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Approved-By:  Hopwoods <[log in to unmask]>
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Date:         Wed, 11 Aug 1999 17:52:44 -0400
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From: Hopwoods <[log in to unmask]>
Subject:      UCS letter with Sierra Club sign on
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Anyone is welcome to send this to their local newspapers: posted by laurel.

FOR IMMEDIATE RELEASE:                Contact:        Jane Rissler or Margar=
et Mellon
Wednesday, August 11, 1999                                      (202) 332-09=
00

Scientists, Environmentalists Urge EPA to Protect Butterflies
First Joint Petition by Major Green Groups on Gene-Altered Crops

For the first time in the biotechnology debate in the United States, a
group of national environmental organizations is jointly urging federal
action in response to a potential threat to the environment from
genetically engineered crops. In a letter sent on Tuesday, August 10, the
Union of Concerned Scientists, National Wildlife Federation, Sierra Club,
Natural Resources Defense Council, Arizona-Sonora Desert Museum, and
Defenders of Wildlife called on the Environmental Protection Agency to
restrict plantings of Bt corn and strengthen programs for identifying and
assessing the environmental risks of genetically engineered crops which it
regulates.

The letter responds to the concerns raised by a recent Cornell University
report that pollen from Bt corn may threaten monarch and other butterflies
and moths. Prior to its approval, EPA evaluated the environmental risks of
Bt corn but did not uncover the threat of toxic pollen to butterflies.

The groups are urging EPA to refrain from registering or extending the
existing registrations of any Bt-corn varieties until it can assure the
public that the corn pollen is not a danger to the monarch or other rare,
endangered, or threatened butterflies and moths. All Bt-corn varieties
currently on the market were approved under temporary registrations that
will expire in either 2000 or 2001. Because the existing registrations
allow Bt corn to be planted next year, the groups are asking EPA to require
borders of non-Bt corn around Bt varieties in the 2000 growing season to
reduce the flow of toxic pollen outside corn fields.

A copy of the letter can be found on the UCS web site at  HYPERLINK
http://www.ucsusa..org www.ucsusa.org  under News Releases, or call Jane
Rissler or Rich Hayes at 202-332-0900.

Ms. Carol Browner
Administrator
Environmental Protection Agency
401 M Street, SW
Washington, DC  20460

RE: Toxic Bt-Corn Pollen and the Monarch Butterfly

Dear Ms. Browner:

On behalf of the Union of Concerned Scientists, National Wildlife
Federation, Sierra Club, Natural Resources Defense Council, Arizona-Sonora
Desert Museum, and Defenders of Wildlife, we are writing to urgently
request that the Environmental Protection Agency (EPA) restrict the
planting of Bt corn and strengthen programs for identifying and assessing
the environmental risks of genetically engineered crops regulated by EPA
under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).

We make this request in the wake of the preliminary=F3but very
disturbing=F3report that Bt-corn pollen is toxic to monarch butterflies at
concentrations approximating those found in nature and that the widespread
planting of Bt corn may threaten the monarch and other butterflies and
moths.

Monarch butterflies are already under pressure as a result of changes in
their overwintering habitats. Additional threats to monarch populations
feeding on toxic corn pollen as they migrate through the Midwest are of
serious concern.

EPA failed to assess risks of toxic pollen to nontarget Lepidoptera.
In documents supporting the approval of Bt corn, the Agency neither
mentioned nor assessed the likelihood that pollen from transgenic corn
would have an impact on monarchs or any other nontarget Lepidopteran
species. Of special concern is the failure to evaluate impacts on the 18
moths and butterflies listed as threatened or endangered under the federal
Endangered Species Act.

The toxic effects of Bt-corn pollen on monarchs are not surprising as the
Bt-corn toxins are specific to Lepidoptera, an insect group which includes
both the target pest, the European corn borer, and the monarch butterfly.
(Indeed, the category of risks=F3potential effects of transgenic pesticidal
plants on nontarget relatives of the target pests=F3was identified by UCS in
its 1996 report, Ecological Risks of Engineered Crops. ) Moreover, it is
not surprising that some nontarget Lepidoptera, even though they do not
feed on corn, may be exposed to the toxin through pollen, as corn pollen is
readily carried by wind and insects beyond corn fields.

