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2 Sample Letters to EPA on Bt - send by March 20



Dear SAN - Sustainable Ag Network

Here are 2 sample letters, the first can be simply signed and/or modified.  The
second needs to be adjustedt.   Please send one for each person who is
concerned the organic industry viable to reach the EPA before Saturday.  There
is a fax number at the end of this fax.

The first letter is by Dr. Neil Carman of the Lone Star Chapter of the Sierra
Club.  The second letter is by Dr. A. Gayle Hudgens.

Below the letters is a call for the EPA to protect Bt by Jane Rissler of PANUPS
and the Union of Concerned Scientists.

Thank you for your support,
Judy Kew
Texas Consumers for Safe Food
-----------------


SAMPLE LETTER TO EPA BY MARCH 21 ON PUBLIC CONCERNS ABOUT THE USE OF
GENETICALLY ENGINEERED PLANT-PESTICIDES SUCH AS Bt corn, cotton, and potato.

EPA will hold a public meeting at EPA headquarters in DC on March 21 
to obtain comments on the management of resistance for 
plant-pesticides, particularly plant-pesticides with the 
insecticidal proteins from the bacterium Bacillus thuringiensis (Bt).

Interested parties who cannot attend the March 21 meeting may submit written
comments to the following address or email:


**************************SAMPLE LETTER***********************************
















Public Response and Program Resources Branch
Field Operations Division (7506C)
Office of Pesticide Programs (OPP)
US EPA
401 M St, SW
Washington, DC 20460
EMAIL:  opp-docket@epamail.epa.gov


ATTENTION DOCKET # CONTROL NUMBER OPP-00470

First, the EPA needs to suspend current registrations and forego 
future approvals of Bt crops until workable resistance 
management plans are available, since this has not been the 
case up to now as the cotton bollworm control failures in 1996 
revealed in major cotton states.  The EPA needs to act responsibly regarding
registrations before further problems develop which 
have arisen in recent growing seasons across the US.

Second, the EPA also needs to urgently convene a meeting of the 
Scientific Advisory Panel (SAB) to evaluate the current Bt crop
management plans.  The SAB meeting is an appropriate mechanism for 
the EPA Office of Pesticide Programs (OPP) to receive critical 
scientific support on how to resolve key technical issues 
surrounding use of Bt crops. 

Third, the EPA needs to make resistance management plans mandatory 
because voluntary plans have not worked well in the past. The EPA 
must act if recent Bt crop problems are to be avoided and the 
economic losses of 1996 are not repeated. The potential is obvious 
that the problem may become worse in 1997 if mandatory 
resistance management plans are not implemented.

It's crucial for the EPA to realize that Bt is critical to the 
organic, sustainable agriculture and IPM communities and that 
corporations should not determine the life span of Bt's usefulness.

The organic and sustainable agriculture communities urge the EPA 
to do much more than it has to protect the effectiveness of Bascillus 
thuringiensis (Bt) as a pest management tool.  Organic consumers 
also have a great deal at stake in the Bt crop issues.


Sincerely,










Public Response and Program Resources Branch
Field Operations Division (7506C)
OPP-EPA
401 M St., SW
Washington DC 20460

Dear Public Servants,

As an organic gardening columnist and former certified organic farmer
who has used Bt successfully in its unadulterated form, I write to
implore you to consider people's long-term health and safety rather than
short-term corporate profits in determining the usefulness and lifespan
of Bt organic pesticide controls.  It is my understanding the the
Environmental Protection Agency will hold a public hearing on March 21
to solicit comments from the public regarding the implications for
resistance management of the bollworm control failure; whether
resistance management plans should be mandatory or voluntary; and what
scientific data are needed to evaluate these plans.  The Agency is also
seeking comments about criteria to be used to determine whether a
pesticide is a PUBLIC GOOD.

As you well know, non-corporate stakeholders generally are unable to
attend your hearings for a wide variety of reasons, the most common
being the lack of economic ability to take off a day or so from work and
travel to the meeting place.  Therefore, I trust you will listen
carefully to those of us who write you and cannot attend yet care deeply
about the outcome ... for future generations.

Because the biotechnology and pesticide corporate sector will be no
doubt be present and vociferous, I write on behalf of all people who
would wish to attend and call your attention to the resistance issue.
Bt in its natural form is important to the organic, sustainable
agriculture and IPM communities and we maintain that a corporation (such
as Monsanto) has no right to determine the life span of Bt's usefulness.
I urge and implore you, therefore to

1) Suspend current registrations and forego future approvals
of Bt crops until workable resistance management plans are
available;
2) Convene a meeting of the Scientific Advisory Panel to
evaluate the current management plans;
3) Make resistance management plans mandatory because
voluntary plans have not worked well in the past.

Furthermore, in determining whether a pesticide (or any other
environmental issue for that matter) is a PUBLIC GOOD, I urge your
Agency to explore the methodology used in the Natural Step program in
Sweden whereby the appropriate questions were asked to seek consensus
from a broad array of the public long before (often self-serving)
industry was brought into the decision-making process.

Thank you for your consideration of the people's interest.


