To:  EPA Office of Pesticide Programs
Re:  Docket Number OPP-00678B
Dear EPA Administrator Whitman:

I am writing to express my opposition to the EPA's re-registration of three Bt crops--Bt corn, cotton, and potatoes.  There should be a moratorium on all Genetically Engineered (GE) foods until long-term studies show that these crops are safe for human health and the environment.  Continued registration of these Bt crops ignores evidence of their potential for serious harm.

Bt crops:

* Pose unacceptable risks to butterflies such as monarchs and the endangered Karner Blue.  Monarchs in states such as Minnesota and Iowa are exposed to Bt corn pollen right at the time of their peak migration to Mexico. Insufficient scientific studies have been carried out to show that Bt corn doesn't pose a threat to endangered butterflies like the Karner Blue.

* Threaten human health with the potential to cause allergic reactions. One Bt crop--StarLink corn--has already been withdrawn from the market because of its allergenic potential. New research shows that Bt cotton also contains a protein that affects the immune system. Consumers shouldn't be the guinea pigs to see if Bt corn (in particular Bt sweet corn) is also allergenic.

* Contaminate organic crops as well as conventional non-GE fields. Organic and non-GE corn farmers have lost valuable markets because of contamination.  GE corn and non-GE corn cannot coexist in the same region because of the potential for corn pollen to travel in the wind.  The EPA's analysis has not considered the significant economic impacts of Bt corn on the organic and non-GE farm sectors.

* Will inevitably lead to the loss of Bt for organic pest control.  The resistance management plans EPA is proposing are fatally flawed, because a number of assumptions they rely on are invalid.  For example, grower compliance with Bt guidelines is not 100%. In addition, neither Bt cotton nor Bt corn contain a high enough dose to be effective against cotton bollworm/corn earworm.

* Pose other potential environmental consequences for agricultural and natural ecosystems.  Bt crops have potential effects on soil organisms and natural enemies of crop pests.  Pollen from Bt crops, in particular Bt corn and Bt cotton, can flow to wild and weedy relatives, with potential long-term ecological consequences.  The most important of these wild relatives in North America is teosinte, a close relative of corn.  Growing of Bt corn in the US poses a significant threat to this important reservoir of corn genetic diversity.

The EPA should act to protect consumers and the environment by denying the re-registration of these crops. Thank you.