Ms. Christine Todd Whitman, Administrator
Public Information and Records Integrity Branch
Information Resources and Services Division (7502C)
Office of Pesticide Programs
Environmental Protection Agency 1200 Pennsylvania Ave., NW
Washington, DC 20460

Re: Docket OPP-00678B

Dear Ms. Christine Todd Whitman:

The policy of the American Corn Growers Association (ACGA) is that farmers should decide for themselves whether they want to plant genetically engineered Bt corn varieties or not. That farmer-choice, neutral policy, however, does not extend to encouraging biotech companies, other farmers, farm or commodity organizations or federal or state governments to promote or endorse policies that allow genetically engineered corn varieties to alter or modify the entire U.S. corn crop in the kind of out-of-control manner that exists today through pollen drift and seed contamination.

Negative market price impacts are not neutral issues. The impact that Bt (genetically engineered or GMO) corn is having on markets for U.S. corn is far from being neutral. Therefore, the ACGA cannot be neutral or silent on those issues. The biotech companies who put these GMO corn varieties on the market are indeed imposing a negative economic impact on the majority of farmers who choose not to plant such corn varieties. Consequently, the ACGA has very serious concerns about EPA's consideration of granting re-registration for Bt corn.

We urge you to seriously reconsider this decision until a comprehensive evaluation is conducted on the negative impacts that Bt varieties are having on markets for U.S. corn. One glaringly negative impact is the extremely low prices that farmers are receiving for corn at the farm level. The major issue of pollen drift and cross-pollination contamination of conventional (non-genetically engineered or non-GMO) corn fields by genetically engineered/GMO corn varieties (StarLink and other varieties) has already caused major global market disruptions for U.S. corn growers.

Considering that 75 to 80 percent of the total U.S. corn crop in 2001 was planted to conventional (non-GMO) varieties, it is clear that current U.S. policy is allowing a minority portion of the crop (genetically engineered or GMO varieties) to jeopardize markets and prices for the total corn crop. That is unacceptable. It's also exactly the opposite of the professed "market-oriented" and "export-oriented" farm policy that the United States government tells farmers this country operates under. U.S. farmers are forced to live with that policy even though it is not delivering higher corn exports. Uncertainty about the marketability of genetically engineered corn varieties only exacerbates an already flawed farm policy.

The ACGA urges you to consider the following market impacts from Bt (GMO) corn:

· Lost corn exports to the European Union: According to official USDA export and trade statistics, U.S. corn export quantity to the European Union has dropped from 2.778 MMT (million metric tons) in MY (marketing year) 1995/96 to the miniscule level of only 6,300 MT as of August 16, 2001 with only two weeks remaining in the current 2000/01 marketing year. Meanwhile, the European Union continues to import about 2.5 MMT of corn from U.S. competitors and non-U.S. origins. Had the U.S. even averaged only 1.5 MMT of corn exports to the European Union for each of these past four marketing years, that would have totaled 6 MMT (236 million bushels) more in exports and the same amount less in ending U.S. corn stocks. That excess inventory (corn not exported) has weighed over the market, holding corn prices down. Had those millions of U.S. corn bushels moved to the EU, U.S. corn prices to U.S. farmers would be considerably higher. Higher corn prices would have also reduced federal farm program costs. Conversely, federal farm program costs have reached record highs while corn prices received by farmers on August 24th as reported by USDA were as low as $1.73/bu. in Iowa, $1.70/bu. in Nebraska and $1.59/bu. in South Dakota. These disastrously low corn prices are about $1.50 per bushel below the national average cost of production for corn, also according to USDA data. Additionally, the intransigence of the U.S. government and some in the U.S. grain industry, on the issue of foreign countries and importers having the right to set their own policies on GMOs overall and on labeling policy, has provided an opening for our corn export competitors, such as China and Brazil, to expand their corn exports at our expense. This will have a long-term negative impact on U.S. corn farmers.

· Lost U.S. corn exports to Asia: According to the USDA-Foreign Agricultural Service Weekly Export Sales Report, U.S. corn exports to Japan are 1,266,500 metric tons less than last year as of August 16, 2001. The same USDA-FAS report shows that Taiwan has imported 272,500 MT less U.S. corn than last year. That's a combined loss of 1.539 MMT (60,636,600 bushels) in U.S. corn exports compared to last marketing year as of 8/16/2001. That loss is largely a result of the StarLink problem in the marketplace combined with foreign market concerns about genetically engineered corn varieties in general.

· Market disruption from StarLink, pollen drift and contamination: The market disruption caused by StarLink corn, beginning last September, continues. It clearly demonstrates the pollen contamination problem inherent with genetically engineered corn. According to Neil Harl, noted Agricultural Economist at Iowa State University, corn pollen can drift up to five miles, which imposes the variety selection decision of the minority on the variety choice of the majority of farmers. Neither biotech seed companies nor farmers can control that problem. That fact alone negates the validity of the "buffer strip" concept, while enforceable, was supposedly intended to prevent pollen contamination of nearby cornfields where different corn varieties are being grown. The serious marketing problems caused by StarLink corn have demonstrated the difficulty faced by the U.S. grain-marketing infrastructure in segregating and marketing conventional corn that is not contaminated, to one degree or another, by genetically engineered corn. It causes the need for expensive testing, separate storage and transportation.

