THE EU ORGANIC REGULATION: Preference-led markets in an age of sustainability, and ‘The Ideal Dilemma’

Does an agricultural practice’s naturalness determine its environmental sustainability? How might a market for naturalness affect sustainability efforts?

 Sustainable-agriculture-metrics-pic

Markets do not supply goods we need, they supply goods that we want to buy. I like coffee, old furniture, cats, music and a bunch of other stuff. Whether I need these things is irrelevant, if I want them then it creates a market that somebody will step in to fill. What if I want something that causes considerable harm to somebody else by my having it? We all know that some consumer preferences and desires are dangerous or unsustainable in this way. The demand for ivory, aside from being cruel, is responsible for the extinction of the Western Black Rhino. There are of course many such examples which exist along a spectrum of ethical justifiability. The demand for mahogany timber, palm oil or rooibos tea – to name just a few – have all caused problems in some way and have required governments to intervene (RSPO, 2015; Balmford et al., 2012; Milner-Gulland & Mace, 2009). Rooibos tea seems quite a harmless thing for consumers to want and in fact, as I recall, was most popular among my more fashionable and nature-loving friends. The fact that our love of this tea nearly caused the extinction of 112 plant taxa would be mortifying for many of its consumers.

It’s not just what we want, why we want it also matters, crucially so. It is one thing to want rooibos tea because you like the way it tastes but it is another to want it because you believe it will have some miraculous health effects. Imagine that the government ignored all the facts and adopted this false belief and enacted legislative support for a market in medicinal rooibos tea, taking money from other worthy causes to ensure a deluded few can enjoy the bliss of ignorance. This is perhaps how many will view the government support for homeopathy in the UK where millions are spent ensuring that ill-informed consumers have access to this completely ineffective ‘treatment’. Proponents argue that consumers have the right to the kind of treatment that fits their own lifestyle choices, while opponents argue that it is a waste of public money that could be spent alleviating suffering (Marshall, 2015; NHS Choices, 2010b). In these sorts of markets the incentive is to satisfy preferences rather than needs, nobody needs homeopathy. Nevertheless, the ethics of this debate makes for interesting reading.

This article examines similar risks and ethical dilemmas associated with a particular market that has all these characteristics. I want to look at the demands on agricultural production arising from the so called consumer preference-for-naturalness (PFN).  Agriculture, through deforestation, biodiversity loss, land use, pollution, emissions and other factors is a unique and significant threat to sustainability. It is therefore vital to take an evidence based approach in determining how to reduce its impact, make it more ecological and to understand how market demand forces influence the adoption or exclusion of improved practices.

What is the preference for naturalness?

The PFN refers to a tendency for consumers (you and me) to choose products which satisfy an intuitive concept of naturalness. There are a number of different concepts and definitions of naturalness (see Siipi, 2013) but here we will talk about naturalness defined as a lack of human influence and as foods produced without modern technologies wherein consumers view non-natural things as a risk both for the environment and for their health (Lusk & Briggeman, 2009).

The idea that natural and synthetic chemicals or processes are somehow different is a common misconception and a “fallacy” (Royal Society of Chemistry, 2006, p. 2). It seems as though succumbing to such misconceptions is part-and-parcel of owning a human nervous system. Most of us still have the intuitive sense that heavy objects fall faster than lighter ones despite that this was disproved by Galileo centuries ago. Our nervous systems are easily fooled and the universe has a wicked sense of humour it seems, often not behaving the way we feel intuitively that it should… the illusion of naturalness can be thought of as just another case of this.

The Royal Society actually aim their teaching materials at dispelling the natural-myth at around age 14… just a few years after we learn that Santa isn’t real. In spite of this consumers are often more worried about synthetic chemicals in food production than natural ones (Fernqvist & Ekelund, 2014; Dickson-Spillmann et al., 2011; Devcich et al., 2007; Rozin et al., 2004; Saba & Messina, 2003) and may avoid foods perceived as unnatural even if they have clear health benefits e.g. cancer risk reduction (Duncan, 2011). Golden rice springs to mind…

A great deal has been written about the PFN in relation to the healthiness of food, concluding that natural foods are not intrinsically healthy (Rozin et al., 2004) and that the preference can be seen psychologically as a form of magical thinking (Evans et al., 2010; Lindeman et al., 2000) or commodity fetishism (Hepting et al., 2014) which is ideational rather than instrumental and may in part arise because most of us do not understand dose-response relationships (Dickson-Spillmann et al., 2011). Scientists have pointed out that misconceptions about basic chemistry wastes public money which may be spent trying to eliminate “trivial or imaginary hazards” (Monro, 2001). Smith (2001) adds that an additional ignorance of risk-benefit relationships may further worsen the impacts of consumer behaviour and policy interventions.

