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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) |
| |
| Phone:(415) 541-9140 Fax:(415) 541-9253 |
| Email: panna@panna.org http://www.panna.org/panna/|
| PANNA, 116 New Montgomery, #810, San Francisco, CA 94105 |
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