto revealed no 

significant differences found in the parameters measured to assess the symbiotic relationship of 

the legume and its associated rhizobia (e.g., nodule number, shoot percent total nitrogen, shoot 

total nitrogen, dry weight of nodules, shoot material, and root material) between MON 87712

soybean and the conventional control A3525 and six commercial reference varieties (see Section 

VII.C.4, Symbiont Interactions, Table VII-6, and Appendix J of the Monsanto Petition) 

(Monsanto, 2011). During comparative field observations, responses of MON 87712 soybean to 

abiotic stressors such as drought, mineral and nutrient toxicity, and temperature stress were 

similar to the A3525 control. In addition, data collected on plant-disease interactions during 

environmental assessments indicated that the presence of the BBX32 protein did not alter disease 

susceptibility of MON 87712 soybean compared to conventional soybean, suggesting no 

different impact to the pathogenic microbial community.

Like other high yielding soybean cultivars and high yield soybean production systems, 

cultivation of MON 87712 may remove more nutrients, particularly phosphorus and potassium, 

than other varieties. Such depletion necessitates testing and possibly increased soil nutrient 

amendments. Soil organisms require varying amounts of both macronutrients, including 

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phosphorus, and micronutrients (USDA-NRCS, 2004). Several studies have demonstrated B. 

japonicum activity, root nodulation, and dinitrogen fixation are positively correlated with 

phosphorus levels (Cassman et al., 1980; Beck and Munns, 1984; Israel, 1987; Mullen et al., 

1988; Sa and Israel, 1991; Tsvetkova and Georgiev, 2003). Likewise, potassium is necessary for 

nodule formation and bacteria-mediated nitrogen fixation in soybean and other nitrogen-fixing 

legumes (Mengel et al., 1974; IPNI, 1998). As discussed in Subsection 4.2.2, Agronomic 

Practices, nutrient application to soybean is not an uncommon practice and is widely 

recommended to sustain the yields of all soybean cultivars. 

Based on the above information, overall impacts to microorganisms under the Preferred 

Alternative are expected to be similar to the No Action Alternative.

4.4.5 Biodiversity

Impacts to biodiversity can occur at the crop, farm, and/or landscape level (Visser, 1998; 

Ammann, 2005; Carpenter, 2011). For purposes of this EA, crop diversity refers to the genetic 

uniformity within crops, farm-scale diversity refers to the level of complexity of organisms 

within the boundaries of a farm, and landscape level diversity refers to potential changes in land 

use and the impacts of area-wide weed suppression beyond the farm boundaries (Carpenter, 

2011).

No Action Alternative

Under the No Action Alternative, MON 87712 soybean would remain under APHIS regulation; 

the availability of GE, non-GE and organic soybeans would not change. Agronomic practices 

used for soybean production and yield optimization, such as tillage, the application of 

agricultural chemicals (pesticides and fertilizers), timing of planting, row spacing, and scouting 

would be expected to continue. Agronomic practices that benefit biodiversity would continue 

both on cropland (e.g., intercropping, agroforestry, crop rotations, cover crops, and no-tillage) 

and on adjacent non-cropland (e.g., woodlots, fencerows, hedgerows, and wetlands).

Preferred Alternative

A determination of nonregulated status of MON 87712 soybean is not expected to result in 

changes in current soybean cropping practices that may impact biodiversity. Field trials and 

laboratory analyses conducted by Monsanto showed no differences between MON 87712

soybean and other GE and non-GE soybean in growth, reproduction, or interactions with pests 

and diseases (Monsanto, 2011). Similar to the No Action Alternative, weeds within fields of 

MON 87712 soybean could be managed using mechanical, cultural, and chemical control. 

Growers would determine the best method necessary to manage pests based on individual needs. 

The environmental risks of pesticide use are assessed by EPA during the pesticide registration 

process and are regularly reevaluated by EPA to maintain its registered status under FIFRA for 

each pesticide. Pesticide use in accordance with label instructions approved by EPA would have 

a reasonable certainty of posing no unreasonable risks to the environment. Under the Preferred 

Alternative, potential impacts to biodiversity are not expected to be substantially different from 

those associated with the No Action Alternative, including those from runoff, spray drift, and 

volatilization of agricultural chemicals such as pesticides, herbicides, and fungicides.

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Potential risks to biodiversity from the production of GE crops include the disturbance of 

biosystems, including the agroecosystem, and changing permanently the species diversity of the 

habitat or the genetic diversity within a species (Snow et al., 2005). As discussed in Subsection 

2.3.5, Biodiversity, the intensive farming practices associated with agricultural lands limit the 

diversity of plants and animals (Lovett et al., 2003). Diversity in adjacent natural areas, and those 

areas established to promote biodiversity (e.g., woodlots, fencerows, hedgerows, and wetlands) 

tend to have greater biodiversity. Agronomic practices for the production of MON 87712

soybean are not expected to change from those currently used for other commercially available 

GE and non-GE soybean; therefore, impacts to species diversity would be similar to that of the 

No Action Alternative. Moreover, the agronomic practices commonly used to increase farmscale biodiversity (see Subsection 2.3.5) are likewise not expected to change. As discussed in 

Subsection 4.4.3, Gene Flow and Weediness, MON 87712 soybean poses no potential for 

naturally occurring, pollen-mediated gene flow and transgene introgression into native or 

naturalized plants and is not expected to affect genetic diversity. 

A determination of nonregulated status of MON 87712 soybean is anticipated to have similar 

effects on crop, farm or landscape level biodiversity as the No Action Alternative. As such, the 

impacts of biodiversity under the Preferred Alternative are expected to be similar to the No 

Action Alternative.

4.5 Human Health

4.5.1 Public Health

No Action Alternative: 

Under the No Action Alternative, MON 87712 soybean would remain under APHIS regulation. 

Human exposure to existing GE and non-GE soybean varieties would not change under this 

alternative. Grower and consumer exposure to cultivated MON 87712 soybean would be limited 

to those individuals involved in its cultivation under regulated conditions. 

A variety of EPA-approved pesticides would continue to be used for pest management in both 

GE and non-GE soybean cultivation. When evaluating the potential consequences that may result 

from a determination of nonregulated status of a GE crop, USDA-APHIS considers the EPA’s 

registration of pesticides. The environmental risks of pesticide use are assessed by EPA in the 

pesticide registration process and are regularly reevaluated by EPA for each pesticide to maintain 

its registered status under FIFRA. As part of the registration process, the EPA considers human 

health effects from the use of pesticides and must determine that the pesticide will not cause

unreasonable adverse effects on human health. If needed, the EPA will establish label restrictions 

to mitigate or alleviate potential impacts on human health and the environment. Pesticide 

registration labels provide the guidelines, application restrictions, and precautions necessary to 

protect human health. These label restrictions carry the weight of law and are enforced by EPA 

and the states (Federal Insecticide, Fungicide, and Rodenticide Act 7 USC 136j (a)(2)(G) 

Unlawful Acts). 

Similarly, the EPA establishes tolerances to regulate the amount of pesticide residues that can 

remain on food or feed commodities as the result of pesticide applications (see, e.g., 

http://www.epa.gov/pesticides/bluebook/chapter11.html) (US-EPA, 2010a), and the FDA and 

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USDA monitor foods for pesticide residues and enforce these tolerances (USDA-AMS, 2011)

(see Subsection 2.4.1, Human Health). The tolerance level is the maximum residue level of a 

pesticide that can legally be present in food or feed. If pesticide residues are found to exceed the 

tolerance value, the food is considered adulterated and may be seized. The EPA ensures that 

residue tolerances for pesticides meet FQPA safety standards for the U.S. population and 

designated sensitive populations (i.e., infants and children). EPA makes a finding that there is a 

reasonable certainty of no harm to the general population and any subgroup from the use of 

pesticides at the approved levels and methods of application.

Preferred Alternative

The protein in MON 87712 soybean that regulates the plant’s day/night processes resulting in 

increased availability of assimilates is derived from the BBX32 gene from the plant A. thaliana,

whose common name is mouseear cress. Mouseear cress is an annual forb belonging to the 

Brassicaceae (mustard) family that also includes common food plants such as broccoli, 

cauliflower, cabbage, and canola (USDA-NRCS, 2013c). Mouseear cress is not consumed by 

humans and is not known to be consumed by animals. 

Monsanto conducted safety evaluations based on Codex Alimentarius Commission procedures to 

assess any potential adverse effects to humans or animals resulting from environmental releases 

and consumption of MON 87712 soybean (FAO, 2009; Monsanto, 2011). These safety studies 

included: (1) characterization of the physicochemical and functional properties of BBX32; (2) 

quantification of BBX32 levels in plant tissues; (3) comparison of the amino acid sequence of 

BBX32 in MON 87712 soybean to known allergens, gliadins, glutenins, toxins, and other 

biologically-active proteins known to have adverse effects on mammals; (4) evaluation of the 

digestibility of BBX32 protein in simulated gastric and intestinal fluids; (5) documentation of the 

presence of related proteins in several plant species currently consumed; and (6) investigation of 

the potential mammalian toxicity through an oral gavage assay. The BBX32 protein was 

determined to have no amino acid sequence similar to known allergens, lacked toxic potential to 

mammals, and was degraded rapidly and completely in simulated gastric fluid. Monsanto has 

initiated a food/feed safety consultation on MON 87712 soybean with the FDA (Monsanto, 

2011). A final decision from FDA is pending. MON 87712 soybean does not express a 

pesticidal property, and, accordingly, is not regulated by the U.S. EPA. 

Monsanto also has evaluated the compositional and nutritional characteristics of MON 87712

soybean grain and forage, comparing the composition of the GE soybean with conventional 

products components in accordance with OECD guidelines (OECD, 2001). MON 87712 soybean 

was compared to several conventional soybean varieties from eight different field trial locations 

and analyzed for comparable nutritional composition. Compositional elements compared 

included proximates (protein, fat, carbohydrates, fiber, ash, and moisture), fiber, amino acids, 

fatty acids, and vitamin E in harvested seed, and proximates and fiber in forage. The antinutrients assessed in harvested seed included raffinose, stachyose, lectin, phytic acid, trypsin 

inhibitors, and isoflavones (Monsanto, 2011). There were no biologically meaningful 

differences for any of these compositional characteristics between the MON 87712 soybean and 

the conventional soybean varieties.

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Based on this information, including field and laboratory data and scientific literature provided 

by Monsanto (2011) and safety data available on other GE soybean, APHIS has concluded that a 

determination of nonregulated status of MON 87712 soybean would have no adverse impacts on 

human health. Overall impacts would be similar to the No Action Alternative.

4.5.2 Occupational Health and Safety

No Action Alternative

The availability of GE, non-GE and organic soybeans would not change as a result of the 

continued regulation of MON 87712 soybean. Agronomic practices used for soybean 

production, such as the application of agricultural chemicals (pesticides and fertilizers), would be 

expected to continue. Growers will continue to choose agronomic practices based on weed, 

insect and disease pressures, cost of seed and other inputs, technology fees, human safety, 

potential for crop injury, and ease and flexibility of the production system (Heiniger, 2000; 

Farnham, 2001; University of Arkansas, 2006). Worker safety is taken into consideration by 

EPA in the pesticide registration process and reregistration process. Pesticides are regularly 

reevaluated by EPA for each pesticide to maintain its registered status under FIFRA. 

Furthermore, the OSHA requires all employers to protect their employees from hazards 

associated with pesticides and herbicides. When used according to label directions, pesticides 

can be used with a reasonable certainty of no harm to human health and without posing 

unreasonable risks to the environment.

Preferred Alternative

A determination of nonregulated status of MON 87712 soybean is not expected to result in 

changes in current soybean cropping practices. Similar to the No Action Alternative, it is 

expected that EPA-registered pesticides, fertilizers, and other chemicals that currently are used 

for soybean production would continue to be used by growers. EPA’s core pesticide risk 

assessment and regulatory processes ensure that each registered pesticide continues to meet the 

highest standards of safety including all populations of non-target species and humans, and if 

used in accordance with the label, can be demonstrated to pose “a reasonable certainty of no 

harm to humans” and “no unreasonable adverse effects to the environment.” Growers are 

required to use pesticides consistently with instructions for application provided on the EPAapproved pesticide label. These label restrictions carry the weight of law and are enforced by 

EPA and the states (Federal Insecticide, Fungicide, and Rodenticide Act 7 USC 136j (a)(2)(G) 

Unlawful Acts). 

Exposure to MON 87712 soybean under the Preferred Alternative is not expected to elicit any 

change in existing human health status of individuals or populations. Based on the above 

information, overall impacts to occupational health and safety under the Preferred Alternative are 

expected to be similar to the No Action Alternative.

4.6 Animal Feed

The majority of the soybean cultivated in the United States is grown for animal feed and is 

usually fed as soybean meal. Animal agriculture consumes 98% of the U.S. soybean meal 

produced (Soyatech, 2011). As with human health, the consumption of the inserted genes and 

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proteins in MON 87712 soybean is considered the primary concern relative to animal feed, but 

any changes in composition or nutrition are also relevant to potential impacts of recognizing 

nonregulated status.

No Action Alternative

Under the No Action Alternative, MON 87712 soybean would remain under APHIS regulation 

and soybean derived from MON 87712 would not be allowed for distribution to the animal feed 

market. Soybean-based animal feed would still be available from currently cultivated soybean 

crops, including both GE and non-GE soybean varieties. No change in the availability of these 

crops as animal feed is expected under this alternative.

Preferred Alternative

APHIS’ assessment of the potential impacts of the consumption of the BBX32 protein by 

animals considers the source of the gene and the expressed protein, as well as safety evaluations 

conducted by Monsanto. The protein in MON 87712 soybean that regulates the plant’s day/night 

processes resulting in increased availability of assimilates is derived from the BBX32 gene from 

the plant A. thaliana, also known as mouseear cress. Mouseear cress is an annual forb belonging 

to the Brassicaceae (mustard) family that also includes common food plants such as broccoli, 

cauliflower, cabbage, and canola (USDA-NRCS, 2013c). BBX32 is a protein that has homologs 

in food plants with a history of safe use.

