Public Employees for Environmental Responsibility, USA (PEER)
March 1, 2010
Delaware's Bombay Hook Lacks Required Environmental Review and Justification
Washington, DC - A lawsuit filed today in federal court against the U.S. Fish & Wildlife Service seeks to compel the Service to uproot genetically engineered (GE) crops from its Bombay Hook National Wildlife Refuge in Delaware. As many as 80 other national wildlife refuges across the country now growing GE crops are vulnerable to similar suits.
Filed in the U.S. District Court for Delaware by the Widener Environmental and Natural Resources Law Clinic on behalf of Delaware Audubon Society, Public Employees for Environmental Responsibility (PEER) and the Center for Food Safety, the federal suit charges that the Fish & Wildlife Service had illegally entered into Cooperative Farming Agreements with private parties, allowing hundreds of acres to be plowed over without the environmental review required by the National Environmental Policy Act (NEPA).
In March 2009, the same groups won a similar lawsuit against GE plantings on Prime Hook National Wildlife Refuge. Ironically, Prime Hook has now been administratively incorporated into Bombay Hook, meaning that the same refuge management that is overseeing execution of the Prime Hook verdict is violating its tenets on Bombay Hook. In August 2009, several environmental groups led by the Center for Food Safety and PEER wrote a letter to Interior Secretary Ken Salazar to alert him to the implications of the Prime Hook ruling and asking him to "issue a moratorium on all GE crop cultivation in National Wildlife Refuges." Secretary Salazar has never responded.
"By definition, these refuges are to be administered to benefit wildlife, not farmers," stated PEER Counsel Christine Erickson, noting that Fish & Wildlife Service policy explicitly forbids "genetically modified agricultural crops in refuge management unless [they] determine their use is essential to accomplishing refuge purpose(s)." "GE crops serve no legitimate refuge purpose, and in fact impair the objectives for which the wildlife sanctuaries were originally established."
National wildlife refuges have allowed farming for decades to help prepare seed beds for native grasslands and provide food for migratory birds. In recent years, however, refuge farming has been converted to GE crops because that is only seed farmers can obtain. Today, the vast majority of crops grown on refuges are genetically engineered.
Yet farming on wildlife refuges often interferes with protection of wildlife and native grasses. Scientists also warn that GE crops can lead to increased pesticide use on refuges and can have other negative effects on birds, aquatic animals, and other wildlife. In the Prime Hook case, Federal District Court Chief Judge Gregory Sleet found that "it is undisputed that farming with genetically modified crops at Prime Hook poses significant environmental risks."
"Using genetically engineered crops designed to be used in conjunction with repeated applications of pesticides is a practice in direct opposition to the mission of the National Wildlife Refuges: to serve as safe havens for wildlife," said Paige Tomasilli, Staff Attorney with the Center for Food Safety. "The fact that farmers can obtain no other seeds underscores the questionable business practices of companies like Monsanto that are trying to limit farmer and consumer choice in order to sell more chemical pesticides."
"There is no question that there has been a self-serving relationship between local farmers and the refuge management over time here in Delaware, going back to when Prime Hook and Bombay Hook were first created," commented Mark Martell , President of the Delaware Audubon Society. "Farming on the Delaware refuges has resulted in surplus profits for the farmers with no tangible economic or environmental benefit to the refuges where these lands were purchased from farmers and other private landowners for their ecological significance along the Great Eastern Flyway." "The law on this is clear, and it is clear that the law has been ignored. It took local caretakers and friends of these important refuges to push for enforcement of these existing laws and changes to refuge management practices. The original lawsuit regarding these practices at Prime Hook is a game changer and it is our fervent hope that Bombay Hook and other refuges around the country take notice."
If successful, the suit would enjoin any cultivation of GE crops on Bombay Hook until environmental assessments required by the National Environmental Policy Act have been completed. Meanwhile, unless practices on the refuges change, PEER and the Center for Food Safety are preparing new suits against other refuges with GE farming programs.
By Prof. Joe Cummins
March 3, 2010
Glyphosate resistant weeds may spell the end of patented herbicide tolerant crops, but can farmers exit the transgenic treadmill that's very profitable for Monsanto?
