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HomeMy WebLinkAboutCOM 0271.156 2012-2014 Margaret Wille ��<r.o.,:• Phone No. Hilo: (808)961-8027 Council Member :cR•'�� �.,'.. Phone No. Waimea: (808)887-2043 District 9-North and South Kohala "" ���` ; Fax No.: (808)887-2072 •��� • � �•; E-Mail: mwille @co.hawaii.hi.us HAWAII COUNTY COUNCIL County of Hawai Hawaii County Building Holomua Center West Hawaii Civic Center Bldg.A 25 Aupuni Street 64-1067 Mamalahoa Highway,Suite C-5 74-5044 Ane Keohokalole Hwy. Hilo, Hawaii 96720 Waimea, Hawaii 96743 Kailua-Kona, Hawaii,96740 o n CZ; d t7 r- <-1 11 C) �-frTl V• TO: J Yoshimoto, Chair `o — and Members of the Hawai`i Count uncil FROM: Margaret Wille, Council Member DATE: July 2, 2013 SUBJECT: Testimony regarding Bill 79 Please find attached a copy of testimony dated July 1, 2013 from Dr. Martha L.Crouch, Ph.D.Biology. She was unable to email her testimony yesterday due to the County's mailbox being over quota. Thank you. MW/dh att Comm.No. ,21/. /.r& Ref.To:, P(PS Al TG Ref.Date JUL 0 2 2013 Serving the Interests of the People of Our Island Hawai`i County Is An Equal Opportunity Provider And Employer July 1, 2013 To: Office of the County Clerk, Hawaii counciitestimony @co.hawaii.hi.us From: Martha L. Crouch, Ph.D. Biology 824 W 8th St Bloomington, IN 47404 marticrouch @sbcglobal.net Regarding: Bill No. 79 - AN ORDINANCE AMENDING CHAPTER 14 OF THE HAWAII COUNTY CODE 1983 (2005 EDITION,AS AMENDED), BY ADDING A NEW ARTICLE RELATING TO PROHIBITION OF GENETICALLY MODIFIED ORGANISMS. Thank you for the opportunity to provide testimony on this bill. I am an expert on impacts of biotechnology related to agriculture, and also a frequent visitor to Hawaii county since 1983. I am submitting these comments on my own behalf. By supporting Bill No. 79, Hawaii council members have an opportunity to protect the environment of Hawaii county,while promoting a diverse and valuable future for agriculture. Overview Most genetically engineered (GE) crops grown today and in the pipelines of biotechnology companies in the near future are resistant to herbicides. These pose hazards related to increased use of herbicides, including some that are highly volatile or"restricted use"because of known hazards. Also,the engineered genes from GE crops (transgenes) can move into some wild species, such as native cotton, with negative consequences for conservation and culture. Transgenes can also contaminate non-GE crops, reducing their value. Experience with GE crops on the mainland and elsewhere has shown that coexistence between GE and non-GE crops is extremely difficult. Pesticides used with GE crops move into surrounding air, water and land, potentially harming wild organisms, non-GE crops, and human health. Transgenes end up in organic and non-GE seed stocks and fields, and can persist in feral crop plants and in wild relatives of crops. GE exclusion zones offer the most effective remedy,where certain growing regions are off limits for GE crop production in order to protect non-GE agriculture and nature. In many places, it is difficult to create such geographically isolated areas for non-GE agriculture. There is still an opportunity to do so in Hawaii county,for the benefit of the land and people,by adopting Bill No. 79. 1 Comments, including scientific studies Scientific studies are cited in the comments.The studies are listed in "references" at the end, and either submitted separately as pdf files or have web links. The studies support my comments on the following topics: 1. Native Hawaiian cotton and risks of transgenic contamination 2. Herbicide-resistant crops, present and future impacts 3. Importance of GE exclusion zone in Hawaii to reduce impacts of GE crops 1. Bill No. 79 would prevent transgenic contamination of native Hawaiian cotton in Hawaii county The Hawaiian islands are home to a native species of wild cotton, Gossypium tomentosum, or Ma'o,thought to have evolved on the islands about a million years ago, and found no where else. It has been used by Hawaiians to make a green dye for kapa cloth. Cultivated cotton species (Gossypium barbadense and Gossypium hirsutum) originally from the Americas can interbreed with Ma'o,so it is possible that transgenes could contaminate Ma'o via crosspollination if GE cotton is grown in the vicinity. Recent research on pollination of Ma'o shows that bees, including honeybees, come to the flowers for nectar and can facilitate crosspollination (Pleasants and Wendel 2010). Honeybees are known to move pollen about 5 miles from one flower to another, although pollination distances vary with conditions. Less is known about pollination distances with other pollinators. Cotton is not grown commercially for fiber in Hawaii at this time. However, according to Pleasants and Wendel (2010), GE cotton is grown in Hawaii by seed companies as part of their breeding programs,presumably on islands other than Hawaii. USDA keeps track of GE field tests and publishes what