Monsanto’s safety evaluations were based on Codex Alimentarius Commission procedures to 

assess any potential adverse effects to humans or animals resulting from environmental releases 

and consumption of MON 87712 soybean (Monsanto, 2011). These safety studies included: (1) 

characterization of the physicochemical and functional properties of BBX32; (2) quantification 

of BBX32 levels in plant tissues; (3) comparison of the amino acid sequence of BBX32 in MON 

87712 soybean to known allergens, gliadins, glutenins, toxins, and other biologically-active 

proteins known to have adverse effects on mammals; (4) evaluation of the digestibility of 

BBX32 protein in simulated gastric and intestinal fluids; (5) documentation of the presence of 

related proteins in several plant species currently consumed; and (6) investigation of the potential 

mammalian toxicity through an oral gavage assay. The BBX32 protein was determined to have 

no amino acid sequence similar to known allergens, lacked toxic potential to mammals, and was 

degraded rapidly and completely in gastric fluid. Monsanto has initiated a food/feed safety 

consultation on MON 87712 soybean with the FDA (Monsanto, 2011). A final decision from 

FDA is pending.

Monsanto also has evaluated the compositional and nutritional characteristics of MON 87712

soybean grain and forage, comparing the composition of the GE soybean with conventional 

products. MON 87712 soybean was compared to several conventional soybean varieties from 

eight different field trial locations and analyzed for comparable nutritional components in 

accordance with OECD guidelines (OECD, 2001). Compositional elements compared included 

proximates (protein, fat, carbohydrates, fiber, ash, and moisture), fiber, amino acids, fatty acids, 

and vitamin E in harvested seed, and proximates and fiber in forage. The anti-nutrients assessed 

in harvested seed included raffinose, stachyose, lectin, phytic acid, trypsin inhibitors, and 

isoflavones (Monsanto, 2011). There were no biologically meaningful differences for any of 

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these compositional characteristics between the MON 87712 soybean and the conventional 

soybean varieties.

The results of studies conducted by Monsanto confirm that the crops containing this protein can 

be safely used as animal feed. There are no differences in feed safety between the MON 87712

soybean and other varieties currently available under the No Action Alternative. Based on this 

information, including field and laboratory data and scientific literature provided by Monsanto 

(2011), and safety data available on other GE soybean, APHIS has concluded that a 

determination of nonregulated status of MON 87712 soybean would have no adverse impacts on 

animal health through use as animal feed. Overall impacts would be similar to the No Action 

Alternative.

4.7 Socioeconomic Impacts

4.7.1 Domestic Economic Environment

No Action Alternative

In 2011, 77 million acres of soybeans were planted in the United States, yielding 3.1 billion 

bushels (84.4 MMT) at a value of 35.8 billion U.S. dollars (USDA-NASS, 2012g). The majority 

of soybeans produced in the United States are used domestically for animal feed, with lesser 

amounts and byproducts used for oil or fresh consumption (GINA, 2013; USDA-ERS, 2013a). 

From 1924 when recording U.S. soybean production first began, both soybean acreage and yields 

have steadily increased (Egli, 2008). In comparison, total U.S. cropland has remained relatively 

level since 1945, except in 2007 when it retracted, in part due to changes in USDA classification 

procedures for the 2007 Census of Agriculture (USDA-ERS, 2011e). From 1991 to 2011, U.S. 

soybean acreage expanded 31% and yields increased 17.6% (USDA-NASS, 2012l; USDANASS, 2012j) while annual value of production increased approximately 222% from 

approximately $11.09 billion to approximately $35.8 billion (USDA-NASS, 2012i). 

The expansion of U.S. soybean acreage has largely occurred by replacing other crops on existing 

cropland, and increasing double-cropping (USDA-ERS, 2011f). Yield increases have been 

achieved by adopting higher yield cultivars conventionally bred with GE herbicide-resistant and 

pest-resistant varieties, such as Genuity Ready 2 Yield® (Monsanto), LibertyLink® (Bayer), and 

Y Series® (Pioneer). Herbicide- resistant soybean are grown on 93% of soybean acres (see 

Subsection 2.1.1, Acreage and Area of Soybean Production) and increase yields through 

economically reducing weed competition. Improved management practices such as narrow row 

planting, foliar fungicide application, and fertilization are also factors in achieving increased 

yields (see Subsection 4.2.2, Agronomic Practices). It is expected that planted U.S. soybean 

acreage would hold steady at 76 million acres from 2013/2014 to 2021/2022, primarily because 

of increased foreign competition (less demand), the continued trend of planting more corn 

(lessened supply), but accompanied by increased demand for domestic soybean oil in biodiesel 

production (USDA-OCE, 2012). 

Soybean supply is a function of the amount of acreage planted to soybean and yield. While 

domestic soybean yield has increased, current demand for soybean products has also increased, 

mitigating any downward pressure on farm soybean prices from potentially increased supply 

(NRC, 2010). The national average of U.S. soybean yield is expected to increase between 0.4 to 

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0.5 bushels per acre per year during the same time period, from 44.5 bushels per acre projected 

in 2013/2014 to 48.1 bushels per acre in 2021/2022 at a total increase of approximately 8%, 

without expanding acreage. While overall productivity would increase without expanding U.S. 

soybean acreage, the U.S. farm price per bushel of soybean is predicted to vary only from $10.30 

to $11.35 from 2013/2014 to 2021/2022. Grower net returns are estimated to increase 

approximately 24% from $303 per acre to $375 per acre over the same period, despite an 

estimated approximately 3% rise in seed and residual costs, and 10.3% rise in overall per acre 

cost of production (USDA-OCE, 2012). 

Under the No Action Alternative, MON 87712 soybean would remain under APHIS regulation. 

Growers and other parties who are involved in production, handling, processing, or consumption 

of soybean would continue to have access to nonregulated GE and non-GE soybean varieties. 

Domestic growers would continue to use GE and non-GE soybean varieties based upon 

availability and market demand. As discussed in Subsection 4.2.2, agronomic practices and 

conventional breeding techniques using GE herbicide- and pest-resistant cultivars currently used 

to optimize yield and reduce production costs would be expected to continue under the No 

Action Alternative. Under the No Action Alternative, any potential increase to yield from the 

production of MON 87712 soybean would not be realized.

Preferred Alternative

In field tests accomplished by Monsanto, the performance and composition of MON 87712

soybean was determined as not substantially different from that of the non-GE comparator 

A3525 soybean and other conventional soybean reference varieties (Monsanto, 2011). Field 

tests in 2010 demonstrated MON 87712 soybean did have a statistically higher yield than the 

conventional control A3525 (7.3%), and its average yield during field trials was 18.9% greater 

than the average yield for the entire U.S. soybean crop reported for 2010; however, its yield in 

the study trial was within the range of conventional varieties reported that year of 67.5 bushels 

per acre to as high as 100 bushels per acre for some locations (Monsanto, 2011), and well below 

the world record for soybean yield per acre achieved in 2010 in Missouri at 160.6 bushels per 

acre for irrigated soybean and 98.9 bushels per acre for non-irrigated soybean (Alsager, 2010). 

MON 87712 soybean is subject to the same variables that affect yield of other GE and non-GE 

soybean varieties such as weather, timing and density of planting, and soil nutrients (see 

Subsection 2.1.2, Agronomic Practices). Growers are familiar with yield improvements using 

varieties with increased yield obtained through traditional breeding techniques, and more 

recently, from better weed control and disease resistance in transgenic soybean varieties. As 

discussed under the No Action Alternative, soybean yield has increased steadily from 1924 to 

present, increasing over 30 bushels per acre during this period (USDA-NASS, 2012j). 

MON 87712 soybean is expected to be gradually adopted by many of those growers who are 

already growing biotechnology-derived soybeans. Additionally, Monsanto may only 

progressively phase in the incorporation of the trait into their soybean varieties. The rate of 

adoption will depend on the expectation of yield increase, the price of the seed, and other factors. 

The adoption of MON 87712 soybean is expected to be gradual because its yield benefits may 

not be immediately apparent, as it is subject to variables affecting yield common to all soybean 

varieties (Monsanto, 2011). Monsanto estimates maximum trait adoption would be 

approximately 50- 60% (Monsanto, 2011). This estimate assumes that other seed companies will 

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offer soybean varieties that do not contain MON 87712 traits and these varieties will compete for 

market share with varieties that do contain MON 87712 soybean traits. In addition, it is assumed 

that there will be demand for non-GE conventional, organic soybean as well as other specialty 

soybean and these soybean varieties will also compete for acreage with MON 87712 soybean. As 

variations of yields are experienced field-to-field and year-to-year in GE and non-GE soybean 

production, growers are already accustomed to harvesting and storing increased yields that may 

occur following adoption of MON 87712 soybean. 

It is unlikely the availability of MON 87712 soybean would significantly impact the domestic 

economic environment. As discussed under the No Action Alternative, past and recent growth in 

U.S. soybean acreage has occurred at the expense of acreage planted to other crops and not by 

bringing new lands into production. Overall total U.S. cropland has remained relatively stable 

since the mid-20th century. Since 93% of U.S. soybean acreage is planted with GE soybean 

varieties, it is likely that MON 87712 soybean would replace other varieties of GE soybean on 

existing cropland. Historically, soybean yields have been increasing for decades, in more recent 

times as a result of conventionally breeding high yielding cultivars with GE herbicide- and pestresistant (nematode) traits, in addition to improved management practices. Apart from yield, the 

phenotypic and agronomic characteristics of MON 87712 soybean have been demonstrated in 

combined trials to be similar to its comparator A3525 soybean and other commercially available 

reference varieties. Its yields are also similar to other, widely available high yielding soybean 

varieties that have performed as well as, or even better, than MON 87712 soybean’s yield in field 

trials. Further, U.S. soybean acreage is projected to remain relatively steady until 2021/2022, 

accompanied by an anticipated 8% per acre yield gain. Field price of soybean per bushel is not 

expected to appreciably increase, remaining between $10.30 and $11.35 per bushel, while annual 

net value of production is expected to increase. Because yield is highly variable year to year and 

from field to field, the yield benefits of MON 87712 soybean would not be readily apparent, 

likely slowing its adoption. Finally, MON 87712 soybean would also compete with other high 

yielding soybeans conventionally bred with GE herbicide- and pest-resistant traits, and 

conventional, and organic soybean varieties, thus its maximum market potential is estimated at 

50-60% (Monsanto, 2011). 

As discussed in Subsection 2.6.1, Domestic Economic Environment, GE seed is generally more 

expensive than conventional seed; producers using MON 87712 soybean would likely be 

charged a premium technology fee in addition to those fees for other traits as part of the seed 

purchase price (NRC, 2010). Technology fees are charged by the product developer to cover 

research and development, production, marketing and distribution expenses. The amount of the 

fee is determined by producers’ willingness to purchase the seed, the competiveness of the seed 

market and the pricing behavior of firms that hold large shares of the market (NRC, 2010). 

APHIS has no control over the establishment of technology fees, but assumes that the fee for 

MON 87712 soybean would be consistent with the fee charges for other GE crops. Growers must 

make an independent assessment as to whether the benefits of MON 87712 soybean would offset 

higher seed cost. As discussed under the No Action Alternative, an approximately 3% rise in 

seed and residual costs is projected from 2013/2014 to 2021/2022 (USDA-OCE, 2012).

While the MON 87712 soybean trait has a similar phenotype to conventionally bred traits for 

increased yield, these other traits are different because they are most likely derived from multigene inheritance. Selection and incorporation of such multigenic traits are more complicated for 

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seed developers to develop and incorporate, and therefore, the employment of this Monsanto trait 

is likely to provide significant benefits in efficiency of seed and trait production. Also, it is 

possible that when the MON 87712 trait is combined with these conventionally derived traits an

additive yield enhancement may be attained, although the opposite or no effect is possible as 

well. Because of uncertainties in what the developer may do and the unknown yield 

consequence, it is not possible to predict whether an overall increased yield might be attained in 

such combinations.

As discussed in Subsection 2.1.4, Organic Soybean Production, only a small portion of the U.S. 

soybean market is organic. The value of soybean produced from organic-certified farms in the 

United States in 2011 was about $49.4 million, which was 0.14% of the total soybean crop value

(USDA-NASS, 2012j; USDA-NASS, 2012a). Organic production of grain in the United States 

remains low, with only about 0.20% of corn and soybean crops grown under certified organic 

farming systems (USDA-ERS, 2009b). Between 1997 and 2005, overall organic crop acreage 

doubled; however, between 2000 and 2005 acreage for organic grain such as soybean and corn 

declined (USDA-ERS, 2009b). The lack of growth in organic grain production in the United 

States has been associated with financial, managerial, transitional, marketing, and several other 

risk factors (Wolf, 2006; Yeager, 2006; House Hearing -110 Congress, 2007). The availability 

of MON 87712 soybean is another option for farmers to achieve increased productivity and is 

not expected to influence growers’ decisions to pursue organic soybean production.

Recent attitudes towards the production of GE crops in the United States are generally favorable 

(see Subsection 2.6.1, Domestic Economic Environment) (USDA-ERS, 2001; Thomson-Reuters, 

2010). It is not expected that an additional GE soybean variety potentially increasing farm 

productivity without altering soybean’s nutritional value, potential allergenicity, or toxicity 

would change U.S. consumer attitudes towards GE crops.

Based upon the preceding information, the potential domestic economic impacts from a 

determination of nonregulated status of MON 87712 soybean would be no different than those 

currently observed for other high yielding soybean varieties under the No Action Alternative. 