The world may not have much to worry about if we collectively don’t think light objects fall as quickly as heavy ones (unless we fail to let our flight engineers know this is a myth at some point in their education) but the risks of the PFN are high, as we will see. Having consumers who believe naturalness is a guide to a healthy environment or body is the same as having engineers who believe Aristotelian physics is a guide to successful aviation, particularly when environmental policy uses consumer preference rather than science as it’s arbiter.

So why does this all matter?

I think we need to pay special attention to scenarios in which consumers demand a product which they believe is good for the environment but which is in fact significantly less good when compared to the products they are avoiding. Such mismatches are not unheard of and examples might be offered relating to those who forgo effective modern medicine in favour of ineffective alternative remedies, sometimes with fatal consequences (NHS Choices, 2010a). A single consumer can definitely harm themselves by acting on the PFN in a medical sense so we are led to ask whether the accumulated choices of many consumers acting in this way may harm the Earth. If consumers will forego a significant health benefit as a result of the PFN, may they also forego a significant environmental benefit? This becomes of increasing concern to all of us if demand is large enough as to exert a significant market force or gains policy support.

Despite parallels to medicine, the food market is unique from the myriad other markets with which the PFN interacts in that across the EU legislation has made it so that only foods produced with natural agricultural practices and chemicals are allowed to label themselves using the EU eco-label and a number of ‘eco-terms’. For comparison, imagine if medicines which conform to the PFN were the only kinds allowed to label themselves as ‘healthful’. To the contrary, institutional warnings are issued against the purchase of medicines which equate their efficacy or safety to their naturalness (NHS Choices, 2014; BBC News, 2004). The EU rules make it difficult to label your product as ecological unless it is also ‘natural’.

So there are two points to keep in mind, and I will flesh these out in the next sections:

  1. Naturalness, in the form that consumers demand it, is based on misunderstanding of the way the universe works.
  2. This misconception has crept its way into policy, and this matters.

Institutional support for the preference-for-naturalness

The PFN was embraced as a market by the EU and codified into the organic legislation, asserting consumer rights to such foods. EC Regulation 834/2007 now defines organic agriculture (OA) and organic food (OF) and sets out the rules for certification. The problem with this legislation is that it appears to conflate the PFN with environmental stewardship. Paragraph 1 states that “Organic production is an overall system of farm management and food production that combines best environmental practices […] and a production method in line with the preference of certain consumers for products produced using natural substances and processes” and it specifies a list of marketing terms which are restricted from use on any product that is not produced according to the preference. It is reasonable to ask whether ‘best environmental practices’ is a concept that is incompatible with only ‘using natural substances and processes’ (Wu & Sardo, 2010) making this codified definition oxymoronic.

We should clarify the precise form of the PFN operating within EU regulation –is it the fallacious form or some nuanced scientifically valid form? The EU regulation never defines naturalness specifically, nor advances any scientific basis for the concept or why it should lead to more positive environmental or health outcomes and only consumer preference (i.e consumer ignorance) is cited as the basis for the regulation. As already discussed, we know that the consumer preference is indeed the ‘myth’ form that the Royal Society see fit to dispel.

The references to the consumer preference in the regulation along with restrictions to “natural substances”, preferences for minerals of “natural origin”, “natural disease resistance” and resulting prohibitions on “chemically synthesized” inputs indicate that the legislated form is indeed the fallacious form which asserts that ecological outcomes depend on the naturalness of an input or process.

Large surveys using representative samples of national populations show that ecologically or health minded consumers like buying food marketed as organic (Magkos et al., 2006; Magnusson et al., 2003; Saba & Messina, 2003). Research shows that consumers have concerns about the healthfulness and environmental impact of food (Rollin et al., 2011) and that a rising number of consumers believe that OF and OA satisfies these concerns. Many are willing to pay a price premium for the perceived benefits of naturalness. But if naturalness is a myth, then how much trust should consumers have in the EU policy? As an environmentally minded person I don’t care to much for the policy… and to be honest, if I was ignorant enough to harbour my own preference for naturalness I wouldn’t be too thrilled about the policy either, which has so many caveats that what’s allowed under the regulation is barely ‘natural’ by the end. These caveats by the way are only present because purely natural methods would be utterly unsustainable and so a lot of compromise has to be made.