Failure to examine such an obvious risk is a major deficiency in a
regulatory program billed around the world as thorough and comprehensive.
It raises serious questions about the scientific adequacy of the Agency=EDs
ecological evaluation of transgenic crops. One cannot help but wonder what
other, perhaps less obvious, environmental impacts of genetically
engineered crops have been missed by EPA.

The inadequacy of the ecological assessment is of even greater concern in
view of the rapid adoption of transgenic crops. In 1998, Bt-corn varieties
were planted on 20 million acres or approximately one fourth of the corn
acreage in the United States.

Bt corn may offer little environmental benefit.
A major selling point for Bt crops is their promise to reduce applications
of chemical pesticides. However, it appears that substituting Bt corn for
regular corn may do little to decrease synthetic insecticide use. First,
farmers do not typically use pesticides to kill corn borers in field corn,
which makes up all but a small percentage of the corn acreage in the United
States According to an industry plan for Bt-resistance management, =EC[f]or
the vast majority of corn acres (>90%) =D6 growers are unlikely to treat wit=
h
insecticides  to control the corn borer.  In addition, since borer
populations reach economic thresholds only episodically, many farmers
willing to spray may choose not to do so in most years.

Second, even when corn is treated, the adoption of Bt varieties may not
substantially reduce the use of insecticides. A report sponsored by the
Biotechnology Industry Organization estimated that the introduction of Bt
corn reduced insecticide use on only 2.5% of the total US corn acreage in
1998.  Preliminary US Department of Agriculture data for the Heartland
region showed a slight reduction in insecticide use in 1997 for corn borers
on Bt compared to non-Bt corn, and no difference in insecticide use for
other corn pests. Recommendations.
Agricultural biotechnology is a novel and incompletely understood
gene-transfer technology. It is imperative that the technology=EDs
environmental risks be identified and assessed to the extent possible and
that comprehensive assessments occur prior to widespread use.

To achieve that end, we recommend the following:

EPA should not register or extend the existing registrations of any Bt-corn
varieties bearing pollen containing Bt toxin until the Agency:
can assure on the basis of experimental data under field conditions that
the pollen produced by Bt corn is not a danger to the monarch butterfly or
rare, endangered, or threatened Lepidoptera; and
has instituted new, scientifically robust protocols for evaluating the
environmental impacts of Bt crops.

All Bt-corn varieties currently on the market were approved under temporary
registrations that will expire in either 2000 or 2001. EPA should not
register or extend the existing registrations of any Bt-corn varieties
until it has, at a minimum, convened a Scientific Advisory Panel, developed
new protocols to assess and identify the risks of genetically engineered
crops, and consulted with the Department of Interior, as discussed below.

EPA should convene a Scientific Advisory Panel made up primarily of
ecologists to develop protocols for the ecological assessment of Bt crops.
Issues that should be addressed in the protocols include, but are in no way
restricted to, soil ecosystem impacts and effects of Bt toxins on
beneficial organisms, nontarget Lepidoptera, and other species.

In the last two years, in addition to the monarch butterfly studies, new
laboratory research indicates the possibility of risks from Bt crops to
soil ecosystems and beneficial insects. New York University scientists
found that active Bt toxins similar to those engineered into some Bt crops
may accumulate in the soil=F3and may be harmful to soil-inhabiting insects.
Swiss researchers found an indirect but deadly effect of Bt corn on
beneficial insects that feed on European corn borers.

This research should be the basis for the construction of new protocols to
assess risk. These protocols would guide industry in designing and
conducting tests to evaluate the environmental risks of engineered crops.

 EPA should consult with the Department of Interior to determine whether
any moths or butterflies protected under treaties and federal laws have
ranges that overlap the regions in which corn is grown. If ranges put
protected moths or butterflies at risk of encountering toxic pollen, the
Agency should require studies to determine the impact of Bt corn on the
insects.