species are tested in which states, including general information about the types of transgenes.Through 2009, GE cotton was grown in field tests in Hawaii, mainly by Syngenta (http:j/www.ish vt.edu/search-release-data.aspx), and tests included traits for herbicide and pest resistance.Although no field tests of GE cotton in Hawaii are currently listed in USDA databases,they could resume in the future. If GE cotton varieties that have already been deregulated by USDA are planted by seed companies on Hawaii,the public has no way of tracking those. Cotton was grown commercially in Hawaii in the past,with plantations near Kailua in Hawaii county, and some of the cotton plants "escaped" to form feral populations that persist to this day. I have seen feral Gossypium barbadense populations near Kawaihae harbor,visible from the highway, for example. 2 I have also seen Ma'o in Hawaii county, although not forming wild populations yet. It is being grown at historical sites such as Lapakahi, north of Kawaihae; Pu'uhonua o Honaunau and Amy Greenwell Gardens,south of Kona; and also as horticultural plantings on the west side of the island. There may be other locations where Ma'o is grown,too. If GE crops are allowed to be grown in Hawaii county, at some point it is possible that GE cotton will be grown, either for breeding and field testing by seed companies that may move to Hawaii county; or for fiber,perhaps on a small scale. There are currently approved GE varieties that are resistant to glyphosate (Roundup Ready) or glufosinate (Liberty Link) herbicides, and that are resistant to insect pests (various Bt traits). New GE traits are also being developed for cotton. For example, Monsanto has engineered cotton to be resistant to the herbicide dicamba, and this cotton is going through the regulatory process for commercial release right now (see comments to EPA from Center for Food Safety on impacts of dicamba use on GE cotton: CFS 2012 dicamba cotton,http://www.centerforfoodsafety.org/files/cfs- science-comments-on-dicamba-use-registration-for-cotton-date- corrected_45293.pdf). Hawaii county has lots of honeybees and other pollinators, and if GE cotton is grown within —5 miles of either feral commercial cotton or Ma'o, hybrids could form that would carry transgenes. These transgenes could then become established in wild Gossypium barbadense populations and persist indefinitely. Hybrid seeds containing transgenes could also form on Ma'o plants that were pollinated either by GE cotton directly or via transgenic feral plants at some future time, and eventually become part of a Ma'o population. Without specific testing for transgenes, contamination would go undetected,because there would be no way to tell just by looking. There are other examples of transgenic contamination of feral or wild relatives of GE crops. Experimental glyphosate-resistant alfalfa contaminated non-GE alfalfa seed stocks in western North America (Jenkins 2007). Feral canola populations with GE glyphosate resistance have established around the world,wherever GE canola is grown (CFS 2013 Oregon canola). GE glyphosate-resistant bentgrass has spread miles beyond field test sites in western North America, and has even formed hybrids with wild species in different genera, spreading the transgene to other wild grasses (Snow 2012).And of course, in Hawaii you are familiar with the widespread transgenic contamination of feral papaya, along with non-GE cultivated papaya (Bondera and Query 2006) Transgenes have already contaminated wild cotton populations in Mexico (Wegier et al. 2011, Hurtado 2011), the place of origin of Gossypium hirsutum that is the major cotton variety grown throughout the world today. Within 15 years of growing GE cotton in Mexico, transgenic contamination has spread through wild cotton populations for hundreds of miles, and includes almost all the traits from commercial GE cotton. These wild cotton plants have crossed with each other resulting in new combinations of herbicide, insect and antibiotic resistance traits. In 3 other words,they have "stacked"transgenes into novel combinations,without human intervention. In Hawaii, as in Mexico,wild native cotton species provide reservoirs of genetic diversity that are used by plant breeders for new pest resistance or other qualities in commercial crops. The native species are often culturally significant, as well. Thus their genetic integrity and diversity needs to be protected. Even though Hawaii county is not part of the original distribution of wild Ma'o (Stephens 1964), it is being cultivated in Hawaii county now, and more could be planted in suitable habitats. Particularly since GE cotton is being grown on other Hawaiian islands, it is important that there be some refuge for Ma'o from transgenic contamination. Adopting Bill No. 79 would provide such a place of refuge for native Hawaiian cotton. 