05
Oct
Again: Trump Administration Needs to Listen to Science to Protect Farmers and the Environment (Instead of Special Interests)
(Beyond Pesticides, October 5, 2020) Another example of trading health and environmental protection for the support of special interests, EPA announces the misleading and fraudulently named, “EPA Supports Technology to Benefit America’s Farmers.” This time, EPA announces plans to “streamline the regulation of certain plant-incorporated protectants (PIPs).” Named to sow confusion, PIPs are plants engineered with pesticides in them. PIPs are known in general for two problems arising from incorporating pesticidal ingredients into crops: residues that cannot be washed off and production of crop-eating insects that are resistant to the incorporated pesticide that blankets the agricultural landscape.
This time, EPA is proposing to exempt from regulation certain PIPs created by biotechnological techniques that are cisgenic (using genes derived from sexually compatible species), such as CRISPR. The distinction that EPA seeks to make between cisgenic plants and transgenic plants (in which the gene of interest may come from any species) is not supported by science. In fact, cisgenic techniques make use of genetic material other than the targeted genes, and that may come from species that are not sexually compatible with the crop. The bottom line: these genetically engineered organisms introduce havoc into biological systems and the local ecology.
According to an analysis by Les Touart, PhD, Beyond Pesticides’ senior science and policy manager, ”Experiments confirm that cisgenesis can result in significant unanticipated changes to a plant. The results of these experiments show that a trait introduced via a cisgene can result in plants that differ in unanticipated and dramatic ways from their conventionally bred counterparts. The differences observed would have important implications relevant to health and ecological risk assessments.”
Two important confounding aspects that EPA ignores are the likely move by the biotech industry to use multiple genetic manipulations—EPA has never been good at assessing risks of multiple stressors—and pleiotropy. Pleiotropy is the fact that a single gene controls more than one trait, so that introduction of a genetic change may have unanticipated impacts.
The other important effect of the use of PIPs is the certain development of resistance in pest organisms. Resistance creates severe economic impacts on farmers and the food production system because it leads to crop failures and requests to use more toxic compounds on for so-called pest emergencies. These resistance events, of course, are predictable outcomes that should not qualify for emergency use of unregistered pesticides under a loophole in the federal pesticide law. Because PIPs present a constant exposure to the pesticide, they present a constant selection pressure for resistance. Resistance to Bacillus thuringiensis (Bt) arising from its incorporation as a PIP in corn has resulted in the loss of effectiveness of this biological insecticide and the use of more toxic insecticides as a replacement. (See Beyond Pesticides’ draft comment on PIPs to EPA.)
Simultaneous with this proposal, EPA has issued a proposal to address the development of resistance to Bacillus thuringiensis (Bt) in PIP corn and cotton. The proposal does not address or impact the biology of pest populations developing resistance, but only the recognition and identification of such resistance. Science shows that continued reliance on chemical or PIP insecticides only continues the cycle of pests developing resistance and continued need for new chemistry or technologies. Options not considered in EPA’s new resistance management framework include organic management practices, which uses crop rotation and the employment of biological control measures and enhancements.
Even in chemical-intensive agriculture, crop rotation is a good management option because it reduces the possibility of existing pests developing resistance to a particular insecticide by breaking the cycle of continual exposure that causes selection pressure. Crop rotation is more advantageous than use of refuges (buffers where the insecticides are not used), which have failed results due to ongoing pesticide dependency. Likewise, a variety of biological controls as alternatives to reliance on insecticide treatments are available and can be encouraged with proper management for lepidopteran pests resistant to Bt crops. EPA’s resistance proposal, therefore, only serves as a façade while the agency allows the use of more genetically engineered crops. (See Beyond Pesticides’ draft comment on resistance management to EPA.)
Letter to Congress
I am writing to ask you to ask the U.S. Environmental Protection Agency (EPA) to stop harming farmers and the environment by ignoring the science of pest management and pesticide dependency. In another example of trading health and environmental protection for the support of special interests, EPA misleadingly announces, “EPA Supports Technology to Benefit America’s Farmers,” to “streamline the regulation of certain plant-incorporated protectants (PIPs).” PIPs are known for two problems arising from incorporating pesticidal ingredients into crops: residues that cannot be washed off and production of crop-eating insects that are resistant to the incorporated pesticide.
EPA proposes to exempt from regulation certain PIPs created by cisgenic biotech techniques such as CRISPR that use genes derived from sexually compatible species. The distinction that EPA seeks to make between cisgenic plants and transgenic plants (in which the gene of interest may come from any species) is not supported by science. In fact, cisgenic techniques make use of genetic material other than the targeted genes, which may come from species that are not sexually compatible with the crop.
According Beyond Pesticides’ senior science and policy manager, Les Touart, PhD, ”Experiments confirm that cisgenesis can result in significant unanticipated changes to a plant. The results of these experiments show that a trait introduced via a cisgene can result in plants that differ in unanticipated and dramatic ways from their conventionally bred counterparts. The differences observed would have important implications relevant to health and ecological risk assessments.”
Two important confounding aspects that EPA ignores are the likely move by the biotech industry to use multiple genetic manipulations—EPA has never been good at assessing risks of multiple stressors—and pleiotropy. Pleiotropy is the fact that a single gene controls more than one trait, so that introduction of a genetic change may have unanticipated impacts.
The other important effect of the use of PIPs is the certain development of resistance in pest organisms. Because PIPs present a continuous exposure to the pesticide, they present a constant selection pressure for resistance. Resistance to Bacillus thuringiensis (Bt) arising from its incorporation as a PIP in corn has resulted in the loss of effectiveness of this biological insecticide and the use of more toxic insecticides as a replacement—often through the use of a loophole in the pesticide law that identifies the predictable resulting insect resistance and population explosion as an emergency.
EPA has also issued a proposal to address the development of resistance to Bt in PIP corn and cotton. The proposal does not address or impact the biology of pest populations developing resistance, but only the recognition and identification of such resistance. Science shows that continued reliance on chemical or PIP insecticides only continues the cycle of pests developing resistance. EPA fails to consider agricultural practices used in organic agriculture, including crop rotation and biological control. Crop rotation is always a good management option because it reduces the possibility of existing pests developing resistance to a particular insecticide by breaking the cycle of continual exposure that causes selection pressure. Likewise, a variety of biological controls are available that can be encouraged to manage lepidopteran pests resistant to Bt crops. EPA’s resistance proposal, therefore, only serves as a façade while the agency allows the use of more genetically engineered crops.
Please tell EPA to listen to scientists, not the companies it is supposed to regulate. Ecology and toxicology support the need for incentives to adopt organic agriculture.
Thank you for your consideration of this request.