An evolving problem
Glyphosate herbicide was patented and sold by Monsanto corporation since 1974 under the trade name and proprietary formulation Roundup. The herbicide has been used widely in agriculture, forestry, aquaculture, alongside roads and highways, and in home gardening. Glyphosate is a broad-spectrum herbicide that poisons many plant species so it is frequently used to 'burn down' weeds on a field prior to the planting or emergence of crops.
Before 1996, weeds were not observed to have evolved resistance to glyphosate in the field, but since then, the introduction of transgenic glyphosate tolerant crops has led to evolution of a number of resistant weeds as the result of the greatly increased use of the herbicide particularly during the post-emergent growth of the crops. Glyphosate reisistant Asiatic dayflower (Commelina cumminus L) common lambsquarters (Chenopodium album L) and wild buckwheat (Polygonum convolvulus L) are reported to be increasing in prominence in some agro ecosystems as are populations of horseweed (Conyza canadensis (L) Cronq) .
In regions of the USA where transgenic glyphosate resistant crops dominate, there are now evolved glyphosate-resistant populations of the economically damaging weed species Ambrosia artemissifolia (rag weed), Ambrosia trifida L.(great ragweed), palmer pigweed (Amaranthus palmeri), common water hemp (Amaranthus rudis) , rough fruit amaranth (Amaranthus tuberculatus) and various Conyza (horse weed ) and Lolium (rye grass) species.
Likewise, in areas of transgenic glyphosate resistant crops in Argentina and Brazil, there are now evolved glyphosate resistant populations of Johnson grass (Sorghum halepense) and Mexican fireplant (Euphorbia heterophylla) . These herbicide resistant weeds pose a clear threat to the transgenic crops dominating North and South America .
Can resistance be managed?
There is no simple remedy for the evolution of resistance to glyphosate. Interestingly, the inventor of both glyphosate and the herbicide tolerant crops, Monsanto Corporation, does not appear to be engaged in finding remedies for the invasion of resistant weeds. There has been an effort to remedy the invasion of resistant weeds by the academic community. Simulation modeling has been developed. Glyphosate use for weed control prior to crop emergence is associated with low risks of resistance. These models are based on assumptions that low risks can be further reduced by applying glyphosate in sequence with other broad-spectrum herbicides prior to crop seeding . Post-emergence glyphosate use, however, associated with glyphosate-tolerant crops, very significantly increases the risks of resistance evolution. Annual rotation with conventional crops reduces these risks, but the proportion of resistant populations can only be reduced to close to zero by mixing two of three post-emergence glyphosate applications with herbicides that have alternative modes of action. Weed species that are prolific seed producers with high seed bank turnover rates are most at risk of glyphosate resistance evolution. The model is especially sensitive to the initial frequency of resistance alleles, and other genetic and reproductive parameters, including weed breeding system, dominance of the resistance trait and relative fitness, influence rates of resistance. (Although these assumptions may be quite irrelevant in view of numerous physiological mechanisms of the 'fluid genome' that can produce resistant mutations in plants exposed to non-lethal levels of glyphosate, as discussed in  (GM Crops Facing Meltdown in the USA, SiS 46).
Over the past decade, the most problematic weeds in agronomic cropping systems have shifted away from perennial grass and perennial broad leaf weeds to primarily annual broadleaf weeds, although the glyphosate resistance mechanisms in weeds are currently poorly understood . It appears that post-emergent use of glyphosate may be a main contributor to evolved glyphosate resistance, but eliminating post-emergent herbicide treatment practically eliminates all the advantages of and hence the need for herbicide tolerant crops.
Evaluation of herbicide programs for the management of glyphosate-resistant waterhemp (Amaranthus rudis) in maize involved pre-emmergent application with the herbicide glufosinate followed by a post-emmergent treatment of the transgenic maize with glyphosate which controlled water hemp better than pre and post emmergent treatment with glyphosate alone .
Maize growing in the EU27 increased to over 13 million ha in 2007, most of which (>80 percent) grown in just eight countries (France, Romania, Germany, Hungary, Italy, Poland, Spain and Bulgaria). The number of herbicides used to control the wide spectrum of weeds occurring in all these countries is likely to decline in the future, and care need to be taken to manage potential weed shifts to more difficult-to-control species and to reduce the risk of selection for glyphosate-resistant weeds .
