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Date:

September 2, 2000

Subject:

End of Agriculture in the US; Precautionary Principle;

 

This appears to be an unusual listserv on the topic of urban agriculture.
Not sure if it has any connection to biotechnology or not. May be worth a
visit to the website.
------- Forwarded message follows -------

A METROFARM.COM RELEASE FROM MICHAEL OLSON...

"America, the most efficient producer of food in the world, is going out
of the business because it can no longer compete."

This Saturday morning at 9am Saturday Morning Agriculture with Michael
Olson will host a rebroadcast of its conversation with Steven Blank,
Ph.D., on his "The End of Agriculture in the American Portfolio." Blank, a
professor with the Agriculture and Resource Economics Department at UC
Davis, maintains that America simply cannot afford to participate in
high-risk, low-return industries like agriculture, and for that reason,
agricultural production in America is destined to end.

During this past year, America farmers producing apple juice concentrate,
sugar beets, processing tomatoes, Brussels sprouts, artichokes and many
other commodities have discovered that what Blank has to say is coming
true!

"America doing agriculture is a bit like a Ph.D. doing child's work-- its
a waste!" says Blank.

Topics include: If America is the most efficient producer of food in the
world, why can it no longer compete? What specific economic forces are at
work to end the production of food in the U.S? Are these economic forces
also at work in other developed nations? Which nations will produce our
food?

If you are unable to listen to the California radio stations Saturday
morning, YOU CAN LISTEN to the show streamed with a discussion group on
the radio page at www.metrofarm.com.

You can share your thoughts on this by going to
<http://metrofarm.com/discus>

Subscribe: <http://metrofarm.com>

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From: Andrew Apel
Subject: Law Enforcement

Colleagues,

Dr. Metz is absolutely correct in suggesting that law enforcement should
be the focus of the response to eco-vandals. With about 40 attacks on
biotech research over the last couple years, resulting in millions of
dollars in damage and the loss, in some instances, of more than a decade
of research, one would think that the FBI would take an interest. The
Bureau does not, though it has put a low priority on two of the attacks,
which involved Federal research facilities.

It is the Bureau's position that killing a few plants is no more serious
than the spray-painted graffiti these vandals seem so fond of.

In the estimation of law enforcement, these events (with the exception of
the arson at Michigan State) are little more than pranks.

Given the priority assigned by law enforcement, no one should be surprised
that there have been no arrests in connection with any of these attacks on
biotech research -- not a single one.

Researchers and their institutions are unwilling publicly to take a stand
and demand that law enforcement make a concerted effort to investigate
what is clearly a nationwide pattern of destruction because they fear to
attract the attention of the vandals to themselves. Some of them are so
fearful that they hesitate to disclose the nature and extent of the damage
or, in some instances, even the location of their offices.

Such is the reign of terror these vandals have established. If no one will
stand up and speak on behalf of the research community to demand that law
enforcement take these attacks seriously, and members of the research
community will not make such demands on their own, the problem will
continue.

Some suggest that giving this issue publicity would give the vandals the
publicity they crave. This is not necessarily true. When an anti-biotech
activist assaulted Canadian Prime Minister Chretien with a
"Frankencreampie," Canadians were shocked and angered, including those who
are not fond of biotechnology. They easily recognized that assault has no
credible place in the "debate" over biotechnology, and the activists lost
a good deal of credibility as a result.

Similarly, I believe the public could easily recognize that the
destruction of research and research facilities is not part of this
"debate," and I am convinced that that publicly associating eco-vandalism
with the "green" movements would inflict on those movements irreparable
harm. Look at what activism has done to PETA's credibility.

Lack of law enforcement is the problem. At the same time, researchers and
their institutions who are unwilling to stand up and demand law
enforcement are equally at fault.

>Subj: UCSD vandals non-news
>From: Matthew Metz It was noted that the
recent attack on UCSD's plant research received no media attention. While
those of us that are targeted by eco-vandals may
===================

(from ISB News Report http://www.isb.vt.edu)

THE PRECAUTIONARY PRINCIPLE: LEGAL DOCTRINE OR RORSCHACH INKBLOT TEST?