4.7.2 Trade Economic Environment

No Action Alternative

In 2012, 93% of planted soybean acres were GE varieties (USDA-ERS, 2012e). In the same 

year, the United States was responsible for 33.9% of the world’s soybean production, 19.8% of 

world’s soybean meal production, and 20.1% of the world’s soybean oil production (USDAERS, 2012b). Global exports of soybeans are expected to increase by approximately 19.3 MMT 

over the next ten years (FAPRI, 2011). Over the next decade, Argentina, Brazil, and the United 

States will account for about 88% of the world’s exports of soybean and soybean products; 

however, by 2012, the U.S. share is expected to decline from just over 30% to about 25% 

(USDA-OCE, 2012). China is expected to account for 68.8% of imports, with the EU-27 having 

the next greatest demand accounting for 10.0% of imports (FAPRI, 2011). The USDA-OEC 

(2012) predicts that soybean and soybean-product trade would be maintained throughout the next 

decade considering ongoing demand for vegetable oil and protein meal, particularly from China 

and other Asian countries. Under the No Action Alternative, it is unlikely the current soybean 

market trade trends would change if MON 87712 soybean remained regulated. U.S. soybeans 

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will continue to play a role in global soybean production, and the United States will continue to 

be a supplier in the international market (USDA-ERS, 2013b).

Preferred Alternative

A determination of nonregulated status of MON 87712 soybean is not expected to adversely 

impact the current trends affecting the trade economic environment. Commercial availability of 

MON 87712 could have an initial but indeterminable impact on the potential for increased 

yields; these yields could increase gradually as availability and adoption of the trait increased. 

As discussed in Subsection 4.7.1.2, Preferred Alternative: Domestic Economic Environment, 

field trials of MON 87712 soybean had a statistically higher yield than the conventional control 

A3525, yet it was similar to yields documented for other high-yield conventional soybean 

varieties, and is subject to the same variables that impact yield. If the developer frequently 

incorporates this trait into many varieties, if adoption of the trait is high, and conditions in fields 

are supportive of additional soybean productivity for MON 87712, then there are possibilities for 

modest increases in overall U.S. soybean production (see Subsection 4.7.1.2, Preferred 

Alternative: Domestic Economic Environment). 

Overall increased farm productivity, such as increased soybean production, may increase U.S 

competitiveness in the global economy. USDA projects that from 2013/2014 to 2021/2022, the 

national annual average of U.S. soybean yield is expected to increase approximately 8% without 

expanding acreage, but the U.S. average farm price per bushel of soybean is predicted to vary 

only between $10.30 and $11.35. Grower annual net returns per acre are estimated to increase 

on average approximately 24% over the same period, despite an estimated approximately 3% rise 

in seed and residual costs, and 10.3% rise in overall per acre cost of production (USDA-OCE, 

2012). Adoption of MON 87712 soybean would likely be gradual, dependent upon the speed of 

introduction of the trait by Monsanto, and upon the value growers place on a higher than average 

yielding soybean cultivar. A gradual increase in soybean production would be beneficial for US 

competitiveness, but an immediate large increase could potentially reduce world prices for 

soybean and the return to growers, both domestic and international. 

As discussed in Subsection 2.6.2, Trade Economic Environment, there are several factors that 

influence worldwide prices for oilseed, including soybean and its products. Included in these are 

energy costs, the value of the U.S. dollar, government policies, population, per capita income, 

global market conditions, and trends and practices in market trading and speculation (Trostle, 

2008b; Trostle, 2008a; Irwin and Good, 2009). Whether any value derived from MON 87712

soybean would be distributed between consumers in the form of reduced prices or growers as 

increased profits would be dependent upon the previously cited global factors. Any impact to 

soybean market prices from the potential increase to yield from the production of MON 87712

soybean, on top of the gradual increase in US soybean yield would likely be difficult to assess or 

predict. 

The Organisation for Economic Co-Operation and Development and the Food and Agriculture 

Organization of The United Nations anticipate that much of the future expansion of soybean 

production will derive from methods that increase yield rather than from increased area of 

production (OECD-FAO, 2008). Exported soybean seed for planting is a small share of U.S. 

soybean exports; in 2009, the value of soybean planting seed exports were about 0.11% of the 

value of bulk soybean and soybean product exports ($17.5 million and $17.6 billion respectively) 

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(USDA-FAS, 2009; USDA-ERS, 2012l). MON 87712 soybean seed could be of interest to other 

countries that also produce and export soybean. 

Monsanto plans to seek biotechnology regulatory approvals for MON 87712 soybean from all 

key soybean import countries that have a functioning regulatory system (Monsanto, 2011). In 

order to ensure global compliance and support the flow of international trade, these actions will 

be in accordance with the Biotechnology Industry Organization Policy on Product Launch10. 

Monsanto has submitted applications to several international agencies, including the regulatory 

authorities in Canada; the Ministry of Agriculture, People’s Republic of China; Japan’s Ministry 

of Agriculture, Forestry, and Fisheries, Ministry of Environment, and the Ministry of Health, 

Labor, and Welfare; the Intersectoral Commission for Biosafety of Genetically Modified 

Organisms, Mexico; and the European Food Safety Authority, as well as other soybean 

importing countries with a functioning regulatory system (Monsanto, 2011). Approval in these 

export countries is intended to mitigate global sensitivities to GE products and work in 

accordance with international regulations. Timely compliance with these agencies will also 

prevent adverse effects on trade. While some countries do not assess GE crops from the United 

States until non-regulated status has been determined in the United States, APHIS does not 

otherwise have an influence on countries to which crops are exported. 

It is not expected that the availability of MON 87712 soybean would affect world attitudes 

towards GE crops. While 28 other countries have adopted the use of GE crops (Clive, 2011), 

consumers in many countries, such as several EU-27 countries, believe the potential risks posed 

by GE crops outweigh any potential benefits they may provide (Costa-Font et al., 2008). 

However, the EU has approved GE soybean food and feed products containing traits conferring 

resistance to glufosinate, glyphosate, and ALS-inhibiting herbicides and certain lepidopteran 

resistance for import for food and feed use in EU-27 countries (European Commission, 2013). It 

is expected food and feed derived from MON 87712 soybean would likely be approved by the 

EU as well since the cultivar has been genetically modified for increased yield using only a plant 

gene from A. thaliana. This gene expressing the BBX32 protein has homologs in common food 

plants such as broccoli, cauliflower, cabbage, and canola with a history of safe use (USDANRCS, 2013c).

The adventitious presence of GE products in other food or feed continues to be a concern of 

internationally traded grain (Demeke et al., 2005). Monsanto performs quality control tests of 

their products to ensure traits such as MON 87712 would not be inadvertently incorporated into

commodity soybean before necessary foreign approvals. Similarly, buyers, foreign governments, 

nongovernmental organizations, and consumer groups may use private testing firms to mitigate 

the potential for adventitious presence of GE traits in food or feed products. Monsanto has 

indicated tests to determine the presence of the BBX32 gene in seed stock would be available 

and easily accomplished.

In conclusion, the potential impacts to the trade economic environment from a determination of 

nonregulated status of MON 87712 soybean would be no different than those currently observed 

for other high yield soybean varieties under the No Action Alternative. 

10 Available at 

http://www.excellencethroughstewardship.org/LinkClick.aspx?fileticket=U8SEhLYSZYA%3D&tabid=62

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5 CUMULATIVE IMPACTS

5.1 Assumptions Used for Cumulative Impacts Analysis

Cumulative effects have been analyzed for each environmental issue assessed in Section 4, 

Environmental Consequences. In this EA, the cumulative effects analysis is focused on the 

incremental impacts of the Preferred Alternative taken in consideration with related activities 

including past, present, and reasonably foreseeable future actions. Certain aspects of this product 

and its cultivation would be no different between the alternatives; those instances are described 

below. In this analysis, if there are no direct or indirect impacts identified for a resource area, 

then APHIS assumes there can be no cumulative impacts. Where it is not possible to quantify 

impacts, APHIS provides a qualitative assessment of potential cumulative impacts. APHIS will 

limit the analysis of cumulative impacts to the areas in the U.S. where soybean is commercially 

produced. 

A potential for reasonably foreseeable cumulative effects is analyzed under the assumption that 

farmers, who produce conventional or organic soybean and those who plant MON 87712

soybean would continue to use reasonable, commonly accepted BMPs for their chosen 

production method using favored traits. APHIS recognizes, however, that not all farmers will 

use such BMPs; thus, the cumulative impact analysis will also make the assumption that not all 

farmers would do so. 

Crop varieties that contain more than one GE trait, known as a “stacked” hybrid, are currently 

found in agricultural production and in the marketplace. If APHIS approves the nonregulated 

status of MON 87712 soybean, it would likely be combined with non-GE and GE soybean 

varieties through traditional breeding techniques. Stacking of nonregulated GE crop varieties 

using traditional breeding techniques is common industry practice and is not regulated by 

APHIS. Stacking would involve combining MON 87712 soybean with other soybean varieties 

having GE traits such as herbicide resistance, non-GE pest resistance, altered nutritional 

characteristics (e.g. high oleic acid), which are no longer subject to the regulatory requirements 

of 7 CFR part 340 or the plant pest provisions of the Plant Protection Act. Such stacked varieties 

could provide growers with several options such as combining several herbicides with different 

modes of action for control of weeds; therefore, as part of the cumulative impacts analysis, 

APHIS will assume that MON 87712 soybean would likely be combined with commercially 

available herbicide-resistant, non-GE pest-resistant, or altered nutritional profile varieties of 

soybean as a reasonably foreseeable future action. This intention is also provided by Monsanto in 

the petition for determination of nonregulated status (Monsanto, 2011).

5.2 Cumulative Effects

5.2.1 Past and Present Actions and the Preferred Alternative

In the preceding analysis, the potential impacts from a determination of nonregulated status to 

MON 87712 soybean were assessed. The agronomic characteristics evaluated for MON 87712

soybean encompassed the entire life cycle of the soybean plant and included germination, 

seedling emergence, growth habit, vegetative vigor, days to pollen shed, days to maturity, and 

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yield parameters. The compositional analysis included the proximates (moisture, carbohydrates, 

protein, fat, and ash), fiber, vitamin E, amino acids, fatty acids, antinutrients and nutritional 

impact in seed and proximates and fiber in forage. Except for its enhanced yield potential, MON 

87712 soybean is agronomically and compositionally similar to its non-GE comparator A3525, 

as well as other GE and non-GE soybean varieties (Monsanto, 2011; USDA-APHIS, 2011a). 

Although MON 87712 soybean yielded 7.3% more that its comparator variety, this yield was still 

within the range of other high yield conventional soybeans; therefore, as determined in Section 4, 

Environmental Consequences, the potential impacts under the Preferred Alternative for all the 

resource areas analyzed would be the same as those described for the No Action Alternative. 

Agricultural Production of Soybean

Neither the No Action nor the Preferred Alternative are expected to directly cause a measurable 

change in agricultural acreage or area devoted to conventional or GE soybean cultivation or 

soybean grown for seed in the U.S. (see Subsections 4.2.1, Acreage and Area of Soybean 

Production, and 4.2.3, Soybean Seed Production). Total U.S. cropland has remained relatively 

steady since the mid-20th century, and growth in soybean acreage has been in place of other 

crops on existing cropland (USDA-ERS, 2011e). The majority of soybean grown in the U.S. is 

already GE and herbicide resistant (USDA-ERS, 2012e). Long-term projections show planted 

soybean acreage would hold steady at 76 million acres from 2013/2014 to 2021/2022 (USDAOCE, 2012), about the same as the 77.2 million acres planted to soybean in 2012 (USDA-NASS, 

2012h). It is expected MON 87712 soybean would replace other similar GE cultivars without 

expanding the acreage or area of soybean production. MON 87712 is agronomically and 

compositionally similar to other commercially available soybean cultivars (including other high 

yield soybean varieties), is subject to the same variables that influence yield as other varieties, 

and would continue to have yield variability from year to year similar to other cultivars. There 

are no anticipated changes to the availability of GE and non-GE soybean varieties on the market 

under either alternative. The Preferred Alternative, therefore, would have no impacts to acreage 

or area of soybean production and soybean grown for seed different than the No Action 

Alternative.

Based upon recent trends, adding GE varieties to the market has no relationship to the ability of 

organic production systems to maintain their market share (see Subsection 4.2.4, Organic 

Soybean Production). As described above, the majority of U.S. soybean planted in 2012 was GE 

and herbicide resistant (USDA-ERS, 2012e). Since 1996, 11 GE soybean events or lines have 

been determined by APHIS to be no longer subject to the regulatory requirements of 7 CFR part 

340 or the plant pest provisions of the Plant Protection Act (USDA-APHIS, 2013). U.S. organic 

soybean production acreage grew 53% from 82,143 acres in 1997 to 126,000 acres in 2008, 

declining 24% to 96,080 acres in 2011 (USDA-ERS, 2010a; USDA-NASS, 2012a), which was

approximately 0.09% of total U.S. soybean acreage in 2011 (USDA-NASS, 2012a). Availability 

of another GE soybean that does not express a herbicide resistant trait or that is a high yield 

soybean variety, such as MON 87712 soybean under the Preferred Alternative, is not expected to 

impact the organic production of soybean more than any other GE or high yield variety. Under 

the No Action Alternative, APHIS concludes from past and present empirical evidence that no 

such impact on organic production has been demonstrated.