 

For those who aren’t convinced that the PFN is a misconception…

This section is probably superfluous for anybody who understands that the natural-synthetic distinction is not a meaningful one in terms of health or environmental risk (if you are one of these, feel free to skip to the section on ‘the ideal dilemma’). The truth is that I felt it was important to dedicate at least a little time to showing how easy naturalness comes tumbling down as a theory of nature… and also, to elaborate on some of the risk-benefit relationships that are so important to grasp in these discussions  (and which happen to be utterly fascinating and glorious in the degree interconnectedness). I’ve chosen to focus in on pesticides because they help to demonstrate many of the points and are a major reported concern of consumers who ‘buy natural’. However, the argument is equally interesting and perhaps more damning for natural advocates when we talk about natural and synthetic fertiliser which I will mention briefly later on.

When the consumer PFN is used as a criteria to tell farmers which pest control technologies to use the logical endpoint is that that some farmers will use more harmful, albeit natural, chemicals or methods when better options are available. Consumer preference is not a strategy for choosing the best pesticides. Think about being a farmer – you can either consult an evidence based scientific measure of environmental impact for different pest control strategies choosing what we know is safest, or you can let the consumer zeitgeist decide. We’ve already seen just how fallible we consumers are, the second option is clearly not wise.

Pests require control no matter what. ‘Natural’ options are not always the most ecological way to control them, yet we want to be the most ecological, don’t we? Proponents of naturalness may interpret it differently with some saying perhaps that no synthetic pesticides should be allowed, and others saying no pesticides at all (even natural ones) are acceptable, let’s have a quick look at these two options.

If you are a believer in ‘naturalness’ it’s worth asking yourself before you delve into this “what evidence is needed in order to render naturalness null as a theory of nature?” If we refer to Karl Popper (1934) then a theory of nature is falsifiable when examples and observations can be made which nullify it. J.B.S Haldane famously said that discovery of mammalian fossils in Precambrian rock would cast serious doubt on evolution. No such discovery has ever been made and probably never will. Likewise, if somebody could measure just one instance of a heavy object falling quicker than a light one in a vacuum, then it would render Galileo and the entire theory of gravity incorrect. We likely never will. If you find just one case of something synthetic being safer or more ecological than something natural, then the theory that natural is inherently better should be considered falsified and you must develop a new theory that predicts safety more accurately and reliably…. of course, these are the fields of toxicology and related disciplines.

Naturalness as no synthetic pesticides

So, you’re a environmentally minded farmer and you decide that the best way is to avoid all those nasty synthetic man-made chemicals. A good strategy right? Wrong. Let’s start with one example. Azadirachtin is a natural pesticide banned in the UK and is harmful to bees (Barbosa et al., 2015). It is natural, it comes from neem seeds. It is sold outside the UK under the guise of being “a natural product, absolutely non-toxic” (OzoneBiotech, 2012) and even specifically “non-toxic to bees” (Gosden, 2015; Planet Natural, 2015). The Chemical Regulations Directorate warn of Azadirachtin being marketed as “organic, natural or safe” (HSE, 2010). This is clearly a case where a natural pesticide is more than a bit crap, which challenges the PFN.

Critics have argued that this chemical, along with the Parkinsons-causing Rotenone, were tolerated for a time by regulatory agencies because of the misconception that they were safe-by-virtue-of-being-natural and in use by organic farmers despite insufficient safety testing (Zaruk, 2015). This regulatory ‘free pass’ for natural pesticides was commented on by Magkos et al (2006, pp. 34) saying “decision-making bodies and legislative authorities seem to be concerned about the health risks associated with synthetic chemicals only” and pointing to a number of regulatory agencies who only inexplicably test for risks from synthetic chemicals.

Of course this is just one example, it is not a fluke. Biondi et al (2012) looking at the impacts of 14 pesticides found that organic-certified (natural) pesticides can be more toxic than synthetic ones and that in these cases at least the ‘natural choice’ should not be the preference of anyone who puts the environment at the forefront of their approach. Bahlai et al (2010) reach the same conclusions with regard to six pesticides used in soybean production and the best environmental performance was achieved by the two novel synthetic pesticides. Jansen et al (2010) in an analysis of organic compatible pesticides on aphid natural enemies also found higher toxicity from these than from the synthetic alternatives. This is not to say that synthetic is always better, only that naturalness and syntheticness are both equally useless criteria for choosing pest control.

