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A comment to Ann Veneman about pharm corn in Texas

(Sunday, Aug. 15, 2004 -- CropChoice news) -- Comments by Neil J. Carman, Ph.D. of the Sierra Club to APHIS regarding Prodigene's application to grow pharmaceutical corn in Texas.

SC comments to DOCKETS No. 04-044-1 and DOCKET No. 04-August 10, 2004

The Honorable Ann Veneman

APHIS DOCKET # 04-044-1 and DOCKET # 04-041-1 Regulatory Analysis and Development, PPD APHIS, Station 3C71 4700 River Road - Unit 118 Riverdale, MD 20737-1238

Via email: regulations@aphis.usda.gov

Re: Comments #3 to Dockets No. 04-044-1 and No. 04-041-1 on APHIS' draft Environmental Assessments and Prodigene's permits to grow up to 725 acres of pharmaceutical corn in Frio County, Texas

Dear Secretary Veneman:

I am writing on behalf of The Sierra Club, America's largest grassroots conservation organization with over 750,000 members. Comments are submitted to Dockets No. 04-044-1 [aprotinin] and No. 04-041-1 [trypsinogen] regarding Prodigene, Inc.'s two pending permit applications to grow up to 725 acres of biopharmaceutical corn in Frio County, Texas and APHIS' two Environmental Assessments (EA). Sierra Club has been calling for more intelligent regulation of transgenic organisms in the outdoor environment for many years, and requesting environmental impact statements (EIS) as part of this process, but APHIS chose to conduct scaled-back EA's rather than comprehensive EIS's, perhaps to minimize public input, corn farmers' outrage, and scientific critique. In the comments below, the term "pharm" is used in place of pharmaceutical. Sierra Club already sent comments #1, #2a and #2b previously.

The Sierra Club recommends denial of the two permits that Prodigene is seeking to authorize it to grow up to 725 acres of pharm corn in Texas. The reasons for permit denial include the following: APHIS has not conducted adequate scientific reviews of the pharm corn field trials, failed to allow sufficient time for public comments, failed to allow local Frio County, Texas residents an opportunity to attend public meetings to speak their mind, failed to allow Texas' affected corn farmers and consumers an opportunity to attend and speak at public meetings, and the Prodigene permits are so seriously flawed that denial is the most appropriate response. If APHIS decides to modify the permits, then an additional public notice and comment period of sixty-days should be allowed on the alterations.

The Sierra Club vigorously protests the brief comment period since it's unacceptable to allow only a thirty-day public comment period rather than sixty-days when such a significant action is pending to authorize the first large scale planting of a commercial pharmaceutical corn crop in the US. Frio County residents, concerned corn farmers and Sierra Club members, who need to share their concerns with USDA, have not been properly informed about Prodigene's pharmaceutical corn crop in their back yard. At this time, USDA has not held any local public meetings to present information about Prodigene's project in Frio County. Even if the Frio County pharm trial site is secret, local residents have a right-to-know about these crops and how they may be impacted. At this point, USDA and Prodigene appear to have done an effective job of keeping Frio County residents in the dark.


Prodigene has requested two pharm corn permits for an undisclosed site and unknown amount of field trial acreage somewhere in Frio County, Texas, just southwest of San Antonio. Frio County covers 1,133 square miles and 725,120 acres. APHIS only mentions in the EA that all of Prodigene's proposed field tests called "the cumulative acreage planted" in Frio County for 2004-2005 will not exceed one-thousandth of the Frio County's area. So Prodigene's field trial acreage could be as much as 725 acres, implying tens of thousands of corn plants and increasing the probability for genetic escape by cross-pollination and seed dispersal. Prodigene's field trials would make it by far the largest pharm crop field trials in the US where acreage is known. Certainly the magnitude of gene escape by pollen and seed increases with the acreage size. Cross-pollination with local corn fields is a major concern since Frio County had 4,000 acres of corn planted in 2001.