Under the Preferred Alternative, extending a determination of nonregulated status to MON 

87712 soybean is not expected to result in changes to current soybean cropping practices 

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including those for tillage, fertilization, irrigation, pest and disease control measures, crop 

rotation, or irrigation. Studies conducted by Monsanto demonstrate that, in terms of agronomic 

characteristics and cultivation practices, MON 87712 soybean is similar to other soybean 

varieties currently grown. However, like any other high yielding soybean or high yield 

production system utilizing conventional soybean, MON 87712 soybean does deplete more 

potassium and phosphorous in soil (Monsanto, 2011; USDA-APHIS, 2011a). Supplementing 

soybean with nutrients is not uncommon (USDA-NASS, 2007a). As discussed in Subsection 

2.1.2.4, Agronomic Inputs, in 19 states surveyed in 2006, potassium was applied to an average of 

25% of planted soybean acres and phosphate to an average of 23% of planted soybean acres 

(USDA-NASS, 2007a). Approximately 95% of the soybean-planted acreage since 1991 has 

been in some form of crop rotation (USDA-ERS, 2005). Approximately 68.6% of soybean 

acreage is rotated to corn in the United States, with the next most frequent rotating crops being 

soybean and wheat (Monsanto, 2010a). In two-year corn-soybean rotations, enough potassium 

and phosphorus amendments are commonly applied to the corn crop to sustain the soybean crop 

the following year without additional supplementation (Bender et al., 2013). By contrast, these 

nutrients are commonly applied annually in soybean-soybean rotations that predominate in the 

South (Heatherly, 2012). Soybean typically removes approximately 65 1b/ac of potash 

(potassium) and 42 1b/ac of phosphate (phosphorus) for a typical 50 bushel per acre yield, while 

corn removes approximately 50 1b/ac of potassium and 77 1b/ac of phosphorus for a typical 180 

bushels per acre yield (Fernandez, 2010), and wheat removes 17 1b/ac of phosphorous and 29 

1b/ac of potassium for an average 46 bushel per acre yield (Silva, 2011). Testing soil fertility 

and supplementing nutrients if indicated is widely recommended in soybean production to 

achieve optimal yield potential (Snyder, 2000; Specht et al., 2006; Pedersen, 2008; CAST, 

2009a; Mallarino et al., 2011; Silva, 2011). Consequently, no changes to current or foreseeable 

soybean cropping practices such as tillage, crop rotation, or agricultural inputs associated with 

the adoption of MON 87712 soybean are expected (see Subsection 4.2.2, Agronomic Practices), 

thus, no cumulative impact to the agronomic production of soybean would occur. 

Physical Environment

As discussed in Subsection 4.3, Physical Environment, a determination of nonregulated status for 

MON 87712 soybean under the Preferred Alternative would have the same potential impacts to 

water, soil, air quality, and climate change as that of other nonregulated GE and conventional 

soybean varieties presently available. Agronomic practices that have the potential to impact soil, 

water and air quality, and climate change such as tillage, agricultural inputs (fertilizers and 

pesticides), and irrigation would not change because MON 87712 soybean is agronomically and 

morphologically similar to other GE and non-GE soybean, including high yield varieties. Other 

practices that benefit these resources, such as contouring, use of cover crops to limit the time soil 

is exposed to wind and rain, crop rotation, and windbreaks would also be the same between the 

No Action and Preferred Alternatives. Because of its similarity to other commercially available 

soybean, including high yield varieties, adoption of MON 87712 soybean in place of other 

similar cultivars would not change the acreage or area of soybean production. As of 2012, 93% 

of U.S. soybean acreage was already planted with GE varieties, and replacement of one similar 

variety for another would not additively impact water, soil, air quality, or climate change. No 

difference would occur in impacts to these resources between the Preferred and No Action 

alternatives. 

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Biological Resources

The impacts of the Preferred Alternative to animal and plant communities, microorganisms, and 

biodiversity as discussed in Subsection 4.4, Biological Resources would be no different than 

those experienced under the No Action Alternative. MON 87712 soybean is both agronomically 

and compositionally similar to its comparator A3525 and other nonregulated GE and 

conventional soybean. Further, it would not require any different agronomic practices to 

cultivate, and does not represent a safety or increased weediness risk different from other 

currently available soybean varieties. 

There are no differences in the potential for gene flow and weediness between the No Action and 

Preferred alternatives. The reproductive characteristics of MON 87712 soybean are substantially 

equivalent to other GE and non-GE soybean varieties (Monsanto, 2011). The trait for increased 

yield is not expected to contribute to increased weediness without changes in a combination of 

other characteristics associated with weediness. Such changes could include expression of hard

seed and development of dormancy and of seed shattering, among other traits. Given the selfpollinating nature of soybean and its limited ability to disperse pollen over large distances, the 

potential for cross pollination of MON 87712 soybean with other soybean cultivars is highly 

unlikely. No feral or weedy species of soybean exist in the United States (Ellstrand et al., 1999; 

OECD, 2000), and MON 87712 soybean poses no potential for either naturally occurring, pollenmediated gene flow or transgene introgression (USDA-APHIS, 2011a). Gene flow by seed 

dispersal is equally unlikely. If present as volunteer soybean, MON 87712 soybean would not be 

considered difficult to control, as soybean seeds rarely remain viable the following season and 

are easily managed with cultivation or hand weeding, or the application of herbicides. The risk 

of gene flow and weediness of MON 87712 soybean is no greater than that of other conventional 

and nonregulated GE soybean varieties.

Human Health and Animal Feed

Food and feed derived from GE soybean must be in compliance with all applicable legal and 

regulatory requirements and may undergo a voluntary consultation process with the FDA prior to 

release onto the market to identify and discuss relevant safety, nutritional, or other regulatory 

issues regarding the bioengineered food. As discussed in Subsections 4.5, Human Health and 

4.6, Animal Feed, MON 87712 soybean would have no toxic effect on human health or 

livestock. Monsanto has submitted a safety and nutritional assessment of food and feed derived 

from MON 87712 soybean to the FDA and their decision is pending. It will be posted on the 

FDA website Final Biotechnology Consultations http://www.fda.gov/Food 

/Biotechnology/Submissions/ucm225108.htm when completed. No change in food and feed 

safety would occur between the Preferred and No Action alternatives.

Socioeconomic

As discussed in Subsection 4.7, Socioeconomic Impacts, it is unlikely the availability of MON 

87712 soybean would significantly impact the domestic economic environment. Past and recent 

growth in U.S. soybean acreage has occurred at the expense of other crops and from doublecropping, not by bringing new lands into production (USDA-ERS, 2011f). Overall total U.S. 

cropland has remained relatively stable since the mid-20th century (USDA-ERS, 2011e) . MON 

87712 soybean is expected to replace other GE soybean varieties on existing cropland since 93% 

of U.S. soybean acreage is already planted with GE soybean varieties (USDA-ERS, 2012e), and 

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combined trials have demonstrated it is phenotypically and agronomically similar to other 

soybean varieties, including high yielding cultivars. Conventional high-yield soybean varieties 

currently available from several seed companies include Albert Lea Seeds’ Sheyenne and Viking 

lines; several D.F. Seeds’ varieties; and eMerge Genetics’ 348.TCS, e3782s, e45120s, and e5110 

varieties) (Advantage Seeds, 2005; D.F. Seeds, 2011; Albert Lea Seeds, 2012; eMerge, 2012). 

Selective breeding of conventional soybean varieties also is accomplished through State 

University Extension Services such as Ohio State University, Kansas State University, North 

Carolina State University, University of Arkansas, and University of Missouri (Pierzynski, 2009; 

North Carolina Soybean Producers Association, 2010; Shannon et al., 2010; The Ohio State 

University, No Date; University of Arkansas, No Date). Currently available high yielding 

soybean cultivars with herbicide or non GE pest resistance or the combination of traits include 

Genuity Roundup Ready 2 Yield® (Monsanto), Liberty Link® (Bayer), and T Series® (Pioneer), 

to name a few. Although field tests conducted by Monsanto found MON 87712 soybean had a 

7.3% higher yield than its comparator A3525 cultivar (Monsanto, 2011), its productivity is well 

within the range of other commercially available conventionally bred high yield varieties. For 

example, the world record for soybean yield was achieved in Missouri in 2010 at 160.6 bushels 

per irrigated acre and 98.9 bushels per acre for non-irrigated soybean using a conventionally bred 

soybean cultivar with transgenic herbicide- and pest-resistant traits (Alsager, 2010). Breeding 

the MON-87712 soybean trait into conventional soybean lines may increase soybean production 

yields for some varieties, but other similar conventional and GE high-producing conventional 

varieties are already commercially available; no significant cumulative impact to the domestic 

economic environment is expected.

Historically, soybean yields have been increasing for decades, in more recent times as a result of 

conventionally bred high yielding cultivars with GE herbicide- and non-GE pest-resistant traits, 

in addition to improved management practices (Specht et al., 2006; Pedersen, 2008). Further, 

U.S. soybean acreage is projected to remain relatively steady until 2021/2022, along with an

anticipated 8% per acre yield gain. Despite potential increased production, elevator price for

soybean per bushel is not expected to appreciably change, remaining between $10.30 and $11.35 

per bushel, while annual production net value is expected to increase (USDA-OCE, 2012). 

Soybean supply is a function of the amount of acreage planted to soybean and yield. While 

domestic soybean yield has recently increased primarily without increasing production acreage, 

demand for soybean products has also increased, mitigating any downward pressure on farm 

soybean prices from potentially increased supply (NRC, 2010). 

Nonregulated MON 87712 soybean is not expected to adversely impact the current trends 

affecting the seed, feed or food trade and may have a negligible impact through increased yields. 

Apart from its increased yield potential, MON 87712 soybean is essentially indistinguishable 

from other soybean cultivars in terms of agronomic, morphologic, and compositional 

characteristics (Monsanto, 2011). As discussed in Subsection 4.7.2, Trade Economic 

Environment, increased farm productivity from adoption of MON 87712 soybean may increase 

U.S competitiveness in the global economy, although many other factors affect worldwide prices 

for soybean, including energy costs, the value of the U.S. dollar, government policies, 

population, per capita income, global market conditions, and trends and practices in market 

trading and speculation (Trostle, 2008b; Trostle, 2008a; Irwin and Good, 2009). How any value 

derived from MON 87712 soybean is distributed between consumers in the form of reduced 

prices and growers as increased profits would be subject to these factors. Based upon the above 

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information, any impact to soybean market prices from the potential increase to yield from the 

production of MON 87712 soybean would be negligible.

Because yield is highly variable year to year and from field to field, the yield benefits of MON 

87712 soybean may be masked and not be as readily apparent as, for example, an herbicideresistant soybean; this would likely slow its adoption, further alleviating potentially significant 

impacts to the domestic socioeconomic environment. MON 87712 soybean would also compete 

with other high yielding soybeans conventionally bred with GE herbicide- and non-GE pestresistant traits, and conventional, and organic soybean varieties. Maximum market potential has 

been estimated at 50-60% (Monsanto, 2011).

Additionally, since MON 87712 soybean is agronomically and compositionally similar to other 

commercially available soybean, there would be no major changes to agronomic inputs or 

practices from approving the nonregulated status of MON 87712 soybean. Consequently, no

impacts to on-farm costs for soybean producers or the domestic economic environment are 

foreseen, including none to the organic soybean market. Like any other high yielding soybean 

cultivar or soybean grown in high yield production systems, MON 87712 soybean has been 

shown to deplete potassium and phosphorous in soil to a greater extent than other varieties. But 

as discussed above, supplementation of these nutrients in soybean production is not uncommon, 

and soil fertility testing and supplementation as indicated by tests and known crop soil nutrient 

removal rates is widely recommended in soybean production to achieve yield potential (Snyder, 

2000; Specht et al., 2006; Pedersen, 2008; CAST, 2009a; Mallarino et al., 2011; Silva, 2011). 

Advances in soybean yield have been attributed to development of conventionally bred higher 

yield varieties that also have GE herbicide and pest resistance. Empirical evidence shows that 

yield is also a consequence of good management practices, including early efforts to manage 

soybean cyst nematodes, optimizing planting time, recognizing optimal row spacing, providing 

sound weed management, scouting for pests, and ensuring appropriate soil fertility (Pedersen, 

2008). 

It is expected adoption of MON 87712 soybean would not impact the cost of U.S. soybean 

production any differently than those following the release of other GE soybean seed in the past. 

GE seed is generally more expensive than conventional seed; and producers using MON 87712

soybean would likely be charged a technology fee for this trait, as well as accompanying traits 

and are all part of the seed purchase price (NRC, 2010). APHIS has no insight into rationales for

the establishment of technology fees, but assumes that the fee for MON 87712 soybean would be 

consistent with the fee charges for other GE crops. Growers would make an independent 

assessment as to whether the benefits of MON 87712 soybean would offset higher seed cost. 

USDA projections from 2013/2014 to 2021/2022 anticipate an approximate 3% rise in seed and 

residual costs (USDA-OCE, 2012) .

The availability of MON 87712 soybean as another option for U.S. farmers to achieve increased 

productivity is not expected to influence growers’ decision to pursue organic soybean 

production. As discussed in Subsection 2.1.4, Organic Soybean Production, only a small portion 

of the U.S. soybean market is organic. Between 2000 and 2005 acreage for organic grain such as 

soybean and corn declined (USDA-ERS, 2009b), attributed to financial, managerial, transitional, 

marketing, and several other risk factors (Wolf, 2006; Yeager, 2006; House Hearing -110 

Congress, 2007). As discussed above in cumulative impacts to organic soybean production, 

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adding GE varieties to the domestic market is not related to the ability of organic production 

systems to maintain their market share. A determination of nonregulated status of MON 87712

soybean would not impact the organic soybean market any differently than did previously 

released GE soybean varieties.

Additionally, it is anticipated that an additional GE soybean variety potentially increasing U.S. 

farm productivity without altering soybean’s nutritional value, potential allergenicity, or toxicity 

would not change U.S. consumer attitudes towards GE crops. Overall, impacts of the Preferred 

Alternative on the domestic economic environment would therefore be no different than 

experienced under the No Action Alternative.

