Central Oregon Contaminated With Unapproved Creeping Bentgrass - Comment Deadline Thursday
Please click on our comment box for Creeping Bentgrass to register disapproval for this genetically engineered grass which has already contaminated a wide swath of Eastern Oregon from the initial field trials. This is a product we do not need, it is an aggressively spread plant either through pollen or vegatatively through its rhizomes and easily crosses with many other grasses. This GE grass threatens to destroy the 3rd largest agricultural market in Oregon - our Willamette valley grass seed industry. The comment period was extended to December 2nd, this Thursday, possibly to allow the industry to catch up to the nearly 700 comments we've helped generate so far. If you are reading this, please send in your comments.
Invasion of the Franken-Grass!Oregon's first publicly acknowledged contamination by a genetically engineered organism occurs in Madras area from Roundup Herbicide resistant Creeping Bentgrass destined to be used on 17,000 golf courses in the US.
Please take action now. Demand a halt to all field trials of GE Bentgrass. Demand liability for Monsanto and Scott's company for their contamination of Oregon's agriculture, forest and grasslands. Demand that GE Bentgrass never becomes commercialized.
GE Creeping Bentgrass Comment Campaign
Right here in Oregon, experimental Round Up Ready Franken-Grass is being tested for release into the marketplace. Although an 11,000 acre buffer zone was established around this experiment, it escaped. Pollen from Monsanto's bentgrass was found up to 14 miles from the designated site, well outside of the protected area.
What does this mean?
1. We have unregulated genetically engineered grass loose in central Oregon.
2. Our states 300 million dollar grass seed industry is at risk because of cross-pollination with the Franken-Grass.
3. Our National Parks and Forests are at risk of contamination if this experiment is continued.
4. Even the land our homes are on is not safe because this genetically engineered grass can cross-pollinate with other grass varieties. Would you like to breath Round Up Ready pollen so Monsanto can make a buck?
Areas to consider when commenting
The following points are areas that APHIS is considering during this comment process. Feel free to use these questions or present any other questions you have that are not listed.
Herbicide resistance, weed management, and vegetation control. Compared to non-genetically engineered creeping bentgrass and other herbicide-tolerant grasses, will deregulation of the subject glyphosate-tolerant creeping bentgrass result in its establishment and persistence in situations where it is unwanted, unintended, or unexpected?
To what extent will deregulation of glyphosate-tolerant creeping bentgrass result in its hybridization and introgression of the herbicide-tolerance trait into related species, and will this result in their establishment and persistence in situations where they are unwanted, unintended, or unexpected?
Will attempts to manage glyphosate-tolerant creeping bentgrass or its relatives in situations where they are unwanted, unintended, or unexpected have significant adverse impacts on the quality of the human environment, including the ability to restore the land and vegetation to their intended use?
Will adoption of glyphosate-tolerant creeping bentgrass, coupled with the use of glyphosate products that might be registered for use on this bentgrass, result in the selection of weeds that are tolerant of doses of glyphosate that were previously lethal, or result in a shift to weeds that are more difficult to control? If so, what are the likely weed species, over what timeframe would selection occur, and how likely would the weeds spread to and persist in other locations? What alternatives are available to control them in situations where they are unwanted, and will those alternative control methods have significant adverse impacts on the environment?
Will adoption of glyphosate-tolerant creeping bentgrass on golf courses, coupled with the expected use of glyphosate products that might be registered to control weeds in this bentgrass, have significant benefits to the environment compared to the growth and weed management of non-glyphosate-tolerant creeping bentgrasses on golf courses?
Hybridization and introgression
In addition to the potential impacts identified above with respect to weediness and herbicide tolerance or resistance, what other significant impacts could occur to the quality of the human environment as a result of the crossing and subsequent introgression of the glyphosate-tolerance trait from glyphosate-tolerant creeping bentgrass with non-glyphosate-tolerant creeping bentgrass and certain compatible species?
Threatened and endangered species
Could there be adverse affects on a listed threatened or endangered species or its habitat, as designated under the Endangered Species Act of 1973, as amended, through the spread of glyphosate-tolerant creeping bentgrass or its relatives to areas where they are unwanted, unintended, or unexpected, e.g., riparian areas, wetlands, or grasslands, or through management of vegetation in those situations?