The precautionary principle may have first appeared in 1976 in the
national law of former West Germany as "Vorsorgeprinzip," a view that the
government should avoid environmental damage by cautious planning. Some
have suggested that the precautionary principle first entered
international law in the World Charter for Nature, adopted by the United
Nations General Assembly in 1982, while others point to the Ministerial
Declaration of the Second Conference on the Protection of the North Sea
(1987). The principle was clearly recognized during the U.N. Conference on
Environment and Development in Rio de Janeiro in 1992. The principle also
resides in the Treaty Establishing the European Community and can be found
in the preamble of the Cartagena Protocol on Biosafety to the Convention
on Biological Diversity (2000). But, what is the precautionary principle?

What It Is, Is . . .

According to the Commission of the European Communities, the precautionary
principle is a full-fledged, general principle of international law. This
is a significant position for the European Commission to take. Three
primary sources of international law are treaties and conventions,
customary practices, and general principles. The latter are principles
that are intrinsic to legal systems of the world, or are principles
derived from the nature of international community, such as territorial
integrity. An example of a general principle common to many national legal
systems is res judicata, which asserts that a matter is settled once a
final judgment has been made.

If the precautionary principle is a general principle of international
law, then it can be used as a subsidiary source of law to complete a
treaty. However, not all nations recognize the precautionary principle as
such. US officials, for example, have recently referred to it as the
"so-called" precautionary principle, an outlook that probably reflects the
principle's lack of a precise definition.

A Principle That Is Polysemous And Abstruse, And Yet Not Totally Cryptic

To some, the precautionary principle implies that precautions should be
taken even if a cause and effect relationship between an activity and its
potential harm to the environment, or to human health, has yet to be
scientifically established. According to one commentator, the first
documented use of the precautionary principle occurred in 1854 when Dr.
John Snow found an association, but not a causal connection, between
drinking water from a London pump and a cholera epidemic. That is, Dr.
Snow apparently decided that the potential cost of being wrong in removing
the water pump handle was likely to be much smaller than the potential
cost of not removing the handle.

The conceptual core of the precautionary principle seems to be that if a
regulatory inaction permits environmental risks that are in some way
uncertain, but non-negligible, then regulatory inaction is unjustified.
Elements woven into the principle include a willingness to take
precautions in advance of formal scientific proof, and to consider of the
cost-effectiveness of action, the intrinsic value of non-human life forms,
and concerns for future generations. An underlying mandate of the
precautionary principle is that, in the face of scientific uncertainty, a
party should refrain from actions that might harm the environment, and
that those who oppose this prohibition have the burden of proof for
assuring the safety of the proposed action.

A significant problem in implementing the precautionary principle as a
policy tool arises from the extreme variability in its interpretation,
with approaches ranging from eco-centric and risk averse to utilitarian
and risk-taking. For example, certain formulations of the precautionary
principle require that actions must be taken in advance of scientific
certainty, while others contend that deliberate inaction is not justified
by a lack of scientific certainty. Some interpretations allow cost-benefit
analysis and discretionary judgment, and yet others call for clear proof
of safety before new technologies can be adopted.

A basic unresolved question about the precautionary principle concerns the
amount of evidence (or lack thereof) needed to invoke it. Should evidence
of "likely harm" or "serious or irreversible harm" trigger the principle?
As one observer notes, the precautionary principle has deviated from a
strong mandate for precautionary action toward a universal sentiment, with
little guidance on practical implementation.

Despite the variability in its interpretation, the precautionary principle
gets a workout. For instance, France banned imports of British beef based
on the precautionary principle. Earlier this year, the German government
used the precautionary principle as the rationale for banning the
commercial scale cultivation of Bt corn by Novartis. Additional examples
include decisions by the EU to ban American and Canadian beef produced
with growth-promoting hormones, and to delay approval of genetically
engineered crops for sale in European markets.

Aside from its possible use as an excuse for trade protectionism, one
reason for the popularity of the precautionary principle is that it
reflects the current mood of distrust of technologies that are perceived
to be risky and forced on a naive public by commercial interests aligned
with governments. The precautionary principle also reflects misgivings
over perceived manipulations of cost-benefit analysis by powerful
commercial interests.