In 2002, a glyphosate resistant Johnson grass (Sorghum halepense) appeared in Argentina and now covers at least 10 000 ha. The introduction of novel genetically modified crops promoted the use of more herbicides. This in turn reinforces the emergence of herbicide-resistant weeds, constituting a new phenomenon of intensification, the "transgenic treadmill" .
Many herbicide tolerant crops become "volunteer" weeds that infest crop rotations. Those weeds complicate cultivation, contaminate crops, and enhance gene transfer to weedy relatives. A transgenically mitigated (TM), dwarf, herbicide-resistant construct using a gibberellic acid-insensitive (Deltagai) gene in the B. napus crop was effective in offsetting the risks of transgene establishment in volunteer populations of B. napus (oilseed rape) . Dwarfing the transgenic crop did not hurt yield of the oil seeds, but controlled the volunteer weeds because they were shaded by a taller crop. Mitigation by dwarfism worked well in greenhouse experiments but failed in field experiments. The proposed mitigation increased escape and persistence of transgenic weeds . An alternative mitigation strategy for transgenic rice involved the introduction of a potpourri of traits including dwarfism, non-shattering, no secondary dormancy and herbicide sensitivity .
The companies selling herbicides and herbicide tolerant transgenic crops are in no hurry to control herbicide resistant weeds; for them, the multiple herbicides used to control transgenic weeds may come as an economic blessing. It is the farmers and the rest of society that suffer.
Genetic basis of glyphosate tolerance
Glyphosate kills plants by interfering with the synthesis of the amino acids phenylalanine, tyrosine and tryptophan. It does this by inhibiting the enzyme 5-enolpyruvylshikimate-3-phosphate synthase (EPSPS), which catalyzes the reaction of shikimate-3-phosphate (S3P) and phosphoenol pyruvate to form 5-enolpyruvyl-shikimate-3-phosphate (ESP). ESP is subsequently dephosphorylated to chorismate, an essential precursor in plants for the aromatic amino acids: phenylalanine, tyrosine and tryptophan. These amino acids are used as building blocks in peptides, and to produce secondary metabolites such as folates, ubiquinones and naphthoquinone. X-ray crystallographic studies of glyphosate and EPSPS show that glyphosate functions by occupying the binding site for phosphoenol pyruvate.
Some micro-organisms have a version of 5-enolpyruvoyl-shikimate-3-phosphate synthetase (EPSPS) that is resistant to glyphosate inhibition. The version used in genetically modified crops was isolated from Agrobacterium strain CP4 (CP4 EPSPS) that was resistant to glyphosate. The CP4 EPSPS gene was engineered for plant expression by fusing the 5' end of the gene to a chloroplast transit peptide derived from the petunia EPSPS. This transit peptide was used because it had shown previously an ability to deliver bacterial EPSPS to the chloroplasts of other plants The chloroplasts of higher plants synthesize amino acids phenylalanine, tyrosine and tryptophan .
The genetic basis of many of the glyphosate resistant weeds remains unknown; but those studied in detail show that there is no single genetic alteration responsible in all of the resistant weeds. Some populations of goosegrass from Malaysia, rigid ryegrass from Australia,and Italian ryegrass from Chile exhibit target site-based resistance to glyphosate through changes at amino acid 106 of the 5-enolpyruvylshikimate-3-phosphate synthase (EPSPS) gene. Mutations change amino acid 106 from proline to either serine or threonine, resulting in an EPSPS weakly resistant to glyphosate. The moderate level of resistance is sufficient for commercial failure of the herbicide to control these plants in the field. Other mechanisms of resistance include a nontarget site resistance mechanism has been documented in glyphosate-resistant populations of horseweed and rigid ryegrass from the United States and Australia, respectively. In these resistant plants, there is reduced translocation of glyphosate to meristematic tissues. Both of these mechanisms are inherited as a single, nuclear gene trait .
