-- FORWARD ---
From: Joseph Makuch, INTERNET:email@example.com
To: Patricia Dines, 73652,1202
Date: Tue, Apr 29, 1997, 1:38 AM
Subject: MEETING IN TEXAS TO SOLICIT COMMENTS ON PLANS FOR PL. PEST (fwd)
---------- Forwarded message ----------
Date: Mon, 28 Apr 1997 16:01:23 -0400 (EDT)
Forwarded from <PRESS@epamail.epa.gov>
FOR RELEASE: FRIDAY, APRIL 25, 1997
EPA ANNOUNCES PUBLIC MEETING IN TEXAS TO SOLICIT COMMENTS ON
RESISTANCE MANAGEMENT PLANS FOR PLANT-PESTICIDES
EPA will hold a public meeting on May 21, at Texas A & M University,
College Station, Texas, to solicit public comments on the management
of resistance for plant-pesticides, particularly plant-pesticides with
the insecticidal proteins from the bacterium Bacillus thuringiensis (Bt).
The Agency recognizes the value of Bt as a safer pesticide and
has determined that it is necessary to conserve this resource by
requiring resistance management plans. To date, EPA has registered Bt
plant-pesticides in three crops: Bt corn, Bt cotton and Bt potato.
The plant-pesticides produce the pesticidal active ingredient
throughout the growing season, which increases the possibility of pest
resistance, both to the target pests as well as other susceptible insects.
The specific issues for which EPA is seeking comment include
the necessity for resistance management plans, the critical elements
of such plans, and the requirements for successful implementation.
EPA held an initial hearing to solicit public comments in Washington,
D.C. on March 21. Approximately 30 individuals and organizations made
presentations or submitted written comments. The information from
both hearings will be made available to the public after the Agency
has had an opportunity to review all comments from both meetings.
The May 21 hearing will be held in room 301 of the Rudder Tower at Texas
A & M, 9 a.m. to 5 p.m. Persons who wish to make a presentation are
urged to register in advance by submitting a brief written request and
abstract before May l4 to: Michael Mendelsohn, Biopesticides and
Pollution Prevention Division (7501W), Office of Pesticide Programs,
U.S. EPA, 40l M St. S.W., Washington, D.C. 20460; 703-308-8715.
All correspondence concerning this issue must be received by May 21 and
should be identified with EPA's docket control number OPP-00478.
Interested parties who cannot attend the meeting may submit written
comments by email to: firstname.lastname@example.org. Further details on
the meeting can be found in the April 18 issue of the Federal Register
R-65 # # #
From: Patricia Dines, 73652,1202
President Clinton INTERNET: President@Whitehouse.Gov
Senator Diane Feinstein INTERNET: Senator@Feinstein.Senate.Gov
Hon. Lynn C. Woolsey INTERNET: WOOLSEY@HR.HOUSE.GOV
Date: Tue, Apr 29, 1997, 1:02 PM
Subject: re: EPA MEETING TEXAS/COMMENTS ON RESISTANCE MANAGEMENT PLANS FOR
RE: EPA's docket control number OPP-00478 - comments on resistance
management plans for plant-based pesticides (Bt)
I am not an expert on resistance management plans specifically, but I do
know something about agriculture and toxics, and I am a citizen who cares
about both the health of humans and the environment. I am deeply concerned
about the widespread harm being done by the high level of toxic pesticides
that are currently used in mainstream agriculture, and I am extremely
supportive of organic agriculture as our path out of the nightmare.
Therefore, I want to strongly encourage you to have extremely high level of
controls on Bt crops, so that this important tool (Bt) is not taken from
Personally, I'd like to see no Bt crops being grown - both because I feel
it's reckless use of a key organic input - and because I am deeply opposed
to genetic engineering - (1) because of the high risk it holds for the
basis of life, our DNA, and our food supply (2) because of our high lack of
knowledge about doing this level of tinkering, and (3) it breaks the
age-old cycle of humans saving seed from season-to-season, in a natural
cycle with nature, and instead replaces it with a more expensive path of
corporate ownership of the basis of Life.
But .. if we are to use genetically-engineered crops at all, I feel that we
should wait until we have a great deal more knowledge and testing about
them - including resistance patterns and effects on humans and the
environment - before introducing them as broadly as their sponsoring
corporations are currently planning. For instance, it is my understanding
that an antibiotic-resistant gene is being used as a marker on at least
some of the genetically-engineered crops. ** DO WE REALLY WANT TO BE
INTRODUCING ANTI-BIOTIC RESISTANCE INTO OUR FOOD SUPPLY?? ** Just one of
the many reasons I feel that we are being reckless with highly risky
activities, and that the consequences will be dire and widescale indeed -
and worse, extremely difficult for medical professionals to determine the
cause, if we allow these things to permeate our food supply.
But ... if the EPA is insisting on allowing the use of
genetically-engineered crops at their current state of development, then I
beg and plead for you - for our well-being and that of many generations to
come - to use the very highest level of controls and caution that are
available, to develop worst-case disaster scenarios and take them
seriously, and to treat with great respect the number of unknowns in the
equation. This should be done at the very very least.
When I read the statement (in the press release on this) "The Agency
recognizes the value of Bt as a safer pesticide and has determined that it
is necessary to conserve this resource by requiring resistance management
plans." I am encouraged (although not as much as if we had refused to go
down this path at all).
However, when the next sentence is, "To date, EPA has registered Bt
plant-pesticides in three crops: Bt corn, Bt cotton and Bt potato." and I
reflect on the failure on the cotton crops - and the corporation's spin
statements to try to deny that fact - then I see the worst case scenarios
unfolding in front of my eyes - and I don't see the corporations treating
that risk with anything near the level of seriousness or truth-telling I
would require of people you are giving permission to tinker with the very
basis of life itself.
The corporations promised they could control resistance - but the cotton
experience disproves that. I believe the problem is deeper than this
particular situation. I believe that resistance to Bt with Bt crops cannot
be "managed" - that increased resistance is INHERENT in the whole approach
of putting pesticides in all plants, instead of just where they are needed.
So I'd like to recommend some kind of exit provision in these plans for Bt
resistance management - some point where the EPA will say, "Nope, sorry -
you haven't disproven the most obvious of premises - that putting
pesticides in crops is a poor delivery mechanism - and that the best way to
manage resistance is to only use pesticides where they are actually needed"
for that is what I indeed believe is true.
Prophylactic use of pesticides is just as foolish as prophylactic use of
anti-biotics, and it PREDICTABLY creates the same outcome - increased
resistance and decreasing success of the tool, until it fails. We have
seen this over and over and over again. When will we see this, and use the
tools wisely and SPARINGLY? Putting them into the plant itself is a
foolhardy delivery mechanism INHERENTLY.
Instead of seeking to manage the risk of inherently foolish enterprises so
that corporations can benefit and move to countries where overhead and
environmental controls are less (i.e., profit to the corporation doesn't
trickle down to much of the American population, but is instead accumulated
by a few) - let's instead put our energy into developing and educating
people on true sustainable ag, where the soil is deeply nurtured (and thus
the resulting plants that we eat); where pesticide use is at its absolute
minimum, and used wisely; and where age-old patterns of saving seed and
knowing the land are revered, not run over by the drive of certain people
to accumulate far more personal wealth than an individual needs, no matter
the cost to our health, our social systems, our environment, our
pocketbooks, or our land....
Thank you for taking your time to consider my comments, for they are not
only heart-felt but also informed by deep study of the issues involved. I
hope you find these comments useful in your work to support the highest
outcome for the greatest number of people, and for future generations.
Best regards -
Citizen, United States of America