A More Certain Way To Deal With Uncertainty?

The Commission of the European Communities issued a report outlining a
definite approach for implementing the precautionary principle. At the
outset, the Commission explained that the precautionary principle
presupposes that the potential dangers of a product or process are known;
but that current scientific evaluation does not allow the risks to be
precisely determined. In the European Commission's view, action based on
the precautionary principle should be proportional to the chosen level of
protection, nondiscriminatory in application, and consistent with measures
taken under similar circumstances. Furthermore, precautionary measures
should be subject to cost-benefit analyses and reviewed in light of new
scientific evidence. The Commission also stated that, if action is deemed
necessary, the measures based on the precautionary principle should
contain the capacity to assign responsibility for producing new scientific
evidence when required for a more comprehensive risk assessment.

Certain manifestations of the precautionary principle present a challenge
to the scientifically based process of risk assessment. The European
Commission's approach, which explicitly blends precautionary measures with
scientific analysis, may well lay a foundation for the future development
of the precautionary principle. It is unclear, however, whether any
particular formulation of the precautionary principle, no matter how
balanced and well reasoned, could become accepted on an international
level.

Can One Size Fit All?

One of the prerequisites for effective implementation of a treaty that
includes a precautionary principle directive is the definitive
interpretation of the principle in terms of practical measures. Without
such interpretation, the principle would remain as a token statement of
belief. However, the perception of risk, the very trigger for invoking the
precautionary principle, varies between populations of various countries,
and between groups within a particular country. To take one example,
several studies indicate that it is the qualitative factors of risk,
rather than the magnitude of the probability of an adverse outcome, that
influence consumer acceptance of foods produced using biotechnology.

The upshot is that an implementation of the precautionary principle may
only be feasible when stakeholders collaborate at the national level to
make a decision in a particular context, trading costs against benefits,
and identifying those levels of damage deemed tolerable to that society.
In other words, the precautionary principle will be put into practice
according to the predominant national values. Since the presumption of the
precautionary approach is that a precautionary action must be taken
despite a lack of full scientific information, policy decisions must be
based upon ethical, moral, or political grounds, as well as the science.
As the European Commission notes, establishing an acceptable level of risk
for society is a political responsibility.

Both the European Commission and US officials contend that decision-making
procedures should be transparent and should involve all interested
parties. A process that treats uncertainty in an open manner, rather than
dismissing or downplaying it, may begin to address the concerns that are
fueling the popularity of the precautionary principle. In the long run,
dealing with the underlying apprehensions that have fostered the
precautionary principle may be more practical than attempting to devise a
formulation intended to fit all nations.

Sources

1. Commission of the European Communities. 2000. Communication from the
Commission on the Precautionary Principle. Available:
http://europa.eu.int/comm/dgs/health_consumer/library/pub/pub07_en.pdf 2.
Knoppers BM and Mathios A, eds. 1998. Biotechnology and the Consumer.
Kluwer Academic Publishers. 3. Lynch OJ and Maggio G. 1997. Human rights,
environment, and economic development: Existing and emerging standards in
international law and global society. Available:
http://204.127.239.82/olp3i.html 4. Kellerhals MD, Jr. 2000. U.S. Codex
Delegation Seeks Science-Based Food Safety Guidelines. Available:
http://usinfo.state.gov/topical/global/biotech/00040603.htm 5.
Raffensperger C and Tickner J, eds. 1999. Protecting Public Health and the
Environment: Implementing the Precautionary Principle. Island Press, Inc.
6. VanderZwaag, D. 1997. CEPA and the precautionary principle/approach.
Available: http://www.ec.gc.ca/cepa/ip18/e18_01.html


Phillip B. C. Jones, PhD., J.D.
Seattle, Washington
mailto:pbcj@wolfenet.com
================

NRC HOLDS WORKSHOP ON ECOLOGICAL MONITORING OF GM CROPS

The National Research Council's (NRC) Standing Committee on Biotechnology,
Food and Fiber Production, and the Environment sponsored a Workshop on
Ecological Monitoring of Genetically Modified Plants on July 13-14 in
Washington, D.C. Workshop presentations collectively described the current
state of knowledge regarding ecological effects of GM plants, limitations
of current knowledge, and potential future directions for ecological
monitoring. The workshop was attended by over 100 academics, government
officials, representatives of non-governmental organizations, and private
citizens.