Frio County is generally considered in South-Central Texas being relatively close to Central Texas counties where organic, conventional and non-pharm biotech corn crops are grown. The South-Central Texas region is periodically subjected to hurricanes, tornadoes and severe weather systems carrying high winds blowing through the region including Frio County. If such high winds of 30-60 mph occur during the time that the Prodigene pharm corn is producing pollen, a weather event could potentially transport a plume of pharm corn pollen leading to a long-distance dispersal event by spreading it all over the Central Texas region and beyond where tens of thousands of acres of other corn varieties are grown each year, thereby resulting in a low but predictable degree of pharm DNA contamination. Currently some 120+ Texas counties are growing commercial corn crops out of 254 counties statewide, or nearly 50% of Texas counties have some corn acreage planted.

Does the USDA or Prodigene, Inc. have any plans to offer a specific pharm corn DNA test or to pay for such an independent pharm corn DNA test for the Texas farmers who want to find out if their corn crops have any pharm DNA contamination? It's important for USDA's credibility on the Prodigene-Frio County experiment to offer or find a way to pay for such a specific pharm corn DNA test.

The USDA's proposed one mile buffer zone is grossly inadequate to prevent widespread transgenic corn contamination occurring from Prodigene's pharm corn pollen over an exceptionally large area of Central Texas, well beyond Prodigene's Frio County crop site and even beyond the one mile buffer zone. In the Federal Register notice, USDA is proposing to authorize two permits for Prodigene's pharm corn crop with a one mile buffer as a purely theoretical safety zone where no other commercial corn crop will be grown in Frio County, Texas. The USDA obviously believes that most of the scientific evidence from studies of corn pollen dispersal supports a one mile buffer zone as protective enough to ensure against cross pollination from the pharm corn pollen crop reaching downwind neighboring corn fields beyond one mile.

Clearly, USDA believes a theory that long-distance dispersal from Prodigene's pharm corn pollen to be so rare an event as to cause no concern for Texas' organic corn farmers, conventional corn farmers, and non-pharm biotech farmers. The Sierra Club asserts that the USDA is technically wrong by using flawed science to authorize a one mile buffer zone, and we maintain that the one mile distance is grossly inadequate to prevent pharmaceutical corn contamination, particularly since corn pollen is capable of long-distance dispersal over much greater distances than a one mile limit.


USDA is using a flawed scientific evaluation to propose approving the Prodigene, Inc. permits. The Sierra Club hopes that USDA will seriously consider the following scientific information in its decision-making process.

A 1999 paper by Emberlin, Adams-Groom and Tidmarsh presents challenging information and a comprehensive analysis of why many previous dispersal studies are flawed and why there is a high probability for so-called "rare" long-distance dispersal of corn pollen for hundreds of miles from Prodigene's originating corn field. The research paper commissioned by the UK Soil Association, "A Report on the Dispersal of Maize Pollen," January 1999, was compiled by three scientists, Dr. Jean Emberlin, Beverley Adams-Groom BSc and Julie Tidmarsh BSc, of the National Pollen Research Unit, University College, Worcester WR2 6 AJ, United Kingdom. A copy of the Soil Association report is being mailed and emailed to the Docket separately. A brief summary of the report's most important points is being presented here as part of the Sierra Club's comments (sent as email #1 from Sierra Club to both DOCKETS).

In addition, a second report by Dr. Rob Treu and Professor Jean Emberlin was published January 2000 and titled "Pollen dispersal in the crops Maize (Zea mays), Oil seed rape (Brassica napus ssp olerifera), Potatoes (Solanum tuberosum), Sugar beet (Beta vulgaris ssp vulgaris) and Wheat (Triticum aestivum)." Treu and Emberlin collected and studied evidence from publications. Their report was commissioned for the UK Soil Association from the National Pollen Research Unit, University College Worcester, UK. The report was sent as emails #2a and #2b from Sierra Club to both DOCKETS.

Treu and Emberlin state in the 2