That said, it is worth remembering how new chemicals (from medicines to pesticides) are often developed. Sometimes a good chemical is found in nature, but it isn’t perfect so chemists use it as a starting point and then play around with it in order to improve it and iron out the negative effects. Thus, many synthetic options are by definition improvements on their natural predecessors.

 

Naturalness as no pesticides at all

PFN advocates may also promote no-chemical approaches, asserting that chemical pesticides, synthetic or natural, should not be used at all (Greenpeace, 2012; Verhoog et al., 2007). No-chemicals is not the same as no-pest-control-at-all as there are other means of controlling pests such as using natural predators, flame weeders, plastic sheets, or tillage (Gomiero et al., 2011) or traditional breeding strategies to increase natural plant defenses. The question remains the same – do such practices intrinsically improve ecological outcomes over chemical options?

At present, non-chemical methods simply are not effective enough to replace pesticides (Hillocks, 2012; Aktar et al., 2009; Edwards-Jones, 2008) which is why pesticides continue to have necessary benefits even for organic farmers  (Bradshaw et al., 2004) and is one of the reasons the EU directive doesn’t prohibit their use entirely.

Trade-offs are without a doubt the most important part of this discussion. Risk-benefit trade-offs are vital in eco-strategies yet are poorly understood by consumers and ignored by conservationists (Balmford et al., 2012; Green et al., 2005). Dayan et al (2009) review many herbicides aimed at weed control indicating a widespread inefficiency in natural herbicides, characterized by low selectivity and poor performance. This introduces our first trade-off. Ask yourself, what are the wider impacts of using a poor method of weed control? This issue was notably raised by long time organic proponent Don Lotter (2014) calling for small scale farmers in Africa to use synthetic fertilizers and herbicides to tackle, for one, the widespread ecological damage caused by the employment of tillage for weed control. Trewavas (2004) in a comprehensive critique of the natural-synthetic-fallacy in organic agriculture suggests that ignorance of risk-benefit trade-offs like this have the potential for significant/catastrophic ecological and social harm if effected at global scales.

Pest threats are certainly real and no-pest-control-at-all is not an option in large part because decisions about pest control have far-reaching implications relating to these complex trade-offs. Cooper & Dobson, (2007) and Popp et al (2013) provide overviews of the many direct and indirect benefits of pesticides, Figure 1, while Edwards-Jones, (2008) aim to specify the benefits which cannot be achieved sufficiently by non-chemical alternatives to pesticides, e.g. control of locusts.

Figure 1 – primary and secondary benefits of pesticides, from Cooper & Dobson (2007)

Figure 1 – primary and secondary benefits of pesticides, from Cooper & Dobson (2007)

For consumers the no-chemicals form of the PFN is a strategy they believe to reduce the risk of dietary toxins. It’s not true, though – a lack of adequate pest control can actually cause higher levels of carcinogenic endogenous pesticides through pest-stress (Kodu & Code, 2013; Magkos et al., 2003). Magkos et al also refer to health issues related to intentionally breeding for higher (but natural) levels of protective endogenous toxins as an alternative to applied pesticides. There have been a number of deaths in the media from natural pesticides and toxins in various vegetables, most recently as I recall an elderly gentleman who died after his courgettes contained dangerous levels of naturally occurring cucurbitacins. Cross (1996) points to various efforts to breed natural pest resistance, e.g. potatoes – an effort which led to tubers which were acutely toxic to humans due to such high levels of natural pesticides. Imagine breeding tobacco by selecting again and again for the highest nicotine content in each generation, how deadly would the plant be eventually? This is what breeding plants for natural pest resistance really means, and this is how nature killed an old man who just wanted soup.

The annual risks of pesticide residues in the diet are smaller than the risks of a single cup of coffee (Ames & Gold, 1998) and this speaks again to the failure of society to understand risk-benefit relationships highlighted by Smith (2001) and Popp et al (2013), thereby being willing to abandon massive environmental and social benefits such as those in Figure 1 to avoid trivial or imaginary health risks. I don’t want to be one of these consumers, do you?

The risk-benefit ignorance is also highlighted by other authors such as Aktar et al (2009), Gold & Slone (2001) & Trewavas (2001) pointing out that the reduction in cancer rates due to cheaper fruits and vegetables, made possible in part by effective pesticides, dramatically outweighs the carcinogenic risks from the pesticides themselves whether they are natural, synthetic or endogenous. Poor diets pose a significantly higher cancer risk than pesticide residues (Winter, 2015; Graça et al., 2014; Defra, 2010) as do endogenous natural pesticides (Magkos et al., 2006; Ames & Gold, 2000; Ames et al., 1990b, 1990a).