The workshop included 16 presentations by individual researchers and four
panel discussions involving 18 speakers. Many speakers made multiple
points. Hence, only highlights can be presented here. Barbara Schaal
(Washington University), co-chair of the Standing Committee, introduced
the workshop by discussing the context for short- and long-term ecological
monitoring of GM plants. Paul Waggoner (Connecticut Agricultural
Experiment Station) described ongoing programs for monitoring plant
pathogens, noting relevant aspects of how to organize, finance, and
maintain effective monitoring programs. Peter Day (Rutgers University)
considered the issue of the baseline for assessing benefits and risks
posed by production of GM plants, arguing that agricultural production of
non-GM plants was the most appropriate baseline.

Allison Power (Cornell University) pointed out that most monitoring
research has focused on estimating the probability of an event as opposed
to the extent of the associated hazard. For example, concerning GM plants
expressing viral genes to achieve virus resistance, the probability of
recombination between transgenic and wild-type viruses is known to be
high, but the extent of the hazard posed is unknown, and should become the
focus of monitoring. She and several other speakers discussed the need for
designing experiments robust enough to avoid Type II experimental error,
the error of failing to detect a significant effect.

The role of ecological monitoring within a framework of adaptive
management was discussed by Anne Kapuscinski (University of Minnesota).
She suggested that results of monitoring should inform an iterative
process of public policy design and implementation. In a panel on
international perspectives on monitoring, Jeremy Sweet (National Institute
of Agricultural Botany, UK) pointed out that monitoring should address
gene flow from GM crops not only to wild relatives, but also to non-GM
crops of the same species in nearby plantings. Rob McDonald (Aventis,
Canada) noted that design of a monitoring study should be specific to the
crop, trait, environment, and event of interest. He described a concept of
product stewardship in which a company makes a commitment to realize the
benefits of GM crops in a safe and sustainable manner. Monitoring for gene
flow from GM canola to weeds using the green fluorescent protein gene as a
biomarker for pollen dispersal and gene flow was described by Neal Stewart
(University of North Carolina - Greensboro).

Presentations on the second day of the workshop addressed the role of
modeling in establishing a monitoring program, and monitoring for pest
resistance in target pests, herbicide tolerance in weeds, effects on
non-target species, and evolution of pathogen resistance. Ecological
modeler Steve Bartell (Cadmus Group) discussed use of models to determine
tradeoffs among the frequency, scale, and extent of a monitoring program,
and described the structure of a spatially explicit model of a farm using
Bt corn. Fred Gould (North Carolina State University) identified major
issues in monitoring for resistance in insect pests targeted by Bt in GM
corn, concluding that mobility of the insects affected both the desired
proportion of non-Bt refuge areas and the spatial extent of monitoring for
novel Bt resistance. Guenther Stotzky (New York University) presented
laboratory results showing slow degradation of the Bt toxin, slowed
degradation of crop residues, and no significant indirect effects of Bt
toxins on soil microbes, earthworms, or nematodes.

Two panel discussions focussed on monitoring for effects on ecological
communities and changing farm practices. Mark Lipson (Organic Farming
Research Foundation) questioned the extent of farmers' compliance with
requirements for refuge areas within Bt plantings and the reliance on
farmers to report unexpected ecological effects of GM plants. William
Hallman (Rutgers University) discussed public perception of risk posed by
GM plants and the implications for development of an effective risk
communication strategy. He pointed out that people are averse to perceived
unfairness or lack of control over their lives, and that they want their
questions answered, not to be educated about plant biotechnology.