Under the No Action Alternative, if the request to determine MON 87712 soybean nonregulated 

were not approved, it would not be available to other countries or to the the United States buyers. 

This consequence would not likely impact U.S. trade as it has no value-added benefit to 

purchasers. On the other hand if nonregulated MON 87712 soybean gains approval in other 

countries, it would still be unlikely that this action would impact the U.S. economic trade 

environment. Other countries are increasing their production of GE herbicide-resistant soybean, 

and an exceptionally high yield variety may make production costs decline, and thus offer 

benefits to growers who participate in U.S. international soybean trade. However, there is no 

assurance that yields from this trait will be markedly larger than that from other varieties with 

increased yield traits. As of publication of this EA, Monsanto is in the process of submitting 

applications to other major soybean producing countries for import clearance and production 

approval of MON 87712 soybean. 

Under the Preferred Alternative, it is possible MON 87712 soybean would not be approved for 

import into other countries. Because the United States and other countries already have access to 

other high yield soybean cultivars, and MON 87712 soybean presents another option of high 

yield soybean similar to cultivars already in the marketplace, its availability only to U.S. 

producers would not likely significantly impact the economic trade environment. In 2011/2012, 

42% of domestically produced U.S. soybean was dedicated to the export market (USDA-ERS, 

2012f). If MON 87712 soybean was not approved for import by other countries but would be 

approved as nonregulated in the United States, it would not likely affect the supply of U.S. 

soybean eligible for import to other countries. Likewise, if it were approved both in the United 

States and for import by other countries, based on its similarity to other high yield soybean 

cultivars and the likelihood it would replace other such cultivars without increasing the acreage 

or area of soybean production, MON 87712 soybean would still be unlikely to affect the supply 

of U.S. soybean available for export.

In summary, the potential cumulative effects regarding past and present actions combined with 

the Preferred Alternative have been analyzed, and no changes from the current baseline under the 

No Action Alternative would occur. 

5.2.2 Reasonably Foreseeable Actions

In the event of a nonregulated determination, MON 87712 soybean could be combined (stacked) 

with non-GE and GE soybean varieties using traditional breeding techniques. While stacking of 

nonregulated GE crop varieties using traditional breeding techniques is common practice, 

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stacked varieties of GE soybeans have only recently been developed (i.e., stacked MON 87701 

insect-resistant and MON 89788 glyphosate-resistant variety (Intacta® Roundup Ready® 2 Pro) 

approved for use in several countries beginning in 2010 (ISAAA, 2013)). The first GE soybean 

(Monsanto GTS 4-30-2 glyphosate resistant) was determined to be no longer subject to the 

regulatory requirements of 7 CFR part 340 or the plant pest provisions of the Plant Protection 

Act in 1994 and was commercially available in 1996 (see APHIS Petition File 93-258-01p at 

http://www.aphis.usda.gov/biotechnology/petitions_table_pending.shtml). As of 2012, 93% of 

the soybean planted in the United States was GE, all of which was herbicide resistant (USDAERS, 2012e). 

MON 87712 soybean would be a GE improved yield soybean cultivar that could be stacked like 

other non-GE improved yield varieties. Potential future stacking of MON 87712 soybean might 

include development of hybrids using other currently available nonregulated soybean varieties 

expressing tolerance to herbicides, varieties expressing resistance to select insect pests, or 

varieties with improved or modified fatty acid profiles. APHIS regulations under 7 CFR part 

340 do not provide for Agency oversight of stacked varieties combining GE varieties with 

previously approved nonregulated status, unless it can be positively shown that such stacked 

varieties are likely to pose a plant pest risk. Whether MON 87712 soybean would be stacked 

with any particular nonregulated GE variety is unknown, as company plans and market demands 

play a significant role in those business decisions. In addition, the adoption level of MON 87712

soybean would depend on the extent producers value the traits offered by stacked versions of 

MON 87712 soybean over other available soybean varieties. 

Agricultural Production of Soybean

The potential future development and cultivation of MON 87712 soybean increased yield 

soybean stacked with other GE traits is not likely to change the area or acreage of soybean 

production. The future expansion of soybean production will likely be from methods that 

increase yield rather than increased area of production (OECD-FAO, 2008). In addition, U.S. 

soybean production acreage projections to 2021/2022 predict it would remain relatively stable at 

approximately 76 million acres, close to recent levels (USDA-OCE, 2012). 

As discussed in Section 4.2, Agricultural Production of Soybean, MON 87712 soybean is 

essentially the same as other commercial soybean varieties in terms of agronomic characteristics 

and cultivation practices (Monsanto, 2011; USDA-APHIS, 2011a). As such, it is not expected 

that stacking MON 87712 soybean with other nonregulated GE varieties would change the 

agronomic practices associated with those GE soybean traits such as herbicide resistance. 

Similarly, the majority of U.S. soybean acres are planted with GE varieties while acreage planted 

with organic soybean has remained small, fluctuating between 96,080 and 126,000 acres 

between 2005 and 2011 (see Subsection 4.2.4, Organic Soybean Production). The adoption of 

MON 87712 soybean stacked with other GE varieties may replace other GE varieties, but would 

not be expected to change production of organic soybean. 

Like any other high yielding soybean cultivar or soybean grown in high yield production 

systems, MON 87712 soybean has been shown to deplete potassium and phosphorous in soil 

more than other varieties. But as discussed in Subsection 5.2.1.1, Agricultural Production, 

supplementation of these nutrients in soybean production is not uncommon (USDA-NASS, 

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2007a), and soil fertility testing and supplementation as indicated by tests and known crop soil 

nutrient removal rates is widely recommended in soybean production to achieve yield potential 

(Snyder, 2000; Specht et al., 2006; Pedersen, 2008; CAST, 2009a; Mallarino et al., 2011; Silva, 

2011). Upon adoption it is expected MON 87712 soybean would be grown in rotation with other 

crops such as corn, soybean-soybean in two-year rotations or double-cropping, and with wheat, 

and other crops depending upon area of the United States (Monsanto, 2010a). To gain economic 

efficiency, fertilization of a preceding corn crop is usually supplemented at a level that would 

support the following soybean crop, but recent research has shown higher yielding corn varieties 

may remove more phosphorous than is applied on average, and soil fertility testing prior to 

soybean planting is recommended (Bender et al., 2013). In the south where soybean to soybean 

rotation is more common, soil fertilizer is applied annually (Heatherly, 2012). For doublecropping of soybeans after wheat or the corn-soybean-wheat and corn-soybean-wheat doublecrop 

soybean, it is recommended phosphorous be supplemented before corn in the two rotations and 

again before wheat in the four crop rotation (PPI, 2003). In conservation tillage soybean 

production, Fernandez and White (2012)note an increasing trend to employ strip tillage with 

deep subsurface fertilizer delivery; soil fertility is improved while the benefits of undisturbed 

soil as in no-till are preserved (Fernandez and White, 2012). Because recent research has found 

agricultural soil fertility in the United States and Canada is declining, regular testing and use of 

improved techniques to attain adequate supplementation is recommended and being 

accomplished by growers (Fixen et al., 2010). On this basis, the cultivation of MON 87712

soybean would not require any change to fertilization practices in soybean production. 

Physical Environment

The potential effects from the cultivation of other stacked GE crops (including soybean) to use of 

pesticides have been evaluated in other EAs by APHIS. For example, glyphosate, glufosinate 

and other herbicide resistance and resistance to insects have been thoroughly evaluated in other 

APHIS EAs since the 1994 introduction of a glyphosate-resistant soybean, and since the first 

insect-resistant crop (potato) in 1994 (see list of pending and previously approved GE crops at 

http://www.aphis.usda.gov/biotechnology/petitions_table_pending.shtml). The total amount of 

the mix of pesticides that may be applied to varieties of MON 87712 soybean stacked with 

herbicide-resistant varieties would be limited by the total application approved by EPA for a 

registered or exempted herbicide and would be no different than the application rate already 

approved for use on currently nonregulated varieties of stacked herbicide-resistant soybean 

cultivars. In addition, MON 87712 soybean engineered for higher yield may also be stacked 

with dicamba-resistant MON 87708 soybean pending determination of nonregulated status 

(Monsanto, pers. comm. October 2012); however, as stated above, the authorized amount or 

application rate of dicamba approved for use on MON 87708 soybean would not likely differ in a 

stacked product containing the MON 87712 soybean enhanced yield trait. When used consistent 

with the label, the potential risks from the application of pesticides to stacked MON 87712

soybean varieties to the physical environment could increase. However, substantial impact

would not occur because EPA will have determined whether environmental effects of application

of an approved herbicide would or would not be likely to cause unreasonable harmful impacts on

the environment. In addition, there would be no changes to currently authorized pesticide 

tolerance levels for stacked varieties of MON 87712 soybean. 

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Biological Resources

As discussed under Physical Resources, the potential impacts from the cultivation of other GE 

soybean traits with which MON 87712 soybean could be stacked have been thoroughly 

evaluated by APHIS. In addition, the amount of herbicides that may be applied to varieties of 

MON 87712 soybean stacked with herbicide-resistant soybean would be limited to the total 

application approved by EPA for a registered or exempted herbicide. Potential risks to 

biological resources from the application of pesticides to stacked MON 87712 soybean varieties 

would be no different than that presented by GE herbicide-resistant soybeans without the MON 

87712 high yield trait when used in accordance with label instructions. 

Under a determination of nonregulated status, MON 87712 soybean could potentially be stacked 

with another herbicide resistant trait. Currently, Monsanto is requesting determination of 

nonregulated status for a dicamba resistant soybean, and this could be potentially stacked with 

MON 87712 soybean. Other herbicide stacked traits such as glufosinate resistance, are 

conceivable, although no plans have been described by Monsanto for that option. Stacking could 

be done in future insect-resistant varieties although that is not the intention of U.S. developers 

who are presently planning for only the international use of some of these traits, such as that 

expressed in lepidopteran-resistant DAS-81419-2 soybean. Any insect-resistant trait that may be 

developed in the future and stacked with MON 87712 soybean using standard genetic crosses 

would be subject to EPA approval. APHIS and FDA would have assessed the traits previously, 

so that developers would be free to construct new varieties from them. No adverse cumulative 

effects of stacking the deregulated traits on biological resources are likely. The adoption of 

stacked MON 87712 soybean would be contingent on the extent growers see value in the traits 

expressed in comparison to other commercially available soybean cultivars with similar traits.

Human Health and Animal Feed

The potential effects to Human Health and Animal Feed from the cultivation of GE herbicideresistant soybean varieties with a nonregulated status with which MON 87712 soybean may be 

stacked have already been evaluated in previous EAs. Additionally, future GE soybean varieties 

would be subject to the same process prior to a determination of nonregulated status. As 

discussed in Section 4.5, Human Health and Section 4.6, Animal Feed, when evaluating the 

potential consequences that may result from a determination of nonregulated status of a GE crop, 

USDA-APHIS considers the EPA’s registration of pesticides. The environmental risks of 

pesticide use are assessed by EPA in the pesticide registration process and are regularly 

reevaluated by EPA for each pesticide to maintain its registered status under FIFRA. As part of 

the registration process, the EPA considers human health effects from the use of pesticides and 

must determine that the pesticide will not cause unreasonable adverse effects on human health. 

Worker safety is also taken into consideration by EPA in the pesticide registration process and 

reregistration process. The application rate of various herbicides that may be applied to MON 

87712 soybean or subsequent varieties derived from it would be limited to those rates approved 

by EPA by single application and yearly total. When used consistent with the EPA label, 

pesticides present minimal risk to human health and worker safety. Pesticide residue tolerances 

for pesticides are listed in 40 CFR § 180 and include acceptable concentrations for soybean 

forage, hay, hulls, and seed (US-EPA, 2010a). APHIS has determined that there are no past, 

present, or reasonably foreseeable actions that would aggregate with effects of the proposed 

action that would have an adverse impact on human health or animal feed.

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In the near term, any additional GE traits that may be stacked with MON 87712 soybean have 

already been assessed by APHIS and determined nonregulated. As such, the production and use 

of products from these cultivars as food or feed have been assessed as not likely to have a 

significant negative impact on human health or animal feed analyzed in this EA. As discussed 

above in Subsection 5.2.1, Past and Present Actions and the Preferred Alternative, food and feed 

derived from GE soybean must be in compliance with all applicable legal and regulatory 

requirements and may undergo a voluntary consultation process with the FDA prior to release 

onto the market. All GE soybean traits with which MON 87712 soybean would be stacked have 

undergone, or are expected to undergo (e.g., MON 87708 dicamba resistant soybean), FDA’s 

premarket consultation process to ensure their safety as food and feed products.

Socioeconomic

MON 87712 soybean could be stacked with other commercially available soybean traits that 

could have domestic economic impacts, such as affecting production costs, consumer prices, and 

growers’ profits, similar to other GE soybean cultivars already on the market. As discussed 

previously, soybean varieties with single and multiple herbicide resistance are widely available, 

representing almost 93% of planted U.S. soybean acreage in 2012. The United States’ adoption 

of herbicide-resistant-only soybean has remained relatively steady from the 2010 through the 

2012 planting seasons (Table 2). The development of GE insect-resistant soybean is relatively 

recent, with DAS- 81419-2 soybean petitioned for a nonregulated status in 2012 (USDA-APHIS, 

2013) although this trait is not likely to be deployed in the US. High yielding soybean cultivars 

of elite germplasm have been and will continue to be conventionally bred with nonregulated GE 

herbicide- and non-GE pest-resistant traits, such as Genuity Roundup Ready 2 Yield® 

(Monsanto), possibly dicamba resistant soybean if determined to be nonregulated, and soybean 

cyst nematode and fungal pathogen resistance to name a few. Similarly, other soybean varieties 

that have been genetically engineered to produce high oleic acid (Event 305423), have a 

modified fatty acid profile (MON 87715), and produce stearidonic acid (MON 87769) have all 

received nonregulated status in the last three years. 

