We have posted this material now because EPA announced at the end of the
meeting that the proceedings will not be available until August. The
issues addressed in Chicago are very time sensitive, for the reasons noted
below; hence our decision to make this information as widely accessible as
possible. Feel free to pass it along, repost it, or otherwise disseminate
it, giving credit to Ag BioTech InfoNet as the source.
The existing conditional registrations for all Bt-corn events lapse in
April 2001. EPA must act to approve an extension of them, or there will be
no Bt corn planted in crop year 2001 in the U.S. Indeed, because of the
need to produce the seed corn for 2001 in 2000, EPA must act this fall or
early winter in order to give the seed industry time to react, especially
if EPA decides to not allow any further planting of certain or all Bt-corn
events. So without doubt, this is THE major decision on ag biotechnology
the U.S. government will make in the next 3 to 6 months.
The Chicago meeting effectively framed Bt-IRM issues and the choices
facing EPA. EPA-USDA deserve credit for designing an open, balanced
meeting and working to assure all interested parties were represented. The
farmer participation and input was excellent, as noted in the meeting report.
If the goal is preserving the efficacy of Bt, the science clearly does not
support continued use of all the existing Bt-corn events (e.g., the low-
and moderate dose events do not meet the "high dose" criterion, and hence
there is no resistance management plan for these).
The decision whether, and on what conditions to extend the use of Bt-corn
will be the most important test to date of EPA resolve to manage proven
risks (resistance and Monarchs, at a minimum) from agricultural
applications of biotechnology. Resistance is by far the more significant
and consequential risk. If EPA does not act to assure the continued
efficacy of Bt, it will set a precedent that, in the context of transgenic
plants, resistance will only be managed as fully as possible, subject to
the marketing plans and intentions of the companies bringing the
technologies onto the market.
This will be a key policy decision with international implications. It
will mean that EPA deals with concerns about resistance to natural
biopesticides like Bt in the same way it now deals with ecological risks
from pesticides -- it grants registrations with restrictions designed to
mitigate ecological impacts to the extent possible, but almost never turns
down a registration to prevent ecological impacts. One can imagine a
scenario where other countries, or the EU, might insist upon resistance
management plans that prevent resistance, not manage it for 5 or 10 or 20
years. In the absence of a proven resistance management plan that
preserves efficacy, India, for example, might object to plants genetically
engineered to express neem -- a key natural biopesticide used for centuries
in that country.
The EPA-USDA are holding a Bt-cotton resistance management meeting on
August 26, 1999 in Memphis. Many of the same issues and concerns will no
doubt arise again there.
chuck benbrook
Charles Benbrook 208-263-5236 (voice)
Benbrook Consulting Services 208-263-7342 (fax)
5085 Upper Pack River Road benbrook@hillnet.com [e-mail]
Sandpoint, Idaho 83864 http://www.pmac.net
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