Subject: Docket No. APHIS–2010–0103

Your Letter: I am writing to urge you not to approve Dow’s genetically engineered corn (DAS-40278-9) designed to survive repeated spraying of the toxic herbicide 2,4-D (Docket No. APHIS–2010–0103). As you know, it was a major component of Agent Orange, the chemical defoliant used by the U.S. military in Vietnam. The scientific community has sounded alarms about the dangers of 2,4-D for decades. Numerous studies link 2,4-D exposure to cancer, lowered sperm counts, liver toxicity and Parkinson’s disease. Laboratory studies show that 2,4-D causes endocrine disruption, reproductive problems, neurotoxicity, and immunosuppression. Industry tests show that 2,4-D is contaminated with dioxins—often referred to the most toxic substance known to science. They are implicated as a major cause of many serious medical conditions in both Vietnam veterans and the Vietnamese, including birth defects in the children of exposed parents. EPA has reported that 2,4-D is the seventh largest source of dioxins in the U.S. Commercial approval of Dow’s corn will trigger a large increase in 2,4-D use, yet USDA has failed to conduct a meaningful review of the consequent harm to native ecosystems, crop injury from 2,4-D drifting onto neighboring fields, or the evolution of weeds resistant to 2,4-D. Even the existing uses of 2,4-D have been found likely to jeopardize protected species such as Pacific salmon. USDA’s proposed unrestricted approval of 2,4-D corn would worsen these impacts, as well as place many other similar and endangered species at risk. Yet USDA has refused to account for these adverse impacts. Ironically, Dow is hyping 2,4-D corn as the solution to glyphosate-resistant weeds, which themselves were fostered by GE Roundup Ready crop systems. Yet, studies already indicate this approach will rapidly generate weeds with resistance to both herbicides. As companies develop new crops resistant to a growing list of multiple herbicides, weeds will evolve multiple resistances, and farmers will respond with increasingly toxic herbicidal cocktails. This chemical arms race with weeds means more pesticidal pollution, more disease, higher production costs, and of course increasing profits for firms like Dow that sell both GE seeds and the pesticides used with them. At a time when more and more people are demanding healthy foods produced in a sustainable manner, approval of this crop would take us dramatically backwards, endangering human health and the environment by sharply increasing use of toxic pesticides. I urge you to heed the warnings of the scientific and environmental communities and deny approval of 2,4-D resistant GE corn. Sincerely,