Past and recent growth in U.S. soybean acreage has occurred primarily at the expense of other 

crops and double-cropping, not by bringing new lands into production (USDA-ERS, 2011f). 

(USDA-ERS, 2011f). Overall total U.S. cropland has remained relatively stable since the mid20th century (USDA-ERS, 2011e). U.S. soybean acreage is projected to remain relatively steady 

until 2021/2022, but with an anticipated 8% per acre yield gain. Field price of soybean per 

bushel is expected to remain unchanged, remaining between $10.30 and $11.35 per bushel, while 

net value of annual production is expected to increase (USDA-OCE, 2012). About 93% of U.S. 

soybean acreage is already planted with GE soybean varieties (USDA-ERS, 2012e) and 

combined trials have demonstrated MON 87712 soybean is phenotypically and agronomically 

similar to other soybean varieties (Monsanto, 2011), including high yielding cultivars. MON 

87712, stacked with herbicide resistance traits and defensive traits, is expected to replace other 

GE soybean varieties on existing cropland. Although field tests conducted by Monsanto found 

MON 87712 soybean had a 7.3% higher yield than its comparator A3525 cultivar (Monsanto, 

2011), its productivity is well within the range of other commercially available conventionally 

bred high yield varieties. Historically, soybean yields have been increasing for decades, in more 

recent times as a result of conventionally breeding high yielding cultivars with GE herbicide- and 

pest-resistant (nematode) traits, in addition to improved management practices (Specht et al., 

2006; Pedersen, 2008). 

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Agronomic practices, including inputs for production of MON 87712 soybean stacked with 

herbicide or pest resistance, or other GE modified traits, would not be substantially different than 

those needed to cultivate other commercially available soybean with the same resistances or 

traits. Some of these commercially available traits include those with similar yields that deplete 

more phosphorous and potassium in soil than other varieties. Therefore, producer costs are not 

expected to be any different for the cultivation of MON 87712 soybean if it were stacked with 

other readily available GE and non-GE traits. As discussed in Subsection 5.2.2.1, Agricultural 

Production of Soybean, supplementation of these nutrients in soybean production is not 

uncommon (USDA-NASS, 2007a), and soil fertility testing and supplementation as indicated by 

tests and known crop soil nutrient removal rates is widely recommended in soybean production 

to achieve yield potential (Snyder, 2000; Specht et al., 2006; Pedersen, 2008; CAST, 2009a; 

Mallarino et al., 2011; Silva, 2011). Upon adoption it is expected MON 87712 soybean would 

be grown in rotation with other crops. Approximately 68% of U.S. soybean acreage is in twoyear rotation with corn, followed in frequency of acreage by soybean and wheat (Monsanto, 

2010a). To gain economic efficiency, fertilization of a preceding corn crop is usually 

supplemented at a level that would support the following soybean crop, but recent research has 

shown higher yielding transgenic herbicide- and insect-resistant corn varieties may remove more 

phosphorous than is applied on average, and soil fertility testing prior to planting of any soybean 

variety is recommended (Bender et al., 2013). In the south where soybean to soybean rotation is 

more common, soil fertilizer is applied annually (Heatherly, 2012). For double-cropping of 

soybeans after wheat or the corn-soybean-wheat and corn-soybean-wheat-doublecrop soybean 

rotation, it is recommended phosphorous be supplemented before corn in the two rotations and 

again before wheat in the four crop rotation (PPI, 2003). In conservation tillage soybean 

production, some authors note an increasing trend that employs strip tillage with deep subsurface 

fertilizer banding to support improved soil fertility; the process preserves the benefits of low soil

disturbance between rows just as in no-till (Fernandez and White, 2012). Because recent 

research has found agricultural soil fertility in the United States and Canada is declining, regular 

testing and adequate supplementation using improved types of tillage and fertilization is 

recommended (Fixen et al., 2010). No cumulative impact on the agricultural practices for the 

production of soybean would therefore be expected with the approval of MON 87712 soybean as 

nonregulated. 

MON 87712 soybean would likely be bred with nonregulated glyphosate-resistant traits. It has 

been reported that glyphosate appears to interact with manganese in soil by forming insoluble, 

stable complexes that either immobilize this element, reducing plant uptake, or preventing 

reduction in the plant, making it unavailable (Eker et al., 2006; Neumann et al., 2006; Ozturk et 

al., 2008; Cakmak et al., 2009; Huber, 2010). Huber (2010) and Cakmak (2009) also reported 

that glyphosate is a broad-spectrum chelate for several other nutrients (e.g., iron, calcium, 

magnesium, copper, iron, nickel, and zinc); however, these assertions are not without debate. 

Hartzler (2010a) agrees that glyphosate could immobilize essential elements temporarily, but 

offers that it does not specifically target manganese or any other particular element, but instead 

targets those cations that are most prevalent in the soil. Hartzler (2010a) also reports that areas 

in which glyphosate interactions with manganese nutrition are reported are also areas with 

known soil manganese deficiencies. Camberato (2010) points out that manganese deficiency is 

not a new phenomenon and is also associated with high pH, low moisture, or high levels of 

organic matter; furthermore, manganese deficiency is easily recognizable and can usually be 

resolved through foliar application(s) of manganese fertilizers. Stacking the MON 87712

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increased yield trait with the glyphosate-resistant trait in soybean would therefore not likely 

cumulatively impact practices governing the application of manganese supplements to this crop.

For the above reasons, the future cultivation of MON 87712 soybean itself or stacked with other 

GE traits would not require any change to agronomic practices in soybean production or changes 

to on-farm costs for soybean producers. Neither is there any likely impact to the U.S. domestic 

soybean market. MON 87712 soybean may also be stacked with other nonregulated GE traits; 

however, predicting potential trait combinations would be purely speculative. Overall, it is 

unlikely that any cumulative impact to the domestic economic environment would result from a 

stacked product consisting of MON 87712 soybean and other readily-available GE traits.

As discussed in Subsection 4.7.2, Trade Economic Environment, the U.S. share of soybean 

exports is expected to decline from the current amount of 30% of world exports to approximately 

25% over the next decade (USDA-OCE, 2012). While MON 87712 soybean had a statistically 

higher yield than the conventional control A3525, it was within yields documented for other 

high-yield conventional and GE soybean varieties, most likely because MON 87712 soybean is 

subject to the same variables that impact yield in other varieties. Conventional non-GE highyield soybean varieties are currently available from several seed companies (e.g., Albert Lea 

Seeds’ Sheyenne and Viking lines; several D.F. Seeds’ varieties; and eMerge Genetics’ 

348.TCS, e3782s, e45120s, and e5110 varieties). Breeding of non-GE conventional soybean 

varieties with high yield may also be accomplished by State University Extension Services such 

as Ohio State University, Kansas State University, North Carolina State University, University of 

Arkansas, and University of Missouri (Pierzynski, 2009; North Carolina Soybean Producers 

Association, 2010; Shannon et al., 2010; The Ohio State University, No Date; University of 

Arkansas, No Date). As discussed above, nonregulated GE herbicide- and non-GE pest-resistant 

soybean cultivars are being conventionally bred with elite soybean germplasm to produce high 

yields, and soybean varieties that combine multiple herbicide resistance with pest resistance are 

in development (USDA-APHIS, 2013). As discussed in Subsection 4.7.2, Trade Economic 

Environment, increased farm productivity from adoption of MON 87712 soybean in addition to 

other high yielding soybean cultivars may increase U.S competitiveness in the global economy, 

and the summation of many other factors affect worldwide prices for soybean. These factors 

include energy costs, the value of the U.S. dollar, government policies, population, per capita 

income, global market conditions, and trends and practices in market trading and speculation 

(Trostle, 2008b; Trostle, 2008a; Irwin and Good, 2009). Global export markets respond to many 

factors and are unlikely to experience a meaningful change with the commercial availability of a 

GE improved yield cultivar such as MON 87712 soybean alone, or stacked with other currently 

available traits. Therefore, no cumulative impact to the trade economic environment is expected 

following determination of MON 87712 soybean as nonregulated. 

In summary, the potential for impacts that may result from nonregulated status of MON 87712

soybean on the resource areas analyzed were considered within this EA. This potential was 

evaluated for both MON 87712 cultivated alone and stacked with other previously nonregulated 

GE or non GE soybean traits. Implementation of the Preferred Alternative would not result in 

any changes to the resources analyzed compared to the No Action Alternative, and no negative 

cumulative impacts from foreseeable actions of stacking MON 87712 soybean with other 

soybean traits would occur. No cumulative effects are expected to the resource areas analyzed 

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from determining MON 87712 soybean nonregulated, when taken into consideration with related 

activities, including past, present, and reasonably foreseeable future actions. 

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6 THREATENED AND ENDANGERED SPECIES

Congress passed the Endangered Species Act (ESA) of 1973, as amended, to prevent extinctions 

facing many species of fish, wildlife, and plants. The purpose of the ESA is to conserve 

endangered and threatened species and the ecosystems on which they depend as key components 

of America’s heritage. To implement the ESA, the United States Fish and Wildlife Service 

(USFWS) works in cooperation with the National Marine Fisheries Service (NMFS); other 

Federal, State, and local agencies; Tribes; non-governmental organizations; and private citizens. 

Before a plant or animal species can receive the protection provided by the ESA, it must first be 

added to the Federal list of threatened and endangered wildlife and plants. A species is added to 

the list when it is determined by the USFWS/NMFS to be endangered or threatened because of 

any of the following factors:

• The present or threatened destruction, modification, or curtailment of its habitat or range;

• Overutilization for commercial, recreational, scientific, or educational purposes;

• Disease or predation;

• The inadequacy of existing regulatory mechanisms; and

• The natural or manmade factors affecting its survival.

Once an animal or plant is added to the list, in accordance with the ESA, protective measures 

apply to the species and its habitat. These measures include protection from adverse effects of 

Federal activities.

Section 7 (a)(2) of the ESA requires that Federal agencies, in consultation with USFWS and/or 

the NMFS, ensure that any action they authorize, fund, or carry out is not likely to jeopardize the 

continued existence of a listed species or result in the destruction or adverse modification of 

designated critical habitat. It is the responsibility of the Federal agency taking the action to assess 

the effects of their action and to consult with the USFWS and NMFS if it is determined that the 

action “may affect” listed species or critical habitat. To facilitate APHIS’ ESA consultation 

process, APHIS met with the USFWS from 1999 to 2003 to discuss factors relevant to APHIS’s 

regulatory authority and effects analysis for petitions for nonregulated status, and developed a 

process for conducting an effects determination consistent with the PPA of 2000 (Title IV of 

Public Law 106-224). This process is described in a Decision Tree document, which is available 

from APHIS. APHIS uses this process to help fulfill its obligations and responsibilities under 

Section 7 of the ESA for biotechnology regulatory actions.

APHIS’ regulatory authority over GE organisms under the PPA is limited to those GE organisms 

for which it has reason to believe might be a plant pest or those for which APHIS does not have 

sufficient information to determine that the GE organism is unlikely to pose a plant pest risk (7 

CFR § 340.1). After completing a plant pest risk analysis, if APHIS determines that MON 87712

soybean does not pose a plant pest risk, then MON 87712 soybean would no longer be subject to 

the plant pest provisions of the PPA or to the regulatory requirements of 7 CFR Part 340, and 

therefore, APHIS must reach a determination that the article is no longer regulated. As part of its 

EA analysis, APHIS is analyzing the potential effects of MON 87712 soybean on the 

environment including any potential effects to TES and critical habitat. As part of this process, 

APHIS thoroughly reviews the GE product information and data related to the organism 

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(generally a plant species, but may also be other genetically engineered organisms). For each 

transgene/transgenic plant, APHIS considers the following information, data, and questions:

• A review of the biology and taxonomy of the crop plant and its sexually compatible 

relatives;

• Characterization of each transgene with respect to its structure and function and the 

nature of the organism from which it was obtained;

• A determination of where the new transgene and its products (if any) are produced in the 

plant and their quantity;

• A review of the agronomic performance of the plant, including disease and pest 

susceptibilities, weediness potential, and agronomic and environmental impacts;

• Determination of the concentrations of known plant toxicants (if any are known in the 

plant);

• Analysis to determine if the transgenic plant is sexually compatible with any threatened 

and endangered species (TES) of plants or a host of any TES; and

• Any other information that may inform the potential for an organism to pose a plant pest 

risk.

In following this review process, APHIS, as described below, has evaluated the potential effects 

that a determination of nonregulated status of MON 87712 soybean may have, if any, on 

Federally-listed TES and species proposed for listing, as well as designated critical habitat and 

habitat proposed for designation. Based upon the scope of the EA and production areas identified 

in the Affected Environment section of the EA, APHIS obtained and reviewed the USFWS list of 

TES (listed and proposed) for each state where soybean is commercially produced. The list was 

generated from the USFWS Environmental Conservation Online System (ECOS; at 

http://ecos.fws.gov/tess_public/). Prior to this review, APHIS considered the potential for MON 

87712 soybean to extend the range of soybean production and also the potential to extend 

agricultural production into new natural areas. Monsanto’s studies demonstrate that agronomic 

characteristics and cultivation practices required for MON 87712 soybean are essentially 

indistinguishable from practices used to grow other soybean varieties (Monsanto, 2011; USDAAPHIS, 2011a). Although MON 87712 soybean may be expected to replace other varieties of 

soybean currently cultivated, APHIS does not expect the cultivation of MON 87712 soybean to 

result in new soybean acres planted in areas that are not already devoted to agriculture. 

Accordingly, the issues discussed herein focus on the potential environmental consequences of 

the determination of nonregulated status of MON 87712 soybean on TES species in the areas 

where soybean are currently grown.

