Bt Resistance; EPA Meeting

        There are many on this list interested in the implications of
widespread planting of Bt-transgenic plants.  Michael Hansen and I presented
a statement today, March 21, before the EPA public meeting.  The full text
(12 pages) presents a brief, but reasonably comprehensive review of the
scientific reasons why most independent scientists believe resistance is
inevitable.  Just last week a very important new paper was published in the
"Proceedings of the NAS" by Dr. Bruce Tabashnik and colleagues which, in our
judgment, provides the most compelling evidence yet that resistance is not
just inevitable, but also around the corner.

        I will e-mail the full text of our statement to anyone that asks for
it, but ONLY as an attached Word file.  If you cannot read/convert such a
file, your best bet is to get it off the PMAC website ,www.pmac.net>.  It is
up already, go to what's hot, and follow the signs.  The last page -- the
"Remedies" section -- follows, to let you know what we advised EPA to do.


Excerpt from Benbrook/Hansen statement 3/21/97 before EPA Bt-transtgenci
plant resistance public meting:


        As recommended in "Pest Management at the Crossroads" (PMAC), CU
feels that EPA should delay any further approval of Bt-transgenic plant
varieties, and that previous approvals should be reversed when evidence
points to the imminent failure of a RMP, a condition which has now clearly
been met for Bt cotton, and which may be met for Bt-corn in crop season 1997.  

        Furthermore, to evaluate RMPs in the case of any transgenic plant
varieties, CU feels that EPA should require registrants to submit a detailed
annual report on the status of resistance, and on how well the RMP is
faring, for at least the first five years of commercial use.  The data cited
in such reports should be accessible for independent review.

        As part of this report, the companies should submit the names and
addresses of farmers planting transgenic crops, so that independent
researchers can study these farms to develop a complete and accurate
assessment of resistance levels and trends. (It is noteworthy that the
identity and location of the farmers planting Bt-cotton in Australia is
known and public; public release of this information made it possible for
regulators, consultants and researchers to appraise performance in Australia
much more fully and systematically than possible in the U.S.)  In addition,
EPA should develop its own, independent capacity to monitor resistant trends
in the field, and deploy this capacity in the event additional, uniquely
valuable natural biopesticides are introduced into plants via genetic

        Our strong opposition to Bt-transgenic plant varieties is pragmatic.
We see many promising applications of biotechnology in advancing progress
toward biointensive IPM.  Several are described in Chapter 6 of PMAC
(Benbrook et al., 1996).  But genetic engineering is like "The Force" in
Star Wars, it has a dark side with the power to return pest management to
the "stone-age."  Sometimes the rush to get products onto the market
overwhelms the disciplined consideration of need, scientific uncertainties
and longer-term consequences. Public policy must fill the void.  In the case
of public good biopesticides like Bt,  EPA can best do so by enforcing the
requirement for effective, science-based resistant management plans.


Charles Benbrook                         202-546-5089 (voice)
Benbrook Consulting Services             202-546-5028  (fax)
409 First Street S.E.                    benbrook@hillnet.com   [e-mail]
Washington, D.C.  20003                  http://www.pmac.net