· Farmers harvesting what they didn't sow: Why should farmers be forced to test for GMO presence in their production when they did not plant such varieties at all? This is an even more serious economic issue for farmers that raise value-enhanced specialty corn varieties such as white corn, high oil corn and yellow corn varieties for human consumption. Those varieties lose their integrity and value to processors and customers, with whom farmers have contracted, to deliver specific intrinsic quality attributes. Why should these farmers lose their identity-preserved and value-enhanced markets because biotech companies convinced other farmers to plant GMOs? The problem also extends to organic corn and commodity production, the fastest growing sector in U.S. agriculture. How can the EPA possibly give its blessing, and that of the federal government, to an agenda that jeopardizes the economic interests of a majority of farmers and reduces the quantity and value of U.S. corn exports into the future? Why should any U.S. farmer face the potential for price discounts because another farmer, miles away, chose to plant genetically engineered corn varieties? The biotech companies and their promoters in the industry cannot answer these questions nor address these marketing problems in any satisfactory way.

· New rootworm and corn borer GMO varieties can create more problems: Agricultural news reports indicate that biotech companies are seeking approval and planning to introduce new corn varieties for this coming year that are genetically engineered to control rootworms and more Bt varieties to control European Corn Borer. The reports state that registrations for these varieties are not set for Europe, Japan or several other markets and that there will be "channeling" questions for next season. The article tells farmers "you'll want to be sure you know where that grain is headed when it leaves your farm". Just how are farmers going to control that situation given the pollen drift issue along with the segregation and commingling problems in the grain-marketing infrastructure? These varieties have very real potential to cause serious problems for all farmers.

· 2001 ACGA Farmer Survey shows U.S. corn growers concerned about consumer opinions: A June 2001 scientific, national survey of corn growers done by Robinson and Muenster Associates, Inc. of Sioux Falls, SD for the ACGA, found that 78% of farmers consider the concerns of U.S. consumers and foreign markets on the issue of GMOs as important when they decide whether or not to plant genetically modified corn varieties. 74% stated that the rejection of GMO corn and soybeans by foreign countries is contributing to low commodity prices. 78% of those farmers said they are willing to plant non-GMO corn varieties, instead of biotech GMO corn varieties, in order to keep customers satisfied and world markets open to U.S. corn. The results of this survey confirm that farmers are willing to do what it takes to keep their customers. However, they need public policies in place that help, rather than hinder, that effort.

· Scientist find molecular barrier capable of locking out foreign genes, was the headline in the 2/19/2001 Corn Issue of the High Plains Journal (page 7-A). It reports that a University of Wisconsin-Madison scientist, working with teosinte, a wild cousin of maize, has found a molecular barrier that, bred into modern hybrid corn, is capable of completely locking out foreign genes, including those from genetically modified corn. The article says this discovery is important because it means farmers will have access to a technology that can ensure the genetic integrity of their corn crop. "Governing the flow of genes between populations is what is at stake," says Jerry L. Kermicle, the UW-Madison professor of genetics, who discovered teosinte's genetic barrier. The article points out that, "Corn varieties of all kinds --- from organic to genetically engineered --- are prolific traffickers in genes. Cross-fertilization between strains occurs as gene-laden pollen is carried by bees or blown with the wind, from one field to another. The resulting contamination, especially from genetically modified corn, can ruin organic crops or make traditional hybrid corn worthless for export to countries where consumers are wary of the new technology." The article goes on stating, "The new discovery could permit American farmers to recapture those profitable markets in Europe and Asia by ensuring that organic or traditional hybrid corn is uncontaminated by genes from genetically modified crops". The EPA should encourage expanded, aggressive federal funding of this research or perhaps require that the biotech companies who introduce, promote and market Bt varieties to farmers, fund the public research on this type of new "genetic barrier" corn variety as a means to mitigate the economic damage their genetically engineered varieties have caused. The new "genetic barrier" varieties would remain totally public and be provided to all farmers at no charge. The expense would be born by the biotech companies, so farmers could block pollen contamination from Bt or other GMO varieties and maintain the integrity of their conventional, non-GMO corn. Finally the article points out, "The technology, according to Steve Gerrish, an agronomist and licensing associate with the Wisconsin Alumni Research Foundation, would have instant appeal to organic farmers and farmers whose corn or corn products might be marketed to countries that now bar imports of genetically modified grain." "This technology can potentially solve the problem of contamination of regular hybrid corn and organic hybrid corn by any genetically modified organism (GMO) during the growing season," says Gerrish. As a proactive, solution-oriented step, we urge EPA to promote more research funding so that this molecular barrier can be bred into modern hybrid corn. This kind of research should be a much higher priority for federal research dollars than spending those resources on behalf of the agenda of the biotech industry and the companies that only want to promote their higher priced, genetically engineered varieties and, in many cases, the increased sales of chemicals and herbicides that go hand-in-hand with them.

In conclusion, it is clear that the neutral position of the American Corn Growers Association only extends to giving farmers a choice in what corn varieties to plant. That neutrality does not extend to the serious economic issues of losing export markets, cross-pollination contamination, the burden of on-farm segregation or the increased cost of production and marketing brought on by genetically engineered Bt varieties.

Sincerely,
President
American Corn Growers Association

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