2. Herbicide-resistant GE crops would expose the land and people of Hawaii to higher levels of toxic chemicals Impacts of current glyphosate-resistant crops Most of the GE crops planted in the US are engineered to be resistant to the herbicide glyphosate (see discussion of history of glyphosate-resistant crops in: CFS 2012 2,4-D soybean, CFS 2012 dicamba cotton, CFS 2012 Oregon canola), the active ingredient in Monsanto's Roundup brand. These Roundup Ready soybeans, corn, cotton, sugar beets and alfalfa can be sprayed with glyphosate-based herbicides over the top of the crop to kill weeds within the field during the growing season. Many conventional farmers have found that growing glyphosate-resistant crops simplifies their weed management, and have chosen to pay the higher seed prices for these varieties even though, on average,yields are not higher than for similar non-GE varieties (Gurian-Sherman 2009).As a result, more herbicide is used per acre and later in the season than before GE crops were adopted (Benbrook 2012). Now, 17 years after the first Roundup Ready soybeans were planted, the negative consequences of widespread planting of these herbicide-resistant crops are becoming more apparent. The simplified weed management of using a single herbicide later in the growing season,year after year, and in subsequent rotations has resulted in an epidemic of glyphosate-resistant weeds (for extensive discussion of resistant weeds, see CFS 2012 2,4-D soybean, CFS 2012 dicamba cotton, CFS 2012 Oregon canola). Although weeds have always developed resistance to widely used herbicides -the first known case of weed resistance occurred in honohono grass in response to 2,4-D use on Hawaiian sugar cane in 1957 -there is no doubt that adoption of herbicide-resistant crops has accelerated that process.As a result,growers now use higher rates of glyphosate more often and in addition to other herbicides,with a greater risk of 4 these herbicides contaminating the environment. Some farmers also till more often now to control resistant weeds,with increasing soil erosion risks. Glyphosate now contaminates the air and water in areas where glyphosate-resistant crops are grown,with unknown consequences to animals and people Glyphosate-based herbicides are found frequently in surface waters In 2002,the US Geological Survey (USGS) began a monitoring program for glyphosate and its main degradation product,AMPA, in Midwestern streams because of increasing glyphosate use on GE crops. Glyphosate was detected in about a third of the streams sampled, after rain events following pre-emergence, post- emergence and harvest seasons (Battaglin et al. 2005). In follow-up studies, Battaglin and his colleagues (Battaglin et al. 2009) observed vernal pools and streams near herbicide application sites in National Parks. Overall,glyphosate was measured in 32% of samples,but 87% of the samples taken from ponds and streams near applications contained glyphosate. One of the vernal pools (Riley Spring Pond) had over 300 ug/1 glyphosate after nearby applications, showing that vernal pools are vulnerable to significant contamination. In spite of the reported strong sorption to soil, glyphosate is commonly found in surface water where Roundup Ready crops are grown, not just in vernal pools. The most recent USGS studies designed to measure the impacts of Roundup Ready cropping systems on glyphosate levels in surface waters (Coupe et al. 2011) found glyphosate in 59% (SFIR New Providence site in Iowa), 72% (SFIR Blairsburg site in Iowa), and 100% (three sites in the Bogue Phalia basin in Mississippi) of samples taken every 1 to 2 weeks over two years from streams and subsurface drains. Researchers concluded that more water samples in Mississippi contained glyphosate than in Iowa because "Mississippi has nearly a continuous application of glyphosate for 9 months,whereas glyphosate applications in Iowa are limited to a few months in spring and summer." Applications in Hawaii would be similar to those in Mississippi. The highest water concentrations of glyphosate occurred in samples taken after applications, during periods of high rainfall,which were not unlikely events. They conclude: "These data suggest that glyphosate will be detected in surface water in agricultural basins where it is used", and that concentrations will be determined by the amount of glyphosate applied relative to the size of the basin, water pathway characteristics, and weather patterns - factors that change from year to year. Hawaii county has unique soil characteristics,water pathways and weather patterns that have not been studied in relation to glyphosate movement, making it difficult to predict exactly how much pollution would occur from herbicide use on GE crops. 