It is odd because we grasp trade-offs in so many other areas. Nobody is going to look at a wound from a seatbelt in a car accident and say we should ban seatbelts. Wounds from seatbelts are bad, but they are not as bad as what would happen if we banned seatbelts. Paracetamol has side effects and kills some small number of people every year, but we consider this an acceptable trade-off for the many benefits it brings by relieving millions of headaches. The technology brings new harms, but they are more acceptable than the old harms. We accept this with many things, from cars to electricity to medicine and vaccines. Why can’t we get our f**king heads around it with food and pesticides?

Le sigh…

I told you this whole section was superfluous… Any analysis of the PFN is destined to become nothing more than a list of exceptions to the rule, or a collection of caveats. These examples (and there are many others) do no more than to show that naturalness in the form it is deployed by the public and in eco-agriculture legislation contrasts with scientific understanding and can lead to worse environmental and health outcomes, despite labelling assuring the very opposite. The next section discusses briefly how we can evaluate when and where a PFN will lead to worse outcomes.

The ideal dilemma

I am growing weary of comparative studies, certainly I am appalled that organic farming appeals to any rational person in it’s legislated definition. Many studies have adopted a method of comparing one type of agriculture to another e.g. organic vs conventional. I think this type of comparative literature is stupid for as long as the PFN, a known scientific fallacy, is operating within the organic methodology. Despite the claims made about OA it has failed to deliver. On many important eco-criteria OA performs worse while showing some promise in other areas (see, for example: McGee, 2015; Lotter, 2014; Gabriel et al., 2013; Tuomisto et al., 2012; Spångberg et al., 2011; Mondelaers et al., 2009; Shepherd et al., 2003). Certainly, any positive results cannot be said to be because of naturalness and in fact adherence to the PFN may be holding OA back and could partly explain the mixed results. We must ask whether organic agriculture would in fact be better off without the PFN?

This section is the main point I want to make and one I think is miserably absent from the current debate. It is actually a wider point to be made about allowing preferences to intrude upon problem solving strategies when evidence along will do. With regard to sustainable farming there is difficulty in defining or proving something is sustainable but a dominantly comparative literature fails to address the notion that:

Even if what is sustainable remains unclear indefinitely it is relatively simple to show mathematically and logically that prohibitive-ideational approaches always under-perform compared to evidence-driven approaches with equivalent values*

*This rule could actually apply to any problem solving approaches. When you apply prohibitions derived from Catholic ideals on HIV strategies in Africa you fail to solve the problem as well as an equivalent strategy with the prohibitive ideals removed.

This view was partly advanced by Bahlai et al (2010) looking at Integrated Pest Management (IPM) and organic systems but its significance was not fully realized and I want to develop it further here. What it amounts to is a logical proof that ideology on average will always deliver worse outcomes. I call it ‘The Ideal Dilemma’.

Both evidence-driven approaches and ideational approaches may draw on scientific knowledge to guide best practice but while an evidence-driven approach can do whatever works, ideational approaches can only ever be equal to whatever works minus any methods prohibited by its pre-concocted paradigms and preferences. This could be represented mathematically where the complete toolkit of an evidence driven approach is x and the ideological approach is therefore x-y where y represents the particular things frowned upon by the ideology in question (i.e synthetic chemicals or condoms).

Figure 2 illustrates how this might look using a theoretical set of current-best-practice (CBP) which is defined as the most eco-friendly option according an environmental impact quotient (EIQ) drawn from a complete evidence base for all possible practices. For each farm issue the farmer can choose to deploy either the CBP for that issue, in green, or adopt an alternative for some reason (ideals, cost, availability, etc).

Figure 2 - A radial graph of current best practice vs alternatives. The axis radiate outward along a normalised scale of decreasing environmental impact. Each segment is a different farm management issue and each point on the outer ring (in green) represents current best practice (CBP) i.e lowest impact, for that issue. A farm which only uses technologies and practice represented by the green points is by definition operating at the most ecologically friendly level possible at the time. The yellow points represent the EIQ of hypothetical next best natural alternatives (NBNA) to the CBP, their position on the axis reflect their relative ecological impact. The impact potential (IP) of choosing an alternative is defined by the difference between the CBP and the NBNA, and three scenarios (a), (b) and (c) are labelled. (a) the green CBP is the same as the natural option. (b) the NBNA is slightly worse. (c) the NBNA is much worse. The outer ring represents the practical ‘toolkit’ of the most ecological farms possible at a given time, and the yellow points represent the restricted toolkit of a ideologically prohibitive farm.

