TO:

United States Department of Agriculture

Tom Vilsack, Secretary, USDA

Subject: Docket No. APHIS-2012-0032; APHIS-2012-0019; APHIS-2012-0047

Dear Secretary Vilsack,

We are writing to urge you to reject applications for a new generation of genetically engineered crops designed to survive repeated spraying of the herbicides dicamba and 2,4-D.

Dow’s application to deregulate 2,4-D corn is the first of 13 genetically engineered crops in the pipeline for USDA approval. It is on your desk now, and Monsanto’s application for dicamba-resistant soy — along with Dow’s 2,4-D soy — is not far behind.

Simply put, these herbicide resistant seeds are a bad idea. Allowing them on the market will drive up use of antiquated, dangerous herbicides that are associated with cancer, reproductive toxicity and endocrine disruption.

The dramatic rise in glyphosate use in conjunction with RoundUp Ready crops tells us that widespread planting of herbicide resistant seed — like 2,4-D corn and dicamba soybeans — will inevitably lead to a surge in the application of these hazardous herbicides.

Since both 2,4-D and dicamba are known to drift — directly and through volatilization — increased use poses a very real threat to rural economies and farmers growing crops not engineered to withstand application of these potent chemicals. Conventional farmers could  lose crops, while organic farmers could lose both crops and certification, resulting in an economic unraveling of already-stressed rural communities.

Dicamba and 2,4-D resistant crops follow the same short-sighted approach to farming taken by Monsanto's RoundUp Ready seed line. The RoundUp Ready seed line is responsible for a dramatic rise in glyphosate-resistant “superweeds” that have afflicted millions of acres of farmland across the Midwest and South. Please don't make the same mistake in approving a new generation of herbicide-resistant crops that will lead to more superweeds, placing even more burden on farmers.

We urge USDA to reject Dow’s petition for approval of its 2,4-D resistant seed line, and Monsanto's dicamba-resistant soybean that is next in line. And we call on your Agency to instead devote more attention to research and development of safe and smart 21st century ecological approaches to weed management. These approaches can protect public health, conserve the environment and assure sustainable crop production by America’s farmers for generations to come.

Sincerely,

PAN North America