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