Ms. Christine Todd Whitman, Administrator
Public Information and Records Integrity Branch
Information Resources and Services Division (7502C)
Office of Pesticide Programs
Environmental Protection Agency
1200 Pennsylvania Ave., NW
Washington, DC 20460
RE:
Docket No. OPP-00678B
Dear Administrator Whitman,
I am writing to urge you to end the registrations for all of the genetically engineered pesticide
plants currently being reviewed – Bt corn, cotton and potatoes. Genetically engineered pesticide
plants should not be planted for the following reasons.
First, they pose unacceptable risks to human health. While the EPA no longer permits pesticidal
StarLink corn to be grown due to concerns about its allergenic potential, the Agency has refused
to subject other Bt corn varieties to similar scrutiny. This is unacceptable, especially in light of
an EPA-sponsored study which detected antibodies consistent with allergic reactions in
farmworkers exposed to Bt sprays. Consumers shouldn’t be guinea pigs in an experiment to find
out whether genetically engineered corn – in particular Bt sweet corn – is allergenic.
Second, pesticide plants may pose serious long term risks to butterflies and other non-target
insects. Lab and field studies show that at least one type of pesticidal corn – Event 176 – kills
Monarch butterfly larvae when they consume pollen that drifts to milkweed, their only source of
food. Long-term studies are lacking for other varieties of pesticidal corn. Bt pollen may also
threaten endangered butterflies like the Karner Blue.
Third, conventional and organic corn growers have lost valuable markets because of
contamination (or just the potential of contamination) with genetically engineered (GE) corn.
For instance, US farmers are now virtually locked out of the $200 million-a-year European
market. The EPA’s analysis should take account of the significant economic impacts of Bt corn
on the organic and non-GE farm sectors.
Finally, continued use of pesticide plants will inevitably lead to the loss of Bt spray for organic
pest control, imposing a severe hardship on organic farmers. The EPA’s schemes for controlling
development of resistance in insects are fatally flawed because doses of Bt toxin are too low to
kill some pests (which can then become resistant), growers often don’t follow the rules, and the
methods used to monitor for resistance are not sufficiently sensitive.
For all of these reasons, I urge you to end the registrations for all of the pesticidal Bt plants, or at
least suspend them until sufficient data are collected to carry out a thorough review.
Sincerely yours,