Figure 2 – A radial graph of current best practice vs alternatives. The axis radiate outward along a normalised scale of decreasing environmental impact. Each segment represents a different hypothetical farm management issue and each point on the outer ring (in green) represents current best practice (CBP) technology i.e lowest impact, for dealing with that issue. A farm which only uses technologies and practices represented by the green points is by definition operating at the most ecologically friendly level possible at the time. The yellow points represent the EIQ of hypothetical next best natural alternatives (NBNA) to the CBP, their position on the axis reflect their relative ecological impact. The impact potential (IP) of choosing an alternative is defined by the difference between the CBP and the NBNA, and three scenarios (a), (b) and (c) are labelled.
(a) the green CBP is the same as the natural option. (b) the NBNA is slightly worse. (c) the NBNA is much worse. The outer ring represents the practical ‘toolkit’ of the most ecological farms possible at a given time, and the yellow points represent the restricted toolkit of a ideologically prohibitive farm.

Because CBP is by definition the best at that moment in time then all alternatives by definition perform equal-to-or-worse against the chosen metric, never better. An Impact Potential (IP) can then be defined as the difference in EIQ between the CBP and the Next Best Natural Alternative (NBNA). Three possibilities arise:

  1. a) CBP might happen to be something socially accepted as ‘natural’ and so no alternative is required. The IP is 0.
  2. b) The NBNA might only be slightly worse than the CBP. The IP is negligible or acceptable in order to improve the well-being of some consumers.
  3. c) The NBNA might be much worse, or there may even be no suitable natural alternative at all. The IP will be high and have significant negative impacts which could be avoided by switching to the CBP.
best-practice-venn-diagrams

Figure 3 – a summary of the view that preference-led or ideological approaches to problems (in this case farming) are a subset of the best approach.

For the whole farm the total IP of the alternative management choices is the shaded area on Figure 2 and this can only ever be zero if we arrive at a time in our technological development where all possible CBPs happen to be ‘natural’ in the eyes of the consumer/legislation which seems extremely unlikely on a timeline of historic and ongoing melioristic advancement.

This view also asks us to keep in mind that, as technological advancements continue, it may only be a matter of time before adherence to the PFN prohibits the deployment of an extremely beneficial best practice, if it is imagined that it hasn’t already.

If the PFN is indeed ideational and a misconception and if the prohibitions that characterise OA make it ideational in this way then it is subject to this understanding. In this way organic certification as it exists now will always be worse on ecological and health metrics than a completely identical legislation or certification scheme which simply has the PFN removed. There is no two ways about it. Of course, no such certification exists and this is a big problem, too. This is perhaps the other ideal dilemma, in that this thought experiment relies on ideal or perfect knowledge about all current technologies. Still, I think the point remains valid. Various interesting points can be made to further explore and substantiate the message of The Ideal Dilemma, but I will not make them here.

Real world calculations of impact potential

Quantifications of tradeoffs such as those in Figure 1 are in their early days, evolving alongside a gradually improving knowledge of EIQs and similar modelling efforts. Regarding pesticides, the first tier effect of the PFN is the removal of the primary benefits of pesticides the efficient killing of pests. One knock on effect of this is yield loss from pest damage. Oerke (2006) & Oerke & Dehne (2004) put potential global crop losses at 70% if we didn’t use pesticides and 48% of current losses are a result of pests despite best efforts. Cooper & Dobson (2007) and Aktar et al (2009) suggest that poorer diets, famine and increases in communicable disease resulting from abandoning efficient pesticides would result in thousands of lives lost for every life saved and financial costs in the billions along with enormous environmental damage, such as soil erosion from tillage.

If both chemical fertilization and pest-control prohibitions are taken into account several authors have claimed more serious and utterly unsustainable scenarios (table 1). Other studies such as Nowak et al (2013), Connor (2008), Carvalho (2006) & Bichel et al (1999) imply that the PFN means that OA requires nutrient inflows from conventional agriculture that would vanish if it were adopted world-wide. Because alternatives to synthetic nitrogen are insufficient, the IP is high, certainly too high to consider or promote prohibition as an ecological imperative.

These calculations are warnings of the impact if organic regulation became the global imperative and were adopted 100%. While the organic market remains a small part of global agriculture, currently less than 5%, these problems are less serious (Connor, 2008) but the extreme nature of some prospective calculations should raise doubts among ENGOs and decision-makers seeking positive environmental outcomes through global adherence to the PFN and encourage more efforts to calculate and communicate these impacts.