APHIS focused its TES review on the implications of exposure to the BBX32 protein in MON 

87712 soybean and the interaction between TES and MON 87712 soybean, including the 

potential for sexual compatibility and the ability to serve as a host for a TES.

6.1 Potential Effects of MON 87712 Soybean on TES

6.1.1 Threatened and Endangered Plant Species

The agronomic and morphologic characteristics data provided by Monsanto were used in the 

APHIS analysis of the weediness potential for MON 87712 soybean, and further evaluated for 

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the potential to impact TES. Agronomic studies conducted by Monsanto tested the hypothesis 

that the weediness potential of MON 87712 soybean is unchanged with respect to conventional 

soybean (Monsanto, 2011). No differences were detected between MON 87712 soybean and the 

conventional control A3525 in assessed agronomic performance characteristics (e.g., 

germination, dormancy, emergence, vegetative growth, reproductive development, seed retention 

and lodging, plant-environment interactions, plant-symbiont interactions, volunteer potential 

characteristics, and persistence outside of cultivation) other than potential for greater yield in 

MON-87712 soybean (Monsanto, 2011; USDA-APHIS, 2011a). Soybean possesses few of the 

characteristics of successful weeds (OECD, 2000). Soybean cannot survive in most geographic 

locations of the country without human intervention, and it is easily controlled if volunteers 

appear in subsequent crops (see Section 2.1.2 Agronomic Practices and 2.3.3 Gene Flow and 

Weediness discussion). The expression of the BBX32 protein providing the increased yield 

potential in MON 87712 soybean is unlikely to appreciably improve seedling establishment or 

increase weediness potential without changes in a combination of other characteristics associated 

with weediness, such as hard seed and increased lodging. APHIS has concluded the 

determination of nonregulated status of MON 87712 soybean does not present a plant pest risk, 

does not present a risk of weediness, and does not present an increased risk of gene flow when 

compared to other currently cultivated soybean varieties (USDA-APHIS, 2011a).

APHIS evaluated the potential of MON 87712 soybean to cross with a listed species. As 

previously discussed in the analysis of Plant Communities and Gene Flow and Weediness (see 

Subsections 4.4.2 and 4.4.3), APHIS has determined there is no risk to unrelated plant species 

from the cultivation of MON 87712 soybean. Soybean is highly self-pollinating and can only 

cross with other members of Glycine subgenus Soja. Wild soybean species are endemic in China, 

Korea, Japan, Taiwan and some eastern regions of Russia; in the United States there are no 

Glycine species found outside of cultivation and the potential for outcrossing is minimal (OECD, 

2000). After reviewing the list of threatened and endangered plant species in states where 

soybean is grown, APHIS determined that MON 87712 soybean would not be sexually 

compatible with any threatened or endangered plant species proposed for listing, as none of these 

listed plants are in the same genus nor are known to cross pollinate with species of the genus 

Glycine. 

Based on agronomic field data, literature surveyed on soybean weediness potential, and no 

sexual compatibility of TES with soybean, APHIS has concluded MON 87712 soybean will have 

no effect on threatened or endangered plant species.

6.1.2 Threatened and Endangered Animal Species

APHIS considered the possibility MON 87712 soybean could serve as a host plant for threatened 

or endangered animal species. A review of the species list reveals there are no members of the 

genus Glycine that serve as a host plant for any threatened or endangered animal species. 

Threatened and endangered animal species that may be exposed to the gene products in MON 

87712 soybean would be those TES that inhabit soybean fields and feed on MON 87712

soybean. To identify potential effects to animal TES, APHIS evaluated the risks to threatened 

and endangered animals from consuming MON 87712 soybean. Soybean commonly is used as a 

feed for many livestock. Additionally, wildlife may use soybean fields as a food source, 

consuming the plant or insects that live on the plants. However, animal TES generally are found 

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outside of agricultural fields. Few if any animal TES are likely to use soybean fields because 

they do not provide suitable habitat. Only whooping crane (Grus americana), sandhill crane 

(Grus canadensis pulla), piping plover (Charadrius melodus), interior least tern (Sterna 

antillarum) occasionally feed in farmed sites (USFWS, 2011a). Bird species may visit soybean 

fields during migratory periods, but would not be present during normal farming operations 

(Krapu et al., 2004; USFWS, 2011a). In a study of soybean consumption by wildlife in 

Nebraska, results indicated soybeans do not provide the high energy food source needed by 

cranes and waterfowl (USFWS, 2011a). The Delmarva fox squirrel (Sciurus niger cinereus), 

which inhabits mature forests of mixed hardwoods and pines, may be found adjacent to 

agricultural areas of the Delmarva Peninsula (USFWS, 2011b). The squirrel forages for food in 

woodlots and openings, such as farm fields, with a diet that mainly includes acorns, nuts/seeds of 

hickory, beech, walnut, and loblolly pine. They also feed on tree buds and flowers, fungi, insects, 

fruit, and mature, green pine cones in the summer and early fall (USFWS, 1999). The Louisiana 

black bear (Ursus americanus luteolus), occurring in Louisiana, Mississippi, and Texas 

(USFWS, 2013), may occasionally forage on soybean; however, other crops such as corn, 

sugarcane, and winter wheat are preferred by the species (Mississippi State University, No Date).

The BBX32 protein is expressed in MON 87712 soybean through the incorporation of the 

BBX32 gene which was derived from A. thaliana, commonly known as mouseear cress. 

Mouseear cress is a common forb found in all soybean producing states except North Dakota and 

belongs to the Brassicaceae (mustard) family that also includes common food plants such as 

broccoli, cauliflower, cabbage, and canola (USDA-NRCS, 2013c). Monsanto has presented data 

on the food, feed, and environmental safety of MON 87712 soybean, evaluating the agronomic 

and morphologic characteristics of MON 87712 soybean, including compositional analysis of 

key nutrients and antinutrients, and safety evaluations and toxicity tests, as compared to 

conventional soybean (Monsanto, 2011). Compositional elements compared included the 

proximates (ash, carbohydrates, moisture, protein and fat), fiber, amino acids, fatty acids, and 

vitamin E in seed, and the above proximates and fiber in forage. The antinutrients assessed in 

seed included raffinose, stachyose, lectin, phytic acid, trypsin inhibitors, and isoflavones 

(daidzein, genistein, and glycitein) (Monsanto, 2011). As discussed in Section 4.6.1.2, the data 

collected indicate there is no difference in the composition and nutritional quality of MON 87712

soybean compared with conventional soybean varieties, apart from the presence of the BBX32 

protein. The results presented by Monsanto show that the incorporation of the BBX32 gene and 

the accompanying expression of the BBX32 protein in MON 87712 soybean does not result in 

any biologically-meaningful differences between MON 87712 soybean and nontransgenic 

hybrids (Monsanto, 2011; USDA-APHIS, 2011a).

In addition to evaluating Monsanto’s comparisons of MON 87712 soybean with the nontransgenic parent (A3525) for potential agronomic and morphologic differences, APHIS also 

considers the FDA regulatory assessment when evaluating the potential impacts of a 

determination of nonregulated status of the new agricultural product. As discussed in Subsection 

4.4.1, Animal Communities, Monsanto has initiated a food/feed safety consultation with FDA on 

MON 87712 soybean. FDA has evaluated the submission and responded with questions on July 

18, 2012, and Monsanto responded to those on August 9, 2012. When complete, FDA will 

announce whether it has identified any possible safety or regulatory issues under the FD&C Act 

that would require further evaluation. The decision memo will be published as BNF No. 131. 

Monsanto conducted safety evaluations based on Codex Alimentarius Commission procedures to 

131
assess any potential adverse effects to humans or animals resulting from environmental releases 

and consumption of MON 87712 soybean (FAO, 2009; Monsanto, 2011). These safety studies 

included: (1) characterization of the physicochemical and functional properties of BBX32 

protein; (2) quantification of BBX32 protein levels in plant tissues; (3) comparison of the amino 

acid sequence of BBX32 protein in MON 87712 soybean to known allergens, gliadins, glutenins, 

toxins, and other biologically-active proteins known to have adverse effects on mammals; (4) 

evaluation of the digestibility of BBX32 protein in simulated gastric and intestinal fluids; (5) 

documentation of the presence of related proteins in several plant species currently consumed; 

and (6) investigation of the potential mammalian toxicity through an oral gavage assay. The 

BBX32 protein in MON 87712 soybean was determined to have no amino acid sequence similar 

to known allergens, lacked toxic potential to mammals, and was degraded rapidly and 

completely in gastric fluid (Monsanto, 2011). MON 87712 soybean does not express a pesticidal 

property, and, accordingly, is not regulated by the EPA.

Because there is no toxicity or allergenicity potential with MON 87712 soybean, there would be 

no direct or indirect toxicity or allergenicity impacts on animal TES that feed on soybean or the 

associated biological food chain of organisms. Based on Monsanto’s findings and the likely 

concurrence of APHIS with FDA’s analyses of data from Monsanto, and that consumption of 

MON 87712 soybean plant parts (seeds, leaves, stems, pollen, or roots) by animal TES would be 

unlikely, APHIS concludes it would have no effect on any listed threatened or endangered 

animal species or animal species proposed for listing.

APHIS expects MON 87712 soybean to replace some of the presently available soybean 

varieties, but APHIS does not expect that MON 87712 soybean will cause new soybean acres to 

be planted in areas that are not already devoted to agriculture. TES generally are found outside of 

agricultural fields. Combining the above information, cultivation of MON 87712 soybean and its 

progeny is expected to have no effect on TES animal species nor is it expected to adversely 

modify designated critical habitat compared to current agricultural practices. Based on this 

analysis, there is no apparent potential for significant impact on nontarget organisms from MON 

87712 soybean, including beneficial organisms and TES animal species, that would result from 

an APHIS determination of nonregulated status for the petition in whole. If APHIS chooses the 

No Action Alternative, there would also be no impact on non-target organisms, beneficial 

organisms and TES animal species.

6.1.3 Summary of Potential Effects of MON 87712 Soybean on TES

After reviewing the possible effects of the environmental release of MON 87712 soybean, 

APHIS has not identified any stressor that could affect the reproduction, numbers, or distribution 

of a listed TES or species proposed for listing. APHIS also considered the potential effect of a

determination of nonregulated status of MON 87712 soybean on designated critical habitat and

habitat proposed for designation, and could identify no differences from effects that would occur 

from the production of other soybean varieties. As discussed above, soybean possesses few of 

the characteristics of successful weeds and cannot survive in most geographic regions of the 

country without human intervention. Soybean is not sexually compatible with, nor serves as a 

host species for, any listed species or species proposed for listing under the ESA. Consumption 

of MON 87712 soybean by any listed species or species proposed for listing will not result in a 

toxic or allergic reaction. Based on these factors, APHIS has concluded that a determination of 

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nonregulated status of MON 87712 soybean, and the corresponding environmental release of this 

soybean variety, will have no effect on listed species or species proposed for listing, and would 

not affect designated habitat or habitat proposed for designation. Because of this no-effect 

determination, consultation under Section 7(a)(2) of the Act or the concurrences of the USFWS 

or NMFS are not required. The APHIS Decision Tree document is used to determine the need for 

Section 7 consultation under the ESA.

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7 CONSIDERATION OF EXECUTIVE ORDERS, STANDARDS, AND TREATIES 

RELATING TO ENVIRONMENTAL IMPACTS

7.1.1 Executive Orders with Domestic Implications

The following EOs require consideration of the potential impacts of the Federal action to various 

segments of the population.

• EO 12898 (US-NARA, 2010), "Federal Actions to Address Environmental Justice in 

Minority Populations and Low-Income Populations," requires Federal agencies to 

conduct their programs, policies, and activities that substantially affect human health or 

the environment in a manner so as not to exclude persons and populations from 

participation in or benefiting from such programs. It also enforces existing statutes to 

prevent minority and low-income communities from being subjected to 

disproportionately high and adverse human health or environmental effects. 

• EO 13045, “Protection of Children from Environmental Health Risks and Safety 

Risks,” acknowledges that children may suffer disproportionately from environmental 

health and safety risks because of their developmental stage, greater metabolic activity 

levels, and behavior patterns, as compared to adults. The EO (to the extent permitted by 

law and consistent with the agency’s mission) requires each Federal agency to identify, 

assess, and address environmental health risks and safety risks that may 

disproportionately affect children.

The No Action and Preferred Alternatives were analyzed with respect to EO 12898 and EO 

13045. Neither alternative is expected to have a disproportionate adverse effect on minorities, 

low-income populations, or children. 

Available mammalian toxicity data associated with the BBX32 protein establish the safety of 

MON 87712 soybean and its products to humans, including minorities, low-income populations, 

and children who might be exposed to them through agricultural production and/or processing. 

No additional safety precautions would need to be taken with nonregulated MON 87712

soybean. 

Based on the information submitted by the applicant and assessed by APHIS, MON 87712

soybean is agronomically, phenotypically, and biochemically comparable to conventional 

soybean except for the introduced BBX32 gene and expressed BBX32 protein. The information 

provided in the petition indicates that the protein expressed in MON 87712 soybean is not 

expected to be allergenic, toxic, or pathogenic in mammals (USDA-APHIS, 2011a). Also, 

Monsanto began the process of consultation with FDA on the BBX32 protein in the context of 

food and feeds deriving from MON 87712. Monsanto received questions from FDA on July 

18, 2012, and responded to those on August 9, 2012 and FDA has not subsequently

requested that Monsanto address further questions. When FDA’s process is complete, the 

decision memo will be published as BNF No. 131. APHIS assumes that growers will adhere 

to herbicide use precautions and restrictions. Pesticide labels include use precautions and 

restrictions intended to protect workers and their families from exposures. As discussed in 

Subsection 4.5, Human Health, it is expected that EPA-registered pesticides, fertilizers, and other 

134
chemicals that currently are used for soybean production would continue to be used by growers 

on MON 87712 soybean using application rates currently approved for other GE and non-GE 

soybean varieties and determined by the EPA to have no unreasonable adverse impacts to human 

health when used in accordance with label instructions. 