5 Glyphosate-based herbicides are found in air and rain Even though glyphosate is not volatile, it moves off-site via air and in rainfall at about the same frequency and at higher concentrations compared to other herbicides that are more volatile because glyphosate is used so much in Roundup Ready cropping systems (Chang et al. 201.1). In this USGS study,glyphosate was measured in air and rain samples,weekly, during 2 growing seasons in the same areas sampled for surface water contamination by Coupe et al. (2011). They were surprised to detect glyphosate in 60-100% of samples: "The detection frequency and median concentrations of glyphosate in both air and rain were not substantially different compared with other current-use herbicides, but maximum glyphosate concentrations were greater." (p. 551) "These results are somewhat surprising insofar as the other herbicides are more volatile than glyphosate. The relatively elevated levels of glyphosate probably are due to its frequent use in these agricultural areas in conjunction with the genetically modified crops." (p. 552) Glyphosate gets into the air from spray drift and wind erosion of soil-bound glyphosate (p. 553), and then comes down later- sometimes after weeks - in rain, indicating that some portion was in small enough droplets to remain airborne. The amount of glyphosate taken out of the air in rain is substantial, given the large amount of glyphosate applied to Roundup Ready crops, and must contribute to surface water contamination, in addition to glyphosate from other sources. Glyphosate is found in urine samples of almost everyone living in Iowa, at ten times higher levels than in Europeans Not only is glyphosate found in the environment after applications to GE crops, it is also found inside of people. Studies in Iowa found glyphosate in the urine of almost everyone tested,whether they lived on farms or not (Curwin et al. 2007). Are levels of glyphosate higher inside people in states like Iowa where most crops are Roundup Ready, than in regions where less glyphosate is used? There have been few surveys of glyphosate residues in people. However, a recent survey in Europe, where Roundup Ready crops are not grown, showed that glyphosate was detected in 10 to 90% of urine samples, depending on the country, and at ten times lower levels than the average for people in Iowa (FOE 2013). Impacts of higher glyphosate levels in water and air, and inside humans is unknown: precaution is thus advised Some animals particularly sensitive to glyphosate-based herbicides, such as amphibians, can be harmed by herbicide levels found in the environment (Relyea 2011). Specific sensitivity of Hawaii's unique animals to these herbicides is largely unknown. For example, increased levels of glyphosate bound to soil particles or 6 dissolved in water, and washed onto reefs, may affect sensitive organisms and damage reef ecology in ways that have not been studied. Higher levels of glyphosate in urine of people living in states with widespread adoption of Roundup Ready crops indicates higher exposure to glyphosate-based herbicides, and much is still unknown about health consequences. For example, EPA has not yet completed studies to determine if glyphosate is an endocrine disrupting chemical. Drift from glyphosate used in GE crops injures non-GE crops and wild plants during sensitive periods of their development Harm to plants from increased glyphosate use with GE crops is likely to occur, because glyphosate is highly toxic to almost all plants. Researchers at EPA used the detailed pesticide usage information, crop location maps, and developmental timetables for specific crops for Fresno County, CA,to model likelihood of injury to crops from glyphosate use (Lee et al. 2005). They found (p. 3): "Glyphosate is not as damaging to sensitive crops as 2,4-D and dicamba and other potential high risk herbicides but has greater potential to damage sensitive crops due to spray drift because it is applied throughout the year in large quantities." Confirming that glyphosate drift is particularly damaging to plants at their reproductive stages, they state (p. 32): "The likelihood of drift damage to sensitive crops depends upon when,where and how the herbicide was applied in relation to the time of increased plant sensitivity and proximity of the nontarget crop. For most crop species, the time of increased sensitivity occurs at or prior to anthesis [pollen shed]." This sensitive period means that usage patterns for Roundup Ready crops are more likely to cause injury to non-target plants than former burndown applications. Often, injury from glyphosate is not detected until the harmed crop is harvested and low yields are seen. For example,glyphosate drift onto rice plants may cause male- sterility and thus low pollination and seed set,but few other symptoms (Wagner 2011). So in spite of the non-volatile nature of glyphosate and label restrictions on application rate, droplet size, wind speed, equipment set up; drift injury does happen, and will impact growers of non-GE glyphosate-resistant crops. Glyphosate injuries are of particular importance for populations of threatened and endangered species If threatened or endangered plants are found near Roundup Ready crop fields, farmers are supposed to take special measures to limit herbicide drift.Again, however, given the cryptic nature of important sub-lethal glyphosate effects and variations in sensitivity between species under different conditions, such measures may not be adequate to protect the plants. 