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Center for Food Safety – Science Comments – FG72 Soybean 4 b. Introduction Bayer CropScience has genetically engineered soybeans with resistance to the broad-‐spectrum herbicides containing isoxaflutole (Balance Flexx) and glyphosate (Roundup and other brands). Bayer CropScience has developed FG72 soybean in response to the epidemic of glyphosate-‐resistant (GR) weeds fostered by widespread use of GR crops, with the idea that isoxaflutole will be able to control GR weeds in soybean (DEA at 42 – 43, Petition at 15). It expects growers to continue using glyphosate in conjunction with isoxaflutole to help manage non-‐GR weeds (Petition at 15). It is foreseeable that FG72 soybean will be stacked with Bayer CropScience’s glufosinate resistance trait, as well, as we discuss below. APHIS is now considering whether to approve Bayer CropScience’s petition for non-‐regulated status (Petition) for FG72 soybean, and has prepared a draft Plant Pest Risk Assessment (DPPRA) and draft Environmental Assessment (DEA) that are open for public comments. We appreciate the opportunity to participate in this process. c. Herbicide use is part of the FG72 soybean system FG72 soybean is a weed control system that includes the genetically engineered crop and use of the herbicides that the crop has been engineered to withstand. According to APHIS and Bayer, the purpose of the FG72 soybean system is give farmers herbicidal options to manage difficult weeds, in particular weeds that have evolved resistance to glyphosate herbicides (DEA at 42, Petition at 15 -‐ 16). The target species of the FG72 soybean system are thus weeds of soybean. 1 In this respect, FG72 soybean is the same as other herbicide-‐resistant (HR) crops: they are weed control systems involving one or more post-‐emergence applications of the HR crop-associated herbicide(s). Dow describes its pending 2,4-‐D-‐ resistant corn and soybean in precisely these terms, as the “Enlist Weed Control System” (DAS 2011a), with the brand name “Enlist” referring to both the HR trait and Dow’s 2,4-‐D herbicide. Monsanto describes its HR crops in similar terms: “The utilization of Roundup agricultural herbicides plus Roundup Ready soybean, collectively referred to as the Roundup Ready soybean system...” 2 This purposed use of FG72 soybean cannot be assessed without careful consideration of the herbicidal components of the system, any more than an automobile can properly be assessed without putting gasoline in the tank and subjecting it to a road test. APHIS’ failure to assess Monsanto’s glyphosate-‐resistant, Roundup Ready (RR) crop varieties as HR crop systems led to unregulated cultivation, which as discussed later, generated the glyphosate-‐resistant weed epidemic that is now the rationale for Bayer CropScience’s FG72 soybean. APHIS’ preferred 1 See DPPRA at 12 for APHIS’ untenable view that there are no ‘target’ species for FG72 soybean. 2 From: “Petition for the Determination of Nonregulated Status for Roundup Ready2Yield Soybean MON89788,” submitted to USDA by Monsanto on June 27, 2006 (revised November 3, 2006), APHIS Docket No. APHIS-‐2006-‐0195, p. 4).
Center for Food Safety – Science Comments – FG72 Soybean 5 alternative in the DEA – full deregulation – would repeat this same mistake with the FG72 soybean system, triggering unacceptable impacts. Therefore, APHIS must assess both FG72 soybean in its own right and as a component of an HR soybean system, in which isoxaflutole and glyphosate would be used in different amounts and in altered patterns by virtue of the genetically engineered resistance to these herbicides in FG72 soybean seed. The anticipated use of glufosinate via stacked traits must also be assessed. APHIS must determine how approval of the FG72 soybean system will change associated herbicide use in order to properly assess impacts of approval on agronomic practices, human health, the environment, threatened and endangered species, and socioeconomic factors – both in the short-‐ and long-‐term. As shown in these comments, APHIS has failed to provide an adequate assessment of the FG72 soybean system. d. Specific herbicides that are part of the FG72 soybean system i. Herbicides that FG72 soybean can withstand because of transgene expression a) Isoxaflutole FG72 soybean is the first crop genetically engineered to be resistant to isoxaflutole, or to any herbicide in its class. Isoxaflutole is a relatively new herbicide, first used in the US in 1999, which kills plants by disrupting photosynthesis, resulting in bleaching and then death. Isoxaflutole is a pro-‐herbicide that is activated when it degrades or is metabolized to DKN (a diketonitrile derivative) within the plant or in the environment. It is classified as an HPPD inhibitor – interfering with the enzyme hydroxyphenolpyruvate dioxygenase (US EPA 1998). Other members of this herbicide class include mesotrione (Callisto), tembotrione (Laudis), and topramezone (Impact) (AgWeb 2012). Currently, no isoxaflutole is used in soybeans because soybeans are very sensitive to it, and would be killed along with the weeds. Isoxaflutole is used only in corn to kill weeds, and is applied before the crop is planted (pre-‐plant), after planting but before the corn emerges (pre-emergence), until the corn is 2” high (very early post-‐emergence) (Bayer CropScience 2011a). It can remain active in the soil for months, killing weeds that germinate after rains later in the season (Bayer CropScience 2011b) Isoxaflutole is applied at very low doses compared to other commonly used herbicides – about 10-‐fold less herbicide per acre – because it is so toxic to plants (DEA at 31). Corn and some other grasses are less sensitive than other plants (Swarcewicz et al. 2002). Still, growers risk injuring their corn when they use isoxaflutole (US EPA 2011 at 15), particularly at high enough doses to control all weeds, and under certain environmental conditions (Wicks et al. 2000, 2007).
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a four-fold rise - Center for Food Safety

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