Will deregulation of this genetically engineered species establish a precedent for future actions with potentially significant effects or represent a decision in principle about a future consideration? Examples might include deregulation of other genetically engineered grasses, or other perennial species, particularly those that are highly outcrossing, widespread species that may also reproduce vegetatively, and which can hybridize with many wild (native or naturalized) relatives.
Can this action be said to be related to other past, present, and reasonably foreseeable future actions with individually insignificant but cumulatively potentially significant impacts, including actions that ay be taken by other agencies and individuals?
Impacts on unique geographic areas or significant scientific, cultural, or historical resources.
To what extent would deregulation impact unique geographic areas, such as prime farmlands, wetlands, parklands, or ecologically critical areas, or scientific, cultural, or historical resources, e.g., species targeted for conservation?
Are there associated with this action possible effects on the quality of the human environment that are highly uncertain or involve unique or unknown risks, including those listed above?
Can negative environmental impacts of the action be reasonably mitigated, and what is the likelihood that mitigation measures will be successfully implemented? CEQ regulations (40 CFR 1508.20) indicate that mitigation to be considered in the scope of a NEPA document can include actions or decisions that avoid, minimize, reduce, rectify, or compensate for the adverse impacts identified. The EIS will consider the stewardship plan outlined in section VII. E. of the petition, which is designed to minimize inadvertent gene flow as well as to monitor and mitigate the potential development of glyphosate-resistant weeds. The EIS will also consider other actions, e.g., deployment (release) strategies or management practices, including those that may be outside APHIS' jurisdiction, that might mitigate any adverse impacts identified, so as to alert those who may be in a position to implement them.
Comment on the GE bentgrass by December 2nd!There are three ways to comment on the bentgrass.
Postal Mail/Commercial Delivery: Please send four copies of your comment (an original and three copies) to Docket No. 03-101-2, Regulatory Analysis and Development, PPD, APHIS, Station 3C71, 4700 River Road Unit 118, Riverdale, MD 20737-1238. Please state that your comment refers to Docket No. 03-101-2.
E-mail: Address your comment to firstname.lastname@example.org. Your comment must be contained in the body of your message; do not send attached files. Please include your name and address in your message and ``Docket No. 03-101-2'' on the subject line.
Agency Web site: Go to APHIS for a form you can use to submit an e-mail comment through the APHIS Web site.
Sample comments from the Center for Food SafetyDear Sir/Madam,
I am writing in regard to Docket No. 03-101-2, the Animal and Plant Health Inspection Service's (APHIS) intent to prepare an environmental impact statement (EIS) relative to its consideration of a petition received from Monsanto Company and The Scotts Company for a determination of nonregulated status for GE creeping bentgrass. It is critical that APHIS conduct an environmental impact statement on GE creeping bentgrass, as the release of this GE organism has unique potential to negatively impact the natural environment.
I urge APHIS to consider the following points in preparation of its environmental impact statement. Creeping bentgrass is a perennial, wind-pollinated species that has potential to cross-pollinate with 12-14 wild relatives. No other commercialized genetically engineered organism is a perennial species with the potential to cross-pollinate with such a large number of wild relatives.
A recent study conducted by the EPA found evidence of "multiple instances at numerous locations of long-distance viable pollen movement from multiple source fields of GM (genetically modified) creeping bentgrass." Additionally, the study found that the bentgrass had the potential to cross-pollinate with species up to 13 miles away.
If approved for commercial release, genetically engineered bentgrass could be planted on more than 17,000 golf courses and millions of private lawns across the country. No other genetically engineered organism has been planted on small plots of public and private lands spread throughout the country. Up until now, genetically engineered organisms have been limited to farmland. Such widescale plantings virtually ensure contamination by GE bentgrass.
Genetically engineered bentgrass has been opposed by both the U.S. Forest Service and the Bureau of Land Management (BLM), because it and related species can be serious weeds, and because they would lose the ability to use Roundup, one of their best methods of weed control, to keep the GE creeping bentgrass out of national forests and BLM lands.
Thank you for your consideration of the above points in your upcoming environmental impact statement. I appreciate your commitment to conducting an EIS on this new genetically engineered organism that has such potential to negatively impact the natural environment.
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