7 With 377 federally listed species, Hawaii has a greater concentration of threatened and endangered organisms than any place in the world,with many in Hawaii county. Most of these listed species are plants, and thus inherently susceptible to injury by herbicides. Threatened and endangered animals that depend of particular plants for their survival may suffer from injury to their habitats. Example of threat to wildlife: Monarch butterflies in steep decline as habitat destroyed by glyphosate use in GE glyphosate-resistant crops An example of harm to biodiversity from an herbicide-resistant crop system is the recent decline in milkweed populations in Midwestern fields with probable impacts on monarch butterflies,as described in a series of studies (Brower et al. 2010, Brower et al. 2011, Pleasants and Oberhauser 2012).The basic conclusions are well stated in the abstract of Pleasants and Oberhauser (2012): Abstract. 1. The size of the Mexican overwintering population of monarch butterflies has decreased over the last decade.Approximately half of these butterflies come from the U.S. Midwest where larvae feed on common milkweed. There has been a large decline in milkweed in agricultural fields in the Midwest over the last decade. This loss is coincident with the increased use of glyphosate herbicide in conjunction with increased planting of genetically modified (GM) glyphosate-tolerant corn (maize) and soybeans (soya). 2. We investigate whether the decline in the size of the overwintering population can be attributed to a decline in monarch production owing to a loss of milkweeds in agricultural fields in the Midwest.We estimate Midwest annual monarch production using data on the number of monarch eggs per milkweed plant for milkweeds in different habitats,the density of milkweeds in different habitats, and the area occupied by those habitats on the landscape. 3.We estimate that there has been a 58% decline in milkweeds on the Midwest landscape and an 81% decline in monarch production in the Midwest from 1999 to 2010. Monarch production in the Midwest each year was positively correlated with the size of the subsequent overwintering population in Mexico. Taken together,these results strongly suggest that a loss of agricultural milkweeds is a major contributor to the decline in the monarch population. 4.The smaller monarch population size that has become the norm will make the species more vulnerable to other conservation threats. Since this study was published, monarch butterfly populations have declined to their lowest level ever, as habitat continues to decline from loss of milkweeds (Journey North 2013). 8 Here, 17 years after the introduction of Roundup Ready crops, major impacts of associated herbicide use are just now surfacing,with only a handful of researchers doing this kind of"post-market" ecological research. Impacts of future herbicide-resistant GE crops More herbicide-resistant crops about to be commercialized, including crops resistant to volatile herbicides, and to a restricted-use herbicide The agricultural biotechnology industry has been busy creating new herbicide- resistant GE crops on the Roundup Ready model, partly in response to the epidemic of resistant weeds spawned by glyphosate-resistant crops, and also to reap the exceptional profits that come from packaging GE seeds with proprietary herbicides. At the moment, there are over a dozen new herbicide-resistant crops awaiting regulatory approval from USDA (http://www.aphis.usda.gov/biotechnology/not_reg.html). These include corn, soybeans, cotton and canola resistant to volatile herbicides, such as 2,4-D (CFS 2012. 2,4-D soybean) and dicamba (CFS 2012 dicamba cotton); a restricted use herbicide, isoxaflutole, suspected of being a human carcinogen and highly mobile in water (CFS 2012 isoxaflutole soybean); an herbicide on the list to have its registration retired in Europe, glufosinate (CFS 2013 glufosinate maize); and others. Companies are already cross-licensing traits to each other, even before the crops have been approved, and are stacking resistance traits in various combinations so that herbicides will be used together. Many of these herbicides will be used in addition to glyphosate, rather than replacing it. The total use of herbicides associated with these new resistant crops is expected to increase dramatically, multiplying the types of harms to the land and people that I discussed for glyphosate (see the CFS comments cited above for detailed analyses of increased herbicide use and risks). So far,the federal government through EPA and USDA has not shown leadership in addressing the special risks posed by these herbicide-resistant crops and the pesticide treadmill their use causes. Co-existence is difficult: GE-free zones are necessary to