Recipient: Office of Pesticide Programs, Environmental Protection Agency

Date: August 28, 2001

Docket No.: Docket OPP-00678B

The recent controversy surrounding the impact of Bt pollen on monarch butterflies indicates the EPA has yet to establish a strong regulatory program overseeing the risks of these new crops. A March 2001 report released by the agency's own Scientific Advisory Panel identified a number of weaknesses in EPA’s current Bt-crops program including inadequate risk assessment process and resistance management plans. According to the report, EPA also erroneously rushed to conclude, based on inadequate data, that Bt corn is unlikely to harm monarchs under field conditions. The SAP indicated that the impact of Bt corn on monarch butterflies remains unanswered.

We believe that the EPA should suspend registration of Bt crops until impacts to non-target organisms, such as the monarch and federally protected endangered butterflies, are fully researched and effective resistance management plans are developed.