In a wrap-up session, a panel considered criteria and priorities for
monitoring. Fred Gould pointed out that it is difficult to be sure what to
monitor a priori. Steven Duke (USDA - Agricultural Research Service)
emphasized the importance of baseline monitoring to support distinction of
what ecological effects are attributable to a GM plant and what effects
track baseline changes. Steve Bartell suggested selecting ecological
endpoints that are scaled to modeling resources, use of sensitivity
analysis to identify key uncertainties, focusing on ecological function as
well as structure, and practicing monitoring within an adaptive management
framework. Max Carter, a farmer from Georgia, noted that farmers grow GM
plants in order to realize a profit and, for purposes of establishing
criteria and priorities for monitoring, suggested gathering farmers to ask
them what they see in terms of adverse ecological effects. Key issues
identified by Barbara Schaal in her concluding remarks included questions
on post-commercialization monitoring needs, experimental design when
planning monitoring, consequences of ecological effects of GM plants, who
should monitor and who should pay for monitoring, and engaging the public
in respectful dialog.

A summary of the workshop will be published within the next several
months. A listing of NRC publications can be found by accessing
http://www.national-academies.org and clicking on "Publications."


Eric M. Hallerman
Department of Fisheries and Wildlife Sciences Virginia Tech
mailto:ehallerm@vt.edu

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Of Butterflies and Biotech
Willie Vogt, Farm Progress -- Tuesday, August 29, 2000

Biotech has its share of noisy detractors working hard to dredge up every
shred of negative information. Meanwhile the industry is doing a better
job of countering negative publicity more quickly.

Notice the response last week when an Iowa State University study showed
that again pollen from corn modified to contain Bacillus thuringiensis
(Bt) could kill the caterpillars that become monarch butterflies.
Immediately media fax machines and e-mail boxes were filled with comments
and observations countering the study.

They note that the feeding itself was conducted in the lab, not the field.
That means there were no predators around, or adverse conditions to create
a "real world" scenario. And those caterpillars were not "choice" fed.
Very young monarch larvae went into little dishes (petrie) containing
milkweed leaf samples dusted with different amounts of pollen based on
where those plants were placed in or near the corn field. Their reaction
to the exposure over a 48-hour period was measured.

This is different than the first front-page study that came out of Cornell
in 1999 where the caterpillars were exposed to milkweed leaves coated with
Bt pollen. In this latest study, the exposures happened in the field, then
the plants were brought indoors for the feeding study. This time the
researchers wanted to collect the pollen in the real world from plants
from two different Bt products - Event 176 (sold by Mycogen and Novartis)
and Bt11 (the version of YieldGard sold by Novartis). A third kind -- Cry9
(StarLink from Aventis) -- was not included.

The popular press reports don't distinguish between the different kinds of
Bt. The popular press thinks biotech corn is biotech corn -- heaven help
the ag industry as biotech corn for rootworm protection comes around. The
challenge for farmers is that these butterfly studies are in the works at
several universities and these stories will be reported and sadly enough
our industry must be able to answer the questions and challenges of
technology detractors.

The speed of the industry response to this issue was quick. Companies and
commodity group members pointed out that there was still a laboratory
component to the study. They also pointed out that the 20-study program
being carried out by a number of university in the field is showing
different results. However, there are some entomologists who say that they
are finding milkweed in cornfields, and some of them say the Monarch
butterfly likes to lay its eggs on those plants.

Those entomologists will be publishing their work in the coming years,
drawing more attention to the issue. But the detractors don't like the
light of science shined on their arguments. They don't want to acknowledge
that biotech does reduce chemical use, or alter the profile of products
sprayed to control weeds and insect pests. And the more that information
gets out the happier some consumers will be.

The biotech industry must also face up to some fears and answer questions
regarding such issues as the super weed question and the cross-pollination
problem. Of course, the crops we raise are not related to any others
species out there, so there's little chance of the creation of a super
weed. The most worrisome is canola, which can out-cross with mustard (but
2,4-D still controls mustard even if its got herbicide resistance).

Cross-pollination is a worry for organic producers who say they want to
keep biotech content out of their crops. Standard setbacks or separation
distances used in the seed industry should work fine to keep content to
near-zero levels.

Sounds simple, but the anti-biotech forces out there are painting these
products as negatively as possible. Use such resources as Rooster.com to
stay informed. Contact us if there are issues you think need more
attention. And do what you can to make sure there aren't problems even in
your local community. Remember, the hog producers who didn't their
neighbors would be a problem should have been more proactive.

Someday this will probably all blow over. But it may take a few years. If
you have comments or questions about this issue, contact Tech Talk.
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