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Comments to the EPA must be
received by November 28

By mail to:
Public Information and Records Integrity Branch (PIRIB) (7502C),
Office of Pesticide Programs (OPP),
Environmental Protection Agency,
1200 Pennsylvania Ave., NW.

Please enter your information below, and modify the sample letter as you wish. Items in bold are required.

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Public Information and Records Integrity Branch (PIRIB) (7502C) Office of Pesticide Programs (OPP) Environmental Protection Agency 1200 Pennsylvania Ave., NW. To whom it May Concern, Re: Docket ID Number OPP-2003-0274 I am writing in reference to EPA's final rule in response to Bayer CropScience's August 15th petition to establish a tolerance for Glufosinate in or on Rice and Cotton. I believe that by approving the residues requested by Bayer you will be exposing the public to unnecessary health risks, potentially increasing use of toxic herbicides on rice and cotton, and endangering the livelihoods of farmers by shutting off valuable export markets that are rejecting transgenic crops. I am concerned about the loss of overseas markets for farmers growing transgenic crops and for farmers whose own ability to market their crops is threatened by genetic pollution. Many countries throughout the world are refusing transgenic crops and USDA organic standards strictly prohibit the use of transgenic seeds. Glufosinate tolerance levels have not been established by the international food standards commission, Codex Alimentarius. Events such as StarLink and last year's ProdiGene incident highlight the inadequacies of our current system in keeping transgenic crops segregated. In Canada, farmers growing transgenic crops have detected triple herbicide resistance in weeds and volunteer canola plants as a result of gene transfer, rendering the herbicides useless. If Bayer's petition is approved, it will only be a matter of time before Red Rice, which is the same species as cultivated rice and also one of the most virulent weeds on rice farms, becomes resistant to Glufosinate. Similar gene transfer in rice will lead to the need for new, more toxic herbicides. Peer-reviewed scientific studies have shown Glufosinate to be "highly toxic" to aquatic animals such as clams, oysters, water fleas, fish and birds at doses as low as 0.5 ppm. As rice is grown in an aquatic environment, the adoption of Glufosinate tolerant rice will have tragic impacts for the ecosystems of rice growing areas. The EPA classifies Glufosinate as "persistent" and it has been found in the edible parts of spinach, wheat and radishes more than 120 days after being sprayed with the chemical. The approval of Glufosinate tolerant rice and cotton will send us a step backward in our efforts toward a more sustainable agriculture. Please take action to ensure that our current system of agriculture moves toward one that is less reliant on chemicals, and ensures our farmers a prosperous livelihood. I strongly urge you to deny Bayer's request for approval of Glufosinate tolerance and to work with other government agencies to enact a more rigorous approval and testing process for transgenic crops. Please reconsider your ruling. Sincerely,

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