July
31, 2014
https://drive.google.com/file/d/0B8gyxHH4EWoBZ2ItOWtQOXRyMjQ/view?pli=1[To:]
The Honorable Thomas J. Vilsack
Secretary,
Department of Agriculture
1400 Independence Avenue,
SW
Washington, DC 20250
[To:] The Honorable
Gina McCarthy
Administrator, Environmental
Protection Agency
1200 Pennsylvania Avenue,
NW
Washington, DC 20460
Dear Secretary
Vilsack and Administrator McCarthy,
We write to
you to express our grave concerns regarding your
agencies’ proposed decisions to register the Enlist
Duo herbicide as well as deregulate new varieties of
genetically engineered (GE) crops engineered to
withstand exposure to the active ingredients
glyphosate and 2,4-D. We believe that the
Environmental Protection Agency (EPA) and U.S.
Department of Agriculture (USDA) have failed to
thoroughly analyze and address the risks of Enlist Duo
and the multiple adverse human health, environmental,
agronomic, and socioeconomic harms that approval of
2,4-D crops will likely cause.
We currently
stand at an agricultural crossroads. The first
generation of “Roundup Ready” GE crops increased
herbicide use by 527 million pounds between 1996 and
2011, triggering an epidemic of glyphosate-resistant
“superweeds” which now infest over 61 million acres
across 36 states. 2,4-D crops are among the
“next-generation” of GE crops engineered to withstand
applications of older, more toxic herbicides. While
they are often touted as a solution to
herbicide-resistant weeds, even the USDA’s Animal and
Plant Health Inspection Service (APHIS) recognizes in
its draft Environmental Impact Statement (DEIS) that
deregulating 2,4-D crops will spur the further
evolution of 2,4-D resistant weeds and cause a three
to seven fold increase in 2,4-D use.
The
scientific community has sounded alarms about exposure
to 2,4-D for decades. 2,4-D has been linked to
multiple adverse health effects including cancer
(especially non-Hodgkin’s lymphoma), decreased sperm
count, liver disease and Parkinson’s disease. Further,
exposure has also been shown to negatively impact the
hormonal, reproductive, neurological and immune
systems. In addition, EPA has reported that 2,4-D is
the seventh largest source of dioxins in the United
States. Dioxins are extremely toxic chemicals, and
their bioaccumulation in the food chain may
potentially lead to dangerous levels of
exposure.
We are also concerned that EPA failed
to thoroughly examine all of the significant health
and environmental risks of 2,4-D including that of
inhalation and aggregate exposure; the risks of 2,4-D
exposure to threatened and endangered species; and the
risks posed by shifts in use patterns of 2,4-D as a
result of the GE cropping systems. Most alarming is
EPA’s failure to apply the additional safety factor of
10x, as mandated under the Food Quality Protection
Act, to protect children, who are especially
susceptible to harm from pesticide exposure. The
10-fold safety factor is required by law to safeguard
against the potential health risks for young children
and infants that would result from the widespread use
of 2,4-D on GE crops.
In deciding to prepare a
DEIS before proceeding, USDA APHIS recognized that its
proposed approval of Dow’s 2,4-D crops will likely
cause significant environmental, agronomic and
socioeconomic harms.
Despite acknowledging
these significant harms, in the DEIS, APHIS alleges it
“must” approve the proposed crops pursuant to the
Plant Protection Act (PPA), because they do not create
“plant pest” harms.
However in so doing APHIS
has narrowly constrained its interpretation of its
regulation. This overly narrow and arbitrary
interpretation of APHIS’s authority is contrary to
common sense and good governance principles, as well
as contradicts prior acknowledgments by APHIS that its
GE crop review is “considerably broader” than its
review of “traditional” plant pests. Rather, APHIS has
authority over broadly defined harms to agriculture
and the environment that it must apply to Dow’s crops
and their acknowledged adverse impacts.
Surveys
of state pesticide regulators establish that 2,4-D
drift is already responsible for more episodes of crop
damage than any other pesticide. Vastly increased use
with approval of 2,4-D crops would correspondingly
increase crop damage, putting farmers of sensitive
crops at grave risk. Wild plants, waterways and
wildlife – including pollinator – habitat would also
be threatened. 2,4-D is a quite potent plant-killer,
even at levels typical of drift. EPA tests show that
2,4-D is over 400 times more toxic to emerging
seedlings and 12 times more toxic to growing plants
than glyphosate.
While APHIS admits that
transgenic contamination because of its proposed
action is possible, even likely, it refuses to analyze
it. We believe that contamination will occur and it
will result in significant economic harm to
conventional, organic and even some growers of the
first generation of glyphosate-resistant GE crops.
Yet, the agency wrongly puts the entire burden on
non-2,4-D crop farmers to attempt to avoid
contamination.
We request that USDA and EPA
fully review the facts, law, and science in this case.
As the over 400,000 public comments indicate, the
risks of approving 2,4-D crops are simply too great
and benefits too few to jeopardize public health, the
environment and the long-term sustainability of our
food supply. We therefore request EPA not register
Enlist Duo for use on 2,4-D crops and USDA maintain
the regulated status for 2,4-D resistant
crops.
Sincerely…
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