[Sustain] USDA Poised To OK Ethanol Corn As First Industrial Genetic Engineered Crop

Eric Brooks brookse32 at aim.com
Wed Jan 14 14:49:03 PST 2009


<http://www.centerforfoodsafety.org>

USDA Proposes First-Ever Industrial GE Crop

Dear Eric,

USDA is poised to deregulate the world's first genetically engineered 
(GE) industrial crop.  _Similar to GE pharma crops that use corn for 
producing drugs, Syngenta's "Event 3272" is genetically engineered to 
use corn for energy (ethanol) production and not for food._   This 
unprecedented, industrial application of a GE technology poses a variety 
of environmental, health, and economic risks that must be carefully 
evaluated to determine whether the widespread use of this GE industrial 
corn crop should be allowed on farms across our nation. 

In a "business as usual" move, USDA has fast-tracked the 
commercialization of this GE industrial corn and has forgone conducting 
a full Environmental Impact Study (EIS), as required by law. Instead, 
USDA is basing its decision to approve the industrial GE corn upon a 
cursory and incomplete Environmental Assessment (EA) that falls woefully 
short of the thorough review the public expects before a new GE crop is 
approved.  Moreover, USDA has failed to acknowledge that this GE 
technology requires even greater scrutiny since it transforms a 
ubiquitous food crop ---corn--- into an industrial crop --- ethanol--- 
making it no longer fit for human consumption.

_The Obama Administration's USDA must complete a full EIS to address 
these concerns.  The agency is accepting public comments only until 
January 20, 2009._

*Event 3272 corn:*

    * _Raises serious environmental and human health concerns_. It
      contains an exotic enzyme derived from "thermophilic"
      (heat-loving) microorganisms living near deep sea hydrothermal
      vents.  This enzyme might be capable of causing food allergies in
      people who inadvertently consume this corn.  Humans have never
      been exposed to this form of alpha amylase before (no history of
      safe use). 
    * _While meant for fuel and not food, this corn will enter the food
      supply_.  USDA admits that if Event 3272 corn is intentionally or
      accidentally diverted into the food supply, it could negatively
      impact food quality. But instead of reviewing the foreseeable
      negative impacts of biological contamination to organic and
      conventional corn from this unprecedented new industrial crop,
      USDA has improperly relied on Syngenta, the creator of the GE
      corn, to protect non-industrial corn from contamination. If we
      learned anything from the StarLink episode, it is that voluntary,
      industry-led agreements to curtail contamination do not work in
      the real world. 
    * _Is not needed "to help the U.S. meet its goals for ethanol
      production"_ as USDA has erroneously suggested. Ethanol production
      from corn surpassed the 2012 target (7.5 billion gallons) in 2007
      (8.2 billion gallons)!  And with 10 billion gallons of ethanol
      produced in 2008, we're well on the way to achieving the mandate
      for 2022 without the introduction of Event 3272 corn. 
    * _Is engineered for fuel, not food._ The dramatic worldwide surge
      in food prices last year -- which has already pushed 100 million
      more of the world's poor into hunger and poverty -- has caused a
      radical rethinking of how biofuels are produced, especially the
      use of corn for ethanol.  Food experts from academia to the World
      Bank have decried the massive diversion of corn from food to fuel,
      blaming it for at least part of the steep price increases in food
      staples like corn, wheat and rice.  Event 3272 corn will only
      exacerbate this situation.

_Tell USDA to halt this approval until a full EIS has been completed 
that addresses the human health, environmental, and economic impacts 
this industrial corn presents. USDA is accepting public comments until 
January 20th---Send your comment today!_



<http://ga3.org/campaign/EthanolCorn/8un56k84pj7mb6j6?>

Send a letter to the following decision maker(s):
Docket No. APHIS-2007-0016

Below is the sample letter:

Subject: Docket No. APHIS-2007-0016

Dear [decision maker name automatically inserted here],

Docket No. APHIS?2007?0016,
Regulatory Analysis and Development,
PPD, APHIS, Station 3A?03.8, 4700
River Road, Unit 118, Riverdale, MD
20737?1238.

I am writing regarding Docket No. APHIS-2007-0016, Syngenta Seeds, Inc.; 
Availability of Petition and Environmental Assessment for Determination 
of Nonregulated Status for Corn Genetically Engineered To Produce an 
Enzyme That Facilitates Ethanol Production. I strongly oppose commercial 
introduction of Event 3272 corn unless and until a full Environmental 
Impact Study (EIS) addresses and resolves the serious human health, 
environmental, and economic issues that Event 3272 raises.

