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Dakota Resource Council
P. O. Box 1095, Dickinson ND 58602-1095
(701) 483-2851; www.drcinfo.com
Dakota Resource Council urges
the U. S. Environmental Protection Agency to deny the petition of
Monsanto to change tolerances on wheat, rice, and bentgrass to allow
the application of glyphosate to genetically engineered versions
of these crops.
First, the petition is clearly
premature. Monsanto has not received approval from either the U.
S. Department of Agriculture or the U. S. Food and Drug Administration
to release genetically modified (GM) wheat. Therefore, GM wheat
cannot yet be grown commercially. Monsanto representatives told
the North Dakota Legislative Interim Committee on Agriculture in
a March 12 hearing that it did not plan to commercialize GM wheat
until at least 2005. In fact, it may never be commercialized.
EPA should not preempt USDA
Animal and Plant Health Inspection Service (APHIS) by approving
increased tolerances for glyphosate on wheat, rice and bentgrass.
APHIS is the agency charged with the regulation of the commercialization
of GM crops. Since increased tolerances of glyphosate on these crops
serve no purpose prior to the commercialization of GM varieties,
increasing tolerances serves no other purpose than to create regulatory
inertia for the commercialization of GM wheat, rice and bentgrass.
This kind of regulatory inertia will only hamper the ability of
APHIS to make an informed, impartial decision regarding if and when
these GM crops should be deregulated and commercialized. Since there
is considerable disagreement over the commercialization of these
GM crops, GM wheat in particular, EPA should refrain from increasing
the glyphosate tolerances prior to a decision by APHIS.
Second, GM wheat should not
be commercialized, and therefore any increase in tolerance levels
to accommodate its commercialization should be denied. GM wheat
faces increasing opposition, especially in North Dakota. Earlier
this month, two research extension centers of North Dakota State
University announced that they would not participate in new nursery
trials for GM wheat. Their decision was prompted by a number of
disturbing facts:
- There is very little market acceptance
for GM outside the United States;
- There are no storage and transportation
systems in place to prevent the mixing of GM and non-GM seeds;
- There is no proven method of preventing
cross-pollination of GM and non-GM wheat in the field;
- There is no evidence that U. S. Animal
and Plant Health and Inspection Service setback requirements are
adequate to prevent cross-pollination from test plots;
- Certified non-GM seeds for other plants,
such as soybeans, are becoming extremely difficult to obtain,
effectively closing organic and GM-free markets to producers;
- Farmers who are so unfortunate as to have
planted other GM plants are finding that they are unable to rid
their fields of GM contamination, even after planting certified
non-GM seeds.
It would be foolhardy to
accept commercialization of GM wheat under these circumstances.
In addition to Dakota Resource Council, several other farm organizations
in the state actively oppose introduction of GM wheat until these
problems have been addressed. These groups include the North Dakota
Farmers Union, the Farm Bureau of North Dakota, the North Dakota
Wheat Commission, the North Dakota Grain Dealers Association, and
the Northern Plains Sustainable Agriculture Society.
Third, since the request
on this docket directly relates to facilitating the commercialization
of GM wheat, rice, and bentgrass, the Environmental Protection Agency
should conduct a thorough study of the effects of introducing these
GM plants into the environment prior to ruling on the issue of glyphosate
tolerances. Glyphosate tolerances are only a small part of the potential
environmental impact of the introduction of additional GM plants
into the environment. This study should include, but not be limited
to, thoroughgoing analyses of:
- Whether GM wheat and rice have the same
nutritional properties as non-GM varieties;
- The potential impacts of these GM plants
on allergenicity;
- The ability of the biotech industry to
protect the rights of other seed owners and control the spread
of its product through cross-pollination and seed-mixing;
- The buildup of resistance to glyphosates
in the weeds sought to be controlled by these GM products, and
the likelihood that the commercialization of more GM products,
touted as more environmentally sound, may eventuate in further
requests, such as this one, for increasing tolerance levels.
Any other approach by the
U. S. Environmental Protection Agency would be an abdication of
its responsibility to protect the environment and human health.
Sincerely,
Mark Trechock
Staff Director
Dakota Resource Council
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