Authors PFN Activity Cost/Impact
(Oerke, 2006; Oerke & Dehne, 2004) Avoiding pesticides altogether 70% loss in yields worldwide.

Billions of dollars loss

(Cooper & Dobson, 2007) Avoiding pesticides altogether Thousands of lives lost for every life saved.

Billions of dollars in loss

 (Cooper & Dobson, 2007) Avoiding transgenic herbicide resistant crops between 1982 and 1997. Unable to adopt conservation tillage practices which “reduced wind erosion by 31%, and water soil erosion by 30%.“
(Foley et al., 2011) Avoiding intensification, mineral fertilisers and chemical pesticides between 1961 and 2005 additional 161 GTC in the atmosphere
(Ausubel et al., 2013) Abandoning chemical inputs on a global scale. Doubling the world’s cropland area by 2050 to maintain current per capita food consumption
(IFPRI, 2002, p. 4) Avoiding intensification, mineral fertilisers and chemical pesticides between 1970 and 1975 Loss of saved land: “In Asia cereal production doubled between 1970 and 1975, yet the total land area cultivated with cereals increased by only 4 percent”
(Burney et al., 2010) Avoiding the intensification that took place after 1961 Loss of emission efficiency: “each dollar invested in agricultural yields has resulted in 68 fewer kgC (249 kgCO2e) emissions relative to 1961 technology ($14.74/tC, or ∼$4/tCO2e), avoiding 3.6 GtC (13.1 GtCO2e) per year.”
(Smil, 2011)  Avoiding synthetic nitrogen fertiliser Unsustainable manure requirements: “to replace synthetic nitrogen with organic nitrogen would require the manure production of approximately 7-8 billion additional cattle”…

“The United States alone would have to accept nearly one billion additional animals and an added two billion acres of forage crops to feed those animals, equal to all the land in America except Alaska.”

Table 1 – impacts of abandoning, or never having deployed, chemical pesticides and fertilisers in global agriculture

‘Ecological’ vs Ecological – the future of the PFN

As far as I see it science cannot yet tell us what the best form of agriculture is for the environment, certainly not in all locations which each have unique characteristics. But science does tells us that the PFN as a strategy is necessarily restricted from achieving the outcomes that would allow it to be defined and marketed as the right choice for consumers looking to exercise their ecological conscience. Yet, this is exactly how it is marketed and not just by sneaky mountebanks, but by EU legislation. That the EU has granted naturalness the exclusive right to market itself as eco-friendly is thus a grave injustice in many ways. The EU has to act to develop a more appropriate, ethical, successful and just eco-certification scheme.

Consumer shame and producer justice.

In the UK 8% of households are responsible for 54% of organic food sales, a small dedicated consumerate (Gerrard, 2013). Other consumers cite a desire to purchase organic but say they cannot afford to do so and the question arises whether there is imparted a shaming or guilt (Sörqvist et al., 2015; Clarke et al., 2008) on these consumers who clearly have a desire to express their ecological conscience in the market but who may (falsely) believe they are contributing to ecological harm through their inability to ‘fork out’. Just as important is the shame that consumers feel when buying ‘cheap’ foods (Rödiger & Hamm, 2015), which also reflects a lack of understanding insofar as cheaper fruits and vegetables, as previously mentioned, are one of the great health successes of modern society.

The price premium also impacts producers. Farmers have privately admitted to me to knowing that their own organic plots are no more eco-friendly than the rest of their farm but they benefit from the price premiums and this economic rationale for conversion to OA is apparently common (Sutherland, 2011). This is perhaps a morally questionable exploitation of consumer trust and ignorance. Other farmers who value the environment but are informed enough to avoid ideational natural approaches may struggle under current legislation to communicate their efforts to consumers using recognised and trusted certification schemes which will not acknowledge their effort, in addition to not being eligible to receive the payments made to those in the organic schemes (Green et al., 2005).

Do consumers have a right to ignorance when it comes to the environment?

Let’s forget for a moment about the feelings of consumers and producers and ask something more fundamental. Is it right for the natural environment to ‘take a hit’ in order to give consumers the false impression that they are being green when they aren’t? Don’t we as consumers have an obligation to the environment to address our own ignorance if it is going to cause harm? If we love nature, shouldn’t we accept it as it really is rather than as we wish it was?