Based on these factors, a determination of nonregulated status of MON 87712 soybean is not 

expected to have a disproportionate adverse effect on minorities, low-income populations, or 

children.

The following EO addresses Federal responsibilities regarding the introduction and effects of 

invasive species:

• EO 1311 (US-NARA, 2010), “Invasive Species,” states that Federal agencies take action 

to prevent the introduction of invasive species, to provide for their control, and to 

minimize the economic, ecological, and human health impacts that invasive species 

cause. 

Soybean is not listed in the United States as a noxious weed species by the Federal government 

(USDA-NRCS, 2013b) nor is it listed as an invasive species by major invasive plant data bases. 

Cultivated soybean seed does not usually exhibit dormancy and requires specific environmental 

conditions to grow as a volunteer the following year (OECD, 2000). Any volunteers that may 

become established do not compete well with the succeeding planted crop and are easily 

managed using standard weed control practices. Field trials and laboratory tests indicate MON 

87712 soybean has no plant pathogenic properties or weediness characteristics. The agronomic, 

compositional, and reproductive characteristics of MON 87712 soybean are substantially 

equivalent to other GE and non-GE soybean varieties (Monsanto, 2011; USDA-APHIS, 2011a). 

The trait for increased yield is not expected to contribute to increased weediness without changes 

in a combination of other characteristics associated with weediness, such as hard seed and 

increased lodging, among other characteristics. Non-engineered soybean, along with GE

herbicide-resistant soybean varieties, are widely grown in the United States. Based on historical 

experience with these varieties and the data submitted by the applicant and reviewed by APHIS, 

MON 87712 soybean plants are sufficiently similar in fitness characteristics to other soybean 

varieties currently grown and are not expected to become weedy or invasive.

The following executive order requires the protection of migratory bird populations:

• EO 13186 (US-NARA, 2010), “Responsibilities of Federal Agencies to Protect 

Migratory Birds,” states that federal agencies taking actions that have, or are likely to 

have, a measurable negative effect on migratory bird populations are directed to develop 

and implement, within two years, a Memorandum of Understanding with the Fish and 

Wildlife Service that shall promote the conservation of migratory bird populations. 

Migratory birds may be found in soybean fields. While soybean does not meet the nutritional 

requirements for many migratory birds (Krapu et al., 2004), they may forage for insects and 

weed seeds found in and adjacent to soybean fields. As discussed in Subsection 4.4.1, Animal 

Communities, data submitted by the applicant has shown no difference in compositional and 

nutritional quality of MON 87712 soybean compared with other GE soybean or non-GE 

135
soybean, apart from the presence of the BBX32 protein. MON 87712 soybean is not expected to 

be allergenic, toxic, or pathogenic in mammals. In addition, the BBX32 protein is degraded 

rapidly and completely in simulated gastric fluid and simulated intestinal fluid, and the protein 

makes up only a very small portion (less than 0.001%) of the total plant protein (Monsanto, 

2011). The results presented by Monsanto suggest that the BBX32 protein is unlikely to be a 

toxin in animal diets. Monsanto has initiated a food/feed safety consultation with FDA on MON 

87712 soybean. FDA has evaluated the submission and responded with questions on July 18, 

2012, and Monsanto responded to the questions on August 9, 2012. When complete, these will 

be BNF No. 131.Based on APHIS’ assessment of MON 87712 soybean, it is unlikely that a 

determination of nonregulated status of MON 87712 soybean would have a negative effect on 

migratory bird populations.

7.1.2 International Implications

• EO 12114 (US-NARA, 2010), “Environmental Effects Abroad of Major Federal 

Actions” requires federal officials to take into consideration any potential environmental 

effects outside the United States, its territories, and possessions that result from actions 

being taken. 

APHIS has given this EO careful consideration and does not expect a significant environmental 

impact outside the United States in the event of a determination of nonregulated status of MON 

87712 soybean. All existing national and international regulatory authorities and phytosanitary 

regimes that currently apply to introductions of new soybean cultivars internationally apply 

equally to those covered by an APHIS determination of nonregulated status under 7 CFR part 

340.

Any international trade of MON 87712 soybean subsequent to a determination of nonregulated 

status would be fully subject to national phytosanitary requirements and be in accordance with 

phytosanitary standards developed under the International Plant Protection Convention (IPPC) 

(IPPC, 2013). The purpose of the IPPC “is to secure a common and effective action to prevent 

the spread and introduction of pests of plants and plant products and to promote appropriate 

measures for their control” (IPPC, 2013). The protection it affords extends to natural flora and 

plant products and includes both direct and indirect damage by pests, including weeds.

The IPPC establishes a standard for the reciprocal acceptance of phytosanitary certification 

among the nations that have signed or acceded to the Convention (177 countries as of February 

2013). In April 2004, a standard for Plant Risk Analysis (PRA) of living modified organisms 

(LMOs) was adopted at a meeting of the governing body of the IPPC as a supplement to an 

existing standard, International Standard for Phytosanitary Measure No. 11 (ISPM-11, Pest Risk 

Analysis for Quarantine Pests). The standard acknowledges that all LMOs will not present a pest 

risk and that a determination needs to be made early in the PRA for importation as to whether the 

LMO poses a potential pest risk resulting from the genetic modification. APHIS pest risk 

assessment procedures for genetically engineered organisms are consistent with the guidance 

developed under the IPPC. In addition, issues that may relate to commercialization and 

transboundary movement of particular agricultural commodities produced through biotechnology 

are being addressed in other international forums and through national regulations.

136
The Cartagena Protocol on Biosafety is a treaty under the United Nations CBD that established a 

framework for the safe transboundary movement, with respect to the environment and 

biodiversity, of LMOs, which include those modified through biotechnology. The Protocol came 

into force on September 11, 2003, and 164 countries are Parties to it as of February 2013 (CBD, 

2013). Although the United States is not a party to the CBD, and thus not a party to the 

Cartagena Protocol on Biosafety, U.S. exporters will still need to comply with those regulations 

that importing countries which are Parties to the Protocol have promulgated to comply with their 

obligations. The first intentional transboundary movement of LMOs intended for environmental 

release (field trials or commercial planting) will require consent from the importing country 

under an advanced informed agreement (AIA) provision, which includes a requirement for a risk 

assessment consistent with Annex III of the Protocol and the required documentation.

LMOs imported for food, feed, or processing (FFP) are exempt from the AIA procedure, and are 

covered under Article 11 and Annex II of the Protocol. Under Article 11, Parties must post 

decisions to the Biosafety Clearinghouse database on domestic use of LMOs for FFP that may be 

subject to transboundary movement. To facilitate compliance with obligations to this protocol, 

the United States Government has developed a website that provides the status of all regulatory 

reviews completed for different uses of bioengineered products (US-EPA, 2013). These data 

will be available on the United States Regulatory Agencies Unified Biotechnology Website 

database (http://usbiotechreg.epa.gov/usbiotechreg/). 

APHIS continues to work toward harmonization of biosafety and biotechnology consensus 

documents, guidelines, and regulations, including within the North American Plant Protection 

Organization (NAPPO), which includes Mexico, Canada, and the United States, and within the 

OECD. NAPPO has completed three modules of the Regional Standards for Phytosanitary 

Measures No. 14, Importation and Release into the Environment of Transgenic Plants in NAPPO 

Member Countries (NAPPO, 2003).

APHIS also participates in the North American Biotechnology Initiative, a forum for information 

exchange and cooperation on agricultural biotechnology issues for the United States, Mexico, 

and Canada. In addition, bilateral discussions on biotechnology regulatory issues are held 

regularly with other countries including Argentina, Brazil, Japan, China, and Korea.

7.1.3 Impacts on Unique Characteristics of Geographic Areas

A determination of nonregulated status of MON 87712 soybean is not expected to impact unique 

characteristics of geographic areas such as park lands, prime farmlands, wetlands, wild and 

scenic areas, or ecologically critical areas.

Monsanto has presented results of agronomic field trials for MON 87712 soybean. The results of 

these field trials demonstrate there are no differences in agronomic practices between MON 

87712 soybean and non-GE hybrids needed for their cultivation. The common agricultural 

practices that would be carried out in the cultivation of MON 87712 soybean are not expected to 

deviate from current practices, including the use of EPA-registered pesticides. The product is 

expected to be deployed on agricultural land currently suitable for production of soybean and 

replace existing varieties, and is not expected to increase the acreage of soybean production. 

137
There are no proposed major ground disturbances; no new physical destruction or damage to 

property; no alterations of property, wildlife habitat, or landscapes; and no prescribed sale, lease, 

or transfer of ownership of any property. This action is limited to a determination of 

nonregulated status of MON 87712 soybean. This action would not convert land use to 

nonagricultural use and, therefore, would have no adverse impact on prime farmland. Standard 

agricultural practices for land preparation, planting, irrigation, and harvesting of plants would be 

used on agricultural lands planted to MON 87712 soybean, including the use of EPA-registered 

pesticides. The Applicant’s adherence to EPA label use restrictions for all pesticides is expected 

to mitigate potential impacts to the human environment.

Based on these findings, including the assumption that label use restrictions are in place to 

protect unique geographic areas and that those label use restrictions are adhered to, a 

determination of nonregulated status of MON 87712 soybean is not expected to impact unique 

characteristics of geographic areas such as park lands, prime farm lands, wetlands, wild and 

scenic areas, or ecologically critical areas.

7.1.4 National Historic Preservation Act (NHPA) of 1966 as Amended 

The NHPA of 1966 and its implementing regulations (36 CFR 800) require Federal agencies to: 

(1) determine whether activities they propose constitute "undertakings" that have the potential to

cause effects on historic properties, and (2) if so, to evaluate the effects of such undertakings on 

such historic resources and consult with the Advisory Council on Historic Preservation (i.e., 

State Historic Preservation Office, Tribal Historic Preservation Officers), as appropriate.

APHIS’ proposed action, a determination of nonregulated status of MON 87712 soybean is not 

expected to adversely impact cultural resources on tribal properties. Any farming activity that 

may be taken by farmers on tribal lands would only be conducted at the tribe’s request; thus, the 

tribes would have control over any potential conflict with cultural resources on tribal properties.

APHIS’ Preferred Alternative would have no impact on districts, sites, highways, structures, or

objects listed in or eligible for listing in the National Register of Historic Places, nor would it 

likely cause any loss or destruction of significant scientific, cultural, or historical resources. This 

action is limited to a determination of nonregulated status of MON 87712 soybean.

APHIS’ proposed action is not an undertaking that may directly or indirectly cause alteration in 

the character or use of historic properties protected under the NHPA. In general, common 

agricultural activities conducted under this action do not have the potential to introduce visual, 

atmospheric, or noise elements to areas in which they are used that could result in effects on the 

character or use of historic properties. For example, there is potential for increased noise on the 

use and enjoyment of a historic property during the operation of tractors and other mechanical 

equipment close to such sites. A built-in mitigating factor for this issue is that virtually all of the 

methods involved would only have temporary effects on the audible nature of a site and can be 

ended at any time to restore the audible qualities of such sites to their original condition, with no 

further adverse effects. Additionally, these cultivation practices are already being conducted 

throughout the soybean production regions. The cultivation of MON 87712 soybean is not 

expected to change any of these agronomic practices that would result in an adverse impact 

under the NHPA.

138
8 LIST OF PREPARERS

Biotechnology Regulatory Services

Craig Roseland, Ph.D.,

Senior Environmental Protection 

Specialist, NEPA Unit

Michael Blanchette, M.S.

Senior Environmental Protection 

Specialist, NEPA Unit

Geo-Marine, Inc.

Name Organization Project Role

John Ouellette, M.S., 

Senior Program Manager, 

Environmental Services Division 

Geo-Marine, Inc. Quality Assurance

Susan Miller, M.A.,

Senior NEPA Project Manager

Geo-Marine, Inc. Project Management , Sections 1,3,5, 

Agricultural Production, Physical 

Environment, Human Health, Animal 

Feed.

Karen Johnson, M.S.,

Senior Environmental 

Scientist/NEPA Specialist

Geo-Marine, Inc. Physical Environment

Brian Bishop, M.S.,

Environmental Scientist/NEPA 

Analyst

Geo-Marine, Inc. Sections 1,3,5, Agricultural Production, 

Biological Resources, Endnote.

Chris Lotts, B.S.,

Environmental Scientist

Geo-Marine, Inc. Biological Resources, Threatened and 

Endangered Species

Paul Mitchell, Ph.D.,

Economist

University of 

Wisconsin

Technical Review of Domestic and 

Trade Economic Environment

Pawel Wiatrak, Ph.D.,

Agronomist

Clemson 

University

Technical Review of Agronomic 

Practices

Phyllis Fletcher, A.D.,

Document Production Manager, 

Editor

Geo-Marine, Inc. References, Document Production, 

Editor, EndNote

Anna Banda, M.S., 

Senior Administrative Assistant, 

Environmental 

Geo-Marine, Inc. Editor

139
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Adler, P.R., S.J. Del Grosso, and W.J. Parton. (2007). "Life-cycle assessment of net greenhousegas flux for bioenergy cropping systems." Ecological Applications 17 (3): p 675-91. 

Advantage Seeds. (2005). "Conventional Soybeans." Advantage Seeds. 

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Ahrent, D.K., and C.E. Caviness. (1994). "Natural cross-pollination of twelve soybean cultivars 

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Al-Kaisi, M. (2011). "How Does Soybean Yield Fare Following Corn. Iowa State University 

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