Syngenta's "Event 3272" corn is genetically engineered to facilitate 
easier conversion to ethanol, and is not meant for human consumption. 
This first-ever industrial GE corn presents a multitude of serious 
health, environmental, and economic concerns that have not been 
adequately assessed in USDA's cursory and incomplete Environmental 
Assessment (EA).

Event 3272 corn contains an exotic enzyme derived from "thermophilic" 
(heat-loving) microorganisms living near deep sea hydrothermal vents. 
Syngenta's alpha amylase is generated at extremely high levels in the 
corn kernels themselves. Humans have never been exposed to this form of 
alpha amylase before(no history of safe use). We know some versions of 
this enzyme (from fungi) cause respiratory allergies, which are closely 
related to food allergies. And Syngenta's corn-embedded enzyme has two 
characteristic properties of food allergens: it's extremely resistant to 
breakdown by heat, and it tolerates somewhat acidic conditions. Thus it 
will likely survive food processing and may withstand gastric juices 
intact, which means a higher likelihood of triggering allergic reactions.

There's no doubt Event 3272 will enter the food supply. Corn 
cross-pollinates at great distances, and there are absolutely no 
requirements to plant this industrial corn away from food-gra de corn. 
Instead of reviewing the foreseeable negative impacts of biological 
contamination to organic and conventional corn from this industrial 
crop, USDA has improperly relied on Syngenta to protect non-industrial 
corn from contamination.

If we have learned anything from the StarLink episode, it is that 
voluntary, industry-led agreements to curtail contamination do not work 
in the real world. StarLink was a GE corn variety only approved for 
animal feed, not the human food supply. Despite grower agreements and 
voluntary stewardship measures, it massively contaminated the food 
supply, costing farmers, food companies, and taxpayers millions of 
dollars in recalls and lost sales. This experience, along with other 
contamination episodes, showed us that weather, pollen flow, and basic 
human error are simply unavoidable once GE crops are released in the 
open environment. To approve another non-food corn crop based solely on 
Syngenta's word that they will police themselves is irresponsible and 
ignores the realities of farming, food production, human error, and 
basic ecology. Thus far, none of our major corn export markets have 
cleared Event 3272 for import and any corn shipments contaminated with 
Event 3272 are likely to be rejected by Japan, Korea and other 
GE-sensitive markets.

APHIS claims that Event 3272 corn is needed "to help the U.S. meet its 
goals for ethanol production." Congress set certain targets for ethanol 
production in the Energy Policy Act of 2005 and the Energy Independence 
and Security Act of 2007. This is the sole reason given for the supposed 
need for Event 3272 corn. However, ethanol production from corn 
surpassed the 2012 target (7.5 billion gallons) last year in 2007 (8.2 
billion gallons)! And with 10 billion gallons of ethanol produced in 
2008, we're well on the way to achieving the mandate for 2022 without 
the introduction of Event 3272 corn.

Of course, the dramatic worldwide surge in food prices last year--which 
has already pushed 100 million more of the world's poor into hunger and 
poverty--has caused a radical rethinking of biofuels. Food experts from 
academia to the World Bank have decried the massive diversion of corn 
from food to fuel, blaming it for at least part of the steep price 
increases in basic staples like corn, wheat and rice. In 2007, U.S. 
farmers devoted a full 23% of the 13 billion bushel corn harvest to 
ethanol production. In 2008, the percentage rose to 30%.

Event 3272 poses unacceptable risks to human health, the environment, 
and the economic well-being of family farmers. It is not needed to meet 
U.S. biofuels production targets. And even if it were, the food crisis 
makes painfully clear what should have been obvious all along: that 
diverting stupendous quantities of staple food crops (e.g. 30% of U.S. 
corn) to feed automobiles has dramatically increased the price of not 
only corn, but all primary staple crops, and is driving hunger th 
roughout the world.

Sincerely,

Eric Brooks

<http://ga3.org/campaign/EthanolCorn/8un56k84pj7mb6j6?>

	
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What's At Stake:

USDA is poised to deregulate the world's first genetically engineered 
(GE) industrial crop. Similar to GE pharma crops that use corn for 
producing drugs, Syngenta's "Event 3272" is genetically engineered to 
use corn for energy (ethanol) production and not for food. This 
unprecedented, industrial application of a GE technology poses a variety 
of environmental, health, and economic risks that must be carefully 
evaluated to determine whether the widespread use of this GE industrial 
corn crop should be allowed on farms across our nation.

In a "business as usual" move, USDA has fast-tracked the 
commercialization of this GE industrial corn and has forgone conducting 
a full Environmental Impact Study (EIS), as required by law.Instead, 
USDA is basing its decision to approve the industrial GE corn upon a 
shorter assessment that falls woefully short of the thorough review the 
law requires before a new GE crop is approved. Moreover, USDA has failed 
to acknowledge that this GE technology requires even greater scrutiny 
since it transforms a ubiquitous food crop--corn--into an industrial 
crop --ethanol--making it no longer fit for human consumption.