Employing less sustainable (not necessarily unsustainable) production practices may incur social and ecological consequences raising a conflict between food preferences and sustainability. Does a misplaced desire for naturalness itself constitute justification for increased appropriation of ecosystem services?

Free market ethics, food sovereignty and autonomy invoke a deontological view of individual rights yet beneficence must surely override such rights if consumers make irresponsible choices (de Tavernier, 2012). Agriculture’s impact on the Bonum Commune constitutes a strong moral basis for governance, intervention and regulation. Referring again to medicine, there are examples which show that autonomy may be questioned or revoked if individuals make dangerous choices about their own treatment (Schwartz et al., 2007). Concerns raised about leaving the environment in the hands of consumer trends (Sutherland, 2011) present a similar dilemma but at global scales – legislative beneficence in medical treatment autonomy may protect an individual from self-harm, while in the food market it justly serves to protect a shared environment. The legislative paternalism behind EC Regulation 1924/2006 on health claims made on food and similar regulations support the notion that we as consumers, by way of our social contract, concede certain liberties. Such relinquishment’s depend on the trust that specialists and institutions have access to knowledge and insights which we average consumers cannot be reasonably expected to grasp while tending the day-to-day demands of our modern lives (de Tavernier, 2012). This trust is not being honoured by the EU in the case of the eco-label regulation where poor judgement is exercised and harmful misconceptions hurt both people and the environment.

The PFN, as a fallacious intuitive preference, speaks also to a view of regulations as a means “to inoculate us against our failures of intuition” (Harris, 2015) and for us to correct for our own biases in which good social institutions act to reflect in policy our best judgment as we cannot always exercise it ourselves. Choice editing is one way of doing this and is a form of weak paternalism supported by decision makers and ENGOs as a means to achieving sustainable food in the UK (Environmental Audit Committee, 2012). Measures such as choice editing are ethically supported by the fact the environmental awareness does not correlate well with environmental purchasing behaviour (Graça et al., 2014). The PFN ought to be considered in choice editing strategies but this should not serve to allow consumers to avoid personal responsibility entirely nor diminish the importance of public education.

Clearly there are injustices associated with having a legislation that promotes the PFN. This may constitute what James, (2006) called “undesirable distortions” and “ill-defined” aspects of legislation that prevent economically driven sustainable agriculture and we must ask where will this leave us in the coming decades?

Conclusions

The PFN is absolutely a scientific misconception and is no guarantee of the positive environmental outcomes which it has been deployed to assure, but will very likely perform much worse than an equivalent legislation in which the misconception is absent. In this way a legislated market in naturalness acts to assert the right of the market to appropriate ecosystem services to meet consumer preferences. When such preferences are poorly informed the environment may be said to be being appropriated unjustly, particularly when taken in the context of the environmental crises we currently face.

Rawls (1971 p .3) states “Justice is the first virtue of social institutions, as truth is of systems of thought. A theory, however elegant and economical, must be rejected or revised if it is untrue; likewise laws and institutions, no matter how efficient or well arranged, must be reformed or abolished if they are unjust” and both parts of this statement are relevant here. The PFN as a system of thought is untrue and must be rejected; and the institutional eco-label in rewarding the PFN is unjust and in need of reform for this reason. The EU eco-regulation may well stand in the way of a responsible eco-market by trying to combine two incompatible consumer preferences – The PFN and a desire to minimize ecological harm.

Most importantly…. decision makers in the EU need to figure out if the purpose of the organic legislation is as a regulatory scheme for eco-agriculture, or whether it is an instrument to assert the rights of consumers to their irrational food preferences. If the latter is the case then the labelling standards may need to be reviewed to avoid anything which suggests to consumers that the preference is an appropriate means of expressing ones ecological-conscience, and also to leave room for a suitable evidence based and policy backed eco-agriculture scheme to develop and market itself alongside the findings and consensus of developing agricultural science.

Final remarks…

Acknowledging our failures of intuition is most important in our battle to save the Earth and the life it nurtures, where our gut ideas about naturalness stands at odds with how the cosmos really works.

If we treat nature how we want it to work, rather than accepting how it really works, we do so at our peril. There is no point implementing a strategy that appeals to some innate sense of what is natural if the universe simply doesn’t work that way… any more than there would be sense in designing satellites as though heavy objects fell at different velocity than lighter objects.

If we love the Earth we’ll accept it how it is and we’ll treat it in a way that will work, not just a way that will satisfy some mawkish vision of natural purity. Shame on you, E.U.

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