EHSPS gene amplification has been found to lead to glyphosate resistance in Amaranthus palmeri populations from Georgia, in comparison with normally sensitive populations. EPSPS enzyme activity from resistant and susceptible plants was equally inhibited by glyphosate. Genomes of resistant plants contained from 5-fold to more than160-fold more copies of the EPSPS gene than did genomes of susceptible plants. Quantitative RT-PCR on cDNA revealed that EPSPS expression was positively correlated with genomic EPSPS relative copy number. The amplified genes were not clustered on the chromosomes but distributed among all of the chromosomes [15, 16]. These results suggest that the EPSPS genes were amplified through mobile genetic elements (jumping genes). Interestingly, in a laboratory experiment with alfalfa cells in culture reported eight years before the Amaranthus investigation gradual stepwise increases in glyphosate in culture medium led to gene amplification of the EPSPS gene . Another evolutionary glyphosate resistance mechanism was observed in the horse weed. The mutant weeds rapidly pumped the herbicide into vacuoles preventing contact of the herbicide with the chloroplast .
The evolution of glyphosate resistance among weeds that interfere with the productivity of crops is approaching catastrophic proportions. The evolutionary process leading to the resistant weeds has been described as a "transgenic treadmill"that renders current use of transgenic crops unsustainable. As current transgenic crops are rendered obsolete through weed resistance, the crops will be replaced with new transgenic varieties made available at higher prices to the farmers  (GM Crops Increase Herbicide Use in the United States , SiS 45) followed by another round of weed evolution to resistance. The only escape from this treadmill is to shift comprehensively to organic agriculture , as farmers have discovered in India  (Farmer Suicides and Bt Cotton Nightmare Unfolding in India, SiS 45).
References available on request
By Priscilla Jebaraj
March 6, 2010
For the first time anywhere in the world, biotech agriculture giant Monsanto has admitted that insects have developed resistance to its Bt cotton crop. Field monitoring in parts of Gujarat has discovered that the Bt crop is no longer effective against the pink bollworm pest there.
The company is advocating that Indian farmers switch to its second-generation product to delay resistance further. Monsanto's critics say that this just proves the ineffectiveness of the Bt technology, which was recently sought to be introduced in India in Bt brinjal as well.
In November 2009, Monsanto's scientists detected unusual survival of the pink bollworm pest while monitoring the Bt cotton crop in Gujarat. In January and February, samples taken from the field were tested in Monsanto's laboratories. It has been confirmed that pink bollworm is now resistant to the pest-killing protein of Bt cotton in four districts - Amreli, Bhavnagar, Junagarh and Rajkot.
Until now, Monsanto has held that "there have been no confirmed cases of poor field performance of Bt cotton or Bt corn attributable to insect resistance." Although there have been cases of insects resisting the technology in the laboratory, Monsanto held that "field resistance is the criterion of relevance to agricultural producers."
Now that the company itself has admitted that its product has been proved ineffective against some insects on the fields of Gujarat, its advice to farmers is to start using its second generation product instead. "Farmers have another choice. We have a two-gene product called Bollgard II which has greater ability to delay resistance," says Monsanto India's director of scientific affairs Rashmi Nair. She also recommends that farmers conduct better monitoring and plant "refuges", or areas of non-Bt crop which would attract insects.
Agricultural scientists and activists say Monsanto's advice is "ridiculous". The Bollgard II product has no additional toxin to combat pink bollworm, says G.V. Ramanjaneyulu of the Centre for Sustainable Agriculture. It is simply that as a newer product, Bollgard II will take longer for the pest to develop resistance. Anyway, the Bt toxin is only active for 90 days, while pink bollworm is a late season pest, he adds.
"All the hype about the effectiveness of Bt against pests is bogus ... This proves that you can't stay ahead of the pest with ... this shortsighted approach," says Kavitha Kuruganti of the Kheti Virasat Mission. Indian farmers with small holdings cannot be expected to give up large parts of their land for non- productive "refuges," added Dr. Ramanjaneyulu.
Monsanto's Dr. Nair says the Central Institute of Cotton Research (CICR) was informed about the resistance "about eight to ten days ago." The CICR, which has been collaborating in the field monitoring of Bt cotton since 2003, has reported this to the Genetic Engineering Approval Committee (GEAC), she said. However, the Ministry of Environment and Forests seems to have been unaware of the test results until Monsanto issued a statement on Friday.
Over the last month, the GEAC and the Ministry have been at the centre of a storm regarding the government's moratorium on Bt brinjal's commercial release. Critics are now pointing to the ineffectiveness of Bt cotton in Gujarat to strengthen their case against Bt brinjal as well.