The Obama Administration's USDA must complete a full EIS to address 
these concerns. The agency is accepting public comments only until 
January 20, 2009.

Event 3272 corn contains an exotic enzyme derived from "thermophilic" 
(heat-loving) microorganisms living near deep sea hydrothermal vents. 
The enzyme --alpha-amylase--breaks down starches into complex sugars. 
Syngenta's alpha amylase is generated at extremely high levels in the 
corn kernels themselves for the purpose of eliminating one step in 
ethanol production and save a little money. The trouble is that this 
enzyme might be capable of causing food allergies in people who 
inadvertently consume this corn. Humans have never been exposed to this 
form of alpha amylase before. But, we know some versions of this enzyme 
(from fungi) cause respiratory allergies, which are closely related to 
food allergies. Syngenta's corn-embedded enzyme has two characteristic 
properties of food allergens: it's extremely resistant to breakdown by 
heat, and it tolerates somewhat acidic conditions. Thus it will likely 
survive food processing and may withstand gastric juices intact, which 
means a higher likelihood of triggering allergic reactions.

Despite the fact that this GE corn is meant strictly for industrial use, 
USDA admits that if Event 3272 corn is intentionally or accidentally 
diverted into the food supply, it could negatively impact food quality. 
And there's no doubt Event 3272 will enter the food supply. Corn 
cross-pollinates at great distances, and there are absolutely no 
requirements to plant this industrial corn away from food-grade corn. 
Instead of reviewing the foreseeable negative impacts of biological 
contamination on organic and conventional corn from Event 3272 corn, 
USDA has merely relied on Syngenta, the creator of the GE corn, to 
protect non-industrial corn from contamination.

If we have learned anything from the StarLink episode, it is that 
voluntary, industry-led agreements to curtail contamination do not work 
in the real world. StarLink was a GE corn variety only approved for 
animal feed, not the human food supply, because leading allergists said 
it might cause food allergies. Despite grower agreements and voluntary 
stewardship measures, it massively contaminated the food supply, costing 
farmers, food companies, and taxpayers millions of dollars in recalls 
and lost sales. This experience, along with other contamination 
episodes, showed us that weather, pollen flow, and basic human error are 
simply unavoidable once GE crops are released in the open environment. 
To approve another non-food corn crop based solely on Syngenta's word 
that they will police themselves is irresponsible and ignores the 
realities of farming, food production, human error, and basic ecology. 
Thus far, none of our major corn export markets have cleared Event 3272 
for impo rt and, therefore, any corn shipments contaminated with Event 
3272 are likely to be rejected by Japan, Korea and other GE-sensitive 
markets.

So why is USDA even considering going down this road again? In the draft 
approval document APHIS claims that Event 3272 corn is needed "to help 
the U.S. meet its goals for ethanol production." Yet Congress?s targets 
for ethanol production in the Energy Policy Act of 2005 and the Energy 
Independence and Security Act of 2007 have already surpassed the 2012 
target (7.5 billion gallons) in 2007 (8.2 billion gallons)! And with 10 
billion gallons of ethanol produced in 2008, we're well on the way to 
achieving the mandate for 2022 without the introduction of Event 3272 corn.

The dramatic worldwide surge in food prices last year--which 
unfortunately has already pushed 100 million more of the world's poor 
into hunger and poverty--has caused a radical and necessary rethinking 
of biofuels. Food experts from academia to the World Bank have decried 
the massive diversion of corn from food to fuel, blaming it for at least 
part of the steep price increases in food staples like corn, wheat and 
rice., Unbelievable as it may seem, U.S. farmers devoted a full 23% of 
the 13 billion bushel corn harvest to ethanol production in 2007 and in 
2008, that percentage rose to 30%.

Event 3272 poses unacceptable risks to human health, the environment, 
and the economic well-being of farmers, and is not needed to meet U.S. 
biofuels production targets. And even if it were, the food crisis makes 
painfully clear what should have been obvious all along: that diverting 
stupendous quantities of staple food crops (i.e. 30% of U.S. corn) to 
feed automobiles has dramatically increased the price not only of corn, 
but also of all primary staple crops driving hunger throughout the world.

_Tell USDA to halt this approval until a full EIS has been completed 
that addresses the human health, environmental, and economic impacts 
this industrial_ corn presents. USDA is accepting public comments until 
January 20th--Send your comment today!


Campaign Expiration Date:
January 21, 2009

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