protect land and people Coexistence... refers to the concurrent cultivation of conventional, organic, IP [Identity Preserved], and genetically engineered(GE) crops consistent with underlying consumer preferences and farmer choices. (USDA AC21 2012) 9 In my opinion, it is very difficult for GE crops to co-exist with other types of agriculture and with nature. The increased use of herbicides later in the growing season with herbicide-resistant crops puts non-resistant crops and nature at higher risk of harm, and even with extra effort by pesticide applicators, off-site herbicide movement is inevitable. Transgenes from some GE crops pose contamination risks for non-GE farmers, reducing their market opportunities. Wild relatives of GE crops can also be at risk of transgenic contamination,with negative impacts for conservation and cultural values.Although growers can take measures to try to reduce transgenic contamination, the vagaries of weather, uncertainties of pollinator behavior, unknown locations of feral plants, and ever-present human error conspire to ensure gene flow regardless (Marvier and VanAcker 2005). In many cases, the only viable way to allow all kinds of agriculture to exist is to separate them physically, for example,by declaring some regions to be "GE-crop free". There was recently such a zone excluding GE canola in the Willamette Valley of Oregon,because no canola,whether GE or not,was allowed for oilseed production within the Valley. This "canola control area" established by the Oregon Department of Agriculture (ODA) functioned to protect the important industry in vegetable seed and other specialty seed crops from transgenic contamination, but has been recently redefined by ODA in order to allow some "coexistence" of canola for biofuels and edible oil with seed crops. Specialty seed growers in the Valley are fighting to keep the original exclusion zone with specific legislation and lawsuits. The details of the need for an exclusion zone to allow non-GE vegetable seed crops to maintain their markets, and to prevent glyphosate-resistant weeds are discussed at length in CFS comments to the Oregon Department of Agriculture (CFS 2013. Oregon canola). These arguments equally apply to Bill No. 79, and show that by excluding new GE crops from Hawaii county, a diverse and productive agriculture can thrive. Conclusion Hawaii county can best protect its land and people from potential harms of increased glyphosate and other herbicide use, and transgenic contamination of non- GE crops and wild cotton, by adopting Bill No. 79 to prevent planting of GE herbicide-resistant crops. References cited Battaglin, W.A., Kolpin D.W., Scribner E.A., Kuivila K.M., Sandstrom M.W. (2005) Glyphosate, Other Herbicides,and Transformation Products in Midwestern Streams, 2002. Journal of the American Water Resources Association (JAWRA) 41(2):323-332. 10 Battaglin W.A., Rice K.C., Focazio M.J., Salmons S., Barry R.X. (2009) The occurrence of glyphosate, atrazine, and other pesticides in vernal pools and adjacent streams in Washington, DC, Maryland, Iowa, and Wyoming, 2005-2006. Environmental Monitoring and Assessment 155:281-307. 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CFS 2012 dicamba cotton: Center for Food Safety comments to EPA on Application to Register New Use of Dicamba on Dicamba and Glufosinate Resistant MON 87701 Cotton, and to Establish Tolerances for Residues of Dicamba in Cottonseed and Cotton Gin Byproducts; http://www.centerforfoodsafety.org/files/cfs-science-comments-on- dicamba-use-registration-for-cotton-date-corrected_45293.pdf CFS 2012 2,4-D soybean: Center for Food Safety Comments to USDA APHIS on Draft Environmental Assessment and Draft Plant Pest Risk Assessment for Dow AgroSciences Petition (09-349-01p) for Determination of Nonregulated Status of Event DAS-68416-4: 2,4-D-and glufosinate-resistant soybean. http://www.centerforfoodsafety.org/files/cfs-24-d-soy-science-comments- final-9-11-12_11171.pdf CFS 2012 isoxaflutole soybean: Center for Food Safety comments to USDA opposing deregulation of Bayer's isoxaflutole-resistant soybean; http://www.centerforfoodsafety.org/files/bayer-fg72-soy-cfs-science- comments-9-11-12.pdf 11 CFS 2013 Oregon canola: Center for Food Saftery Comments on Proposed Rule that "Amends control area and regulations for growing Brassica spp. and Raphanus spp. in Willamette Valley", Center for Food Safety. http://www.centerforfoodsafety.org/files/cfs-canola-science-comments-to- oda-jan-2013_09091.pdf CFS 2013 glufosinate maize: Center for Food Safety Comments to USDA APHIS on Draft Environmental Assessment and Draft Plant Pest Risk Assessment for Dupont-Pioneer Petition for Determination of Nonregulated Status of Insect Resistant and Herbicide Resistant Pioneer Maize (Docket No.APHIS-2012- 0026); http://www.centerforfoodsafety.org/files/cfs-comments-dupont- pioneer-4114-maize--final_43107.pdf Chang F., Simcik M.F., Capel P.D. 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