                         P A N U P S
                             ***
                   Pesticide Action Network 
                        North America
                       Updates Service
                 http://www.panna.org/panna/
            =====================================

March 10, 1997

Call for EPA to Protect Bt 

The U.S. Environmental Protection Agency (EPA) is holding a 
hearing on March 21, 1997, in Washington DC, to examine the 
resistance management plan implemented last summer for Bt 
cotton. This hearing is an opportunity for the organic and 
sustainable agriculture communities to tell EPA that it is 
not doing enough to protect the effectiveness of Bascillus 
thuringiensis (Bt) as a pest management tool.

Bt crops are transgenic plants genetically engineered to 
produce Bt toxins, which occur naturally in soil bacteria. 
Spray preparations of bacteria containing the toxin have been 
used for decades by organic growers and other sustainable 
agriculture practitioners. This past season, three Bt crops 
- -- corn, cotton, and potato -- were grown on a large scale 
for the first time in the U.S.

Scientists agree that widespread use of Bt crops threatens 
the continued effectiveness of Bt by accelerating the 
evolution of insect resistance to the toxin. Once insects are 
resistant, Bt sprays and Bt crops will be ineffectual in 
controlling insect pests. To attempt to delay the development 
of resistance, EPA, under pressure from environmentalists and 
organic farmers, has required that Bt resistance management 
plans be implemented with Bt cotton and Bt corn.

At issue in the March 21 hearing is whether EPA-approved 
resistance management plans will work. For example, the Bt 
cotton plan relies on the cotton plant to produce a high 
enough dose of the toxin that all but the most highly 
resistant cotton bollworms will perish. In addition, plans 
call for using refuges -- stands of non-Bt cotton -- that 
provide habitat for non-resistant bollworm that can mate with 
the rare, highly resistant bollworm that survive the high Bt 
dose, thereby diluting resistance. 

In the first year of commercialization, dramatic evidence -- 
in the form of failures to control cotton bollworms -- has 
emerged. This evidence indicates that Bt cotton does not 
produce high enough doses of Bt to delay resistance in the 
cotton bollworm. Other evidence indicates the Bt corn does 
not produce a season-long high dose against the European corn 
borer. (These crops, however, still work well enough to 
produce satisfactory control for most farmers).

Since this past summer's failure, Monsanto is suggesting that 
a high dose is not needed for the bollworm, and that refuges 
alone are sufficient to delay resistance. This assertion 
amounts to a new resistance management plan for Bt cotton and 
the cotton bollworm. No submission to EPA by Monsanto 
detailing a resistance management plan based solely on 
refuges has been made available to the public. Nor has EPA 
evaluated any refuge-only plans, according to the Union of 
Concerned Scientists (UCS). 

UCS maintains that EPA has taken a lackadaisical approach to 
protecting Bt. After the bollworm problem arose last summer, 
UCS urged the Agency to prepare a report on the implications 
of the bollworm failure for resistance management in Bt 
cotton and to convene a meeting of the Scientific Advisory 
Panel to aid in the evaluation. Unfortunately, the Agency has 
done neither and it is now too late to complete a 
reevaluation and enact changes before farmers plant cotton 
this spring. 

EPA needs support to strengthen and enforce its requirements 
that Bt crops be grown in ways that will delay resistance. 
The sustainable agriculture community has a lot at stake. If 
insects evolve resistance to Bt in transgenic crops, they 
will also be resistant to Bt sprays upon which many organic 
and sustainable farmers and IPM practitioners rely.

*** What you can do

In preparation for the March 21 hearing, the Agency is 
soliciting comments from the public regarding the 
implications for resistance management of the bollworm 
control failure; whether resistance management plans should 
be mandatory or voluntary; and what scientific data are 
needed to evaluate these plans. In addition, EPA is seeking 
comments about criteria to be used to determine whether a 
pesticide is a "public good." 

The biotechnology/pesticide industry and other proponents of 
the technology will likely be at the hearing to highlight the 
fact that Bt crops work most of the time and to distract 
attention from the resistance issue.

Please write to EPA emphasizing that Bt is important to the 
organic, sustainable agriculture and IPM communities and that 
Monsanto should not determine the life span of Bt's 
usefulness.

*** Urge the Agency to:

1) Suspend current registrations and forego future approvals 
of Bt crops until workable resistance management plans are 
available;
2) Convene a meeting of the Scientific Advisory Panel to 
evaluate the current management plans; 
3) Make resistance management plans mandatory because 
voluntary plans have not worked well in the past.

Send comments, identified with the docket control number OPP-
00470, to arrive before or on March 21.

By mail to:
Public Response and Program Resources Branch, Field 
Operations Division (7506C), OPP/EPA, 401 M St., SW, 
Washington, DC 20460

By email to:
opp-docket@epamail.epa.gov
(ASCII file with no special characters or encryption)

Source/contact: Jane Rissler, Ph.D., Senior Staff Scientist, 
Union of Concerned Scientists, 1616 P St., NW, Washington, DC 
20036; phone (202) 332-0900; fax (202) 332-0905.

For an in-depth update on Bt cotton, see "Bt Cotton -- 
Another Magic Bullet?" by Jane Rissler, in the March 1997 
Global Pesticide Campaigner. Contact PANNA for further 
information.

|      Pesticide Action Network North America (PANNA)       |
|                                                           |
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