re: Syngenta Seeds' petition to produce corn genetically engineered to
produce an enzyme that facilitates ethanol production.
January 20, 2009
The Honorable Barack Obama
President of the United States of America
1600 Pennsylvania Avenue NW
Washington, DC 20500
Secretary Tom Vilsack
Docket No. APHIS-2007-0016
Dept of Agriculture, Regulatory Analysis & Development
PPD, APHIS, Station 3A-03.8
4700 River Road Unit 118
Riverdale, MD 20737-1238
The Honorable Barack Obama and Secretary Vilsack:
The Sierra Club urges you to protect the U.S. food supply and
economy from another USDA bureaucratic bungle and not approve
Syngenta's industrial corn, because it may become the next costly and
preventable genetic contamination debacle in the U.S. Syngenta's
gene altered corn 3272 poses a threat to the U.S. corn supply.
Thousands of U.S. corn farmers will be damaged by the gene
contamination from Syngenta's industrial corn and millions of dollars
in U.S. food will be ruined. Major U.S. food companies will suffer
millions of dollars in tainted corn food items that can not be sold
in the U.S. or abroad. Economic harm to U.S. farmers and food
companies will compound the economic chaos facing them and may
bankrupt some. If the USDA is smart, the agency will recognize that
Syngenta's corn is a bad idea.
Otherwise the U.S. food supply will be sacrificed simply to
grow Syngenta's industrial corn Event 3272 for ethanol that is not
needed to meet current U.S. ethanol production goals. The USDA needs
to be more cautious and avoid making a terrible bureaucratic mistake.
If USDA is smart and conducts an Environmental Impact Statement (EIS)
to properly evaluate the full implications of growing this gene
engineered (GE) corn on a large scale, the USDA will discover this GE
corn is not necessary for ethanol production and U.S. farmers and
food companies will be protected from a multimillion dollar disaster
that is easily avoidable.
The Sierra Club appreciates the opportunity to comment to
USDA Docket No. APHIS-2007-0016 on Petition by Syngenta Seeds, Inc.
and USDA's Environmental Assessment for determination of
non-regulated status for GE corn to produce an enzyme that
facilitates ethanol production. The Sierra Club strongly opposes
USDA approval to grow GE corn Event 3272 as a really bad idea, since
a similar enzyme is already available without using the GE corn.
One reason it's a bad idea is the USDA failed to do an EIS
needed to comprehensively evaluate the environmental and human health
impacts of this industrial GE corn, including food allergies in some
sensitive persons who accidentally consume this corn containing a
unique alpha amylase enzyme. Another reason is this GE corn will be
used to produce ethanol - not food! The USDA failed to do a sound
analysis of how this GE corn will harm the U.S. food supply and cause
more hunger and higher food prices in the U.S.
Contamination of the U.S food supply is a growing problem for
organic and conventional crops, and by approving GE corn Event 3272,
the USDA is assuring new contamination of corn crops and the food
supply, since corn is used in thousands of food items. Contamination
of the U.S. food supply will harm thousands of American farmers, food
companies, consumers, and taxpayers costing millions of dollars in
damage from contaminated food.
The Sierra Club is concerned about introducing a new GE crop,
corn engineered for enhanced ethanol production (Event 3272) because
the inherent biological characteristics of the crop, potential for
genetic contamination and its prolific pollen production demands a
thorough assessment of its impact than the inadequate Environmental
Assessment provides. The Syngenta Petition fails to provide
sufficient scientific data and information to adequately assess its
environmental impact if the GE Corn Event 3272. A rigorous
scientific review is missing in the Environmental Assessment and also
in the Syngenta Petition making it difficult for the Sierra Club to
prepare a suitable reply, except to note that better science is
needed before approval is issued by APHIS.
Finally, USDA must comply with the National Environmental
Policy Act (NEPA) and do an Environmental Impact Statement on GE corn
Event 3272 to comprehensively assess all possible harmful aspects
such as the allergy potential. Failure to properly assess the
allergenic potential of GE corn Event 3272 is a serious failure by
the Obama Administration, USDA Secretary Vilsack and APHIS staff to
act in full compliance with NEPA. The USDA also needs to apply the
"Precautionary Principle" that genetically engineered crops should
first do no harm to public health and the environment. Also see
Sierra Club's detailed public comments submitted to Docket No.
APHIS-2007-0016 on January 20, 2009.
In conclusion, Syngenta's GE corn Event 3272 is a really bad
idea with negative economic consequences for many farmers, food
companies, and consumers, and must not be approved by USDA.
Most respectfully yours,
Neil J. Carman, Ph.D.
Sierra Club Genetic Engineering Action Team
Cc: Carol Browner