As an example, consultations with the US Fish and Wildlife Service should
reveal whether any of the 18 Lepidopteran species listed as endangered or
threatened under the Endangered Species Act are at risk from toxic pollen
that might be deposited on plants that they eat.

To reduce the flow of toxic pollen outside corn fields in the 2000 growing
season, EPA should require borders of non-Bt corn around Bt varieties that
contain toxin in their pollen.

EPA adoption of our first recommendation would ensure that monarchs and
other insects would not be harmed by Bt-corn pollen after the 2000 growing
season. This step would not, however, protect nontarget moths and
butterflies from exposure to Bt-corn pollen next year. To provide that
protection, EPA should take steps to reduce significantly the flow of toxic
pollen out of Bt-corn fields by requiring non-Bt buffers around Bt corn. We
endorse the recommendation made by the Environmental Defense Fund in its
July 13 petition to EPA for 40-to-80 foot borders of non-Bt corn around
engineered varieties which produce pollen containing Bt toxin.  The non-Bt
buffers should trap much of the pollen from the Bt corn, thereby reducing
significantly the amount of toxic pollen carried beyond the field to plants
that nontarget moths and butterflies eat.

Thank you for your consideration of these recommendations. Please call Jane
Rissler at 202-332-0900 if you have questions.

Sincerely,

Margaret Mellon, Ph.D., J.D.
Director, Agriculture and Biotechnology Program
Union of Concerned Scientists

Jane Rissler, Ph.D.
Senior Staff Scientist
Union of Concerned Scientists

John Kostyak
Counsel
National Wildlife Federation

Carl Pope
Executive Director
Sierra Club

David Wallinga, M.D.
Senior Scientist
Natural Resources Defense Council

Gary Nabhan, Ph.D.
Director of Conservation and Science
Arizona-Sonora Desert Museum

William Snape
Legal Director
Defenders of Wildlife

cc: Honorable Dan Glickman, Secretary, US Department of Agriculture
      Honorable Bruce Babbitt, Secretary, Department of Interior
      Honorable Jamie Rappaport Clark, Director, US Fish and Wildlife Servic=
e

  J. Losey, L. Raynor, and M. Carter, =ECTransgenic pollen harms monarch
larvae,=EE Nature 399:214, May 20, 1999; L. Hansen and J. Obrycki,
=ECNon-target effects of Bt corn pollen on the Monarch butterfly
(Lepidoptera: Danaidae),=EE Abstract of a poster presented at the North
Central Branch meeting of the Entomological Society of America, March 29,
1999 (www.pme.iastate.edu/info/monarch.htm).
  Lepidoptera is the biological taxon which includes moths and butterflies.
  J. Rissler and M. Mellon, The Ecological Risks of Engineered Crops, MIT
Press, Cambridge, Mass., 1996.
  Monsanto et al., =ECIndustry insect resistance management plan for Cry1A
plant-expressed protectants in field corn,=EE submission to EPA, April 19,
1999.
  L. Giannessi and J. Carpenter, =ECAgricultural biotechnology: insect
control benefits,=EE National Center for Food and Agricultural Policy,
Washington, D.C., July 1999.
  USDA Economic Research Service, =ECGenetically Engineered Crops for Pest
Management,=EE July 1999, www.econ.ag.gov/whatsnew/issues/biotech. No data o=
n
insecticide use in Bt corn were provided for other years or other regions.
  C. Creechio and G. Stotzky, =ECInsecticidal activity and biodegradation of
the toxin from Bacillus thuringiensis subsp. kurstaki bound to humic acids
from soil,=EE Soil Biology and Biochemistry 30:463-70, 1998.
  A. Hilbeck, et al., =ECEffects of transgenic Bacillus thuringiensis
corn-fed prey on mortality and development time of immature Chrysoperla
carnea (Neuroptera: Chrysopidae),=EE Environmental Entomology 27:480-87, 199=
8.
  Environmental Defense Fund, =ECPetition to Carol Browner, EPA
Administrator, to require the planting of buffer zones of non-Bt corn
around fields of genetically engineered Bt corn=D6; and to take related
actions,=EE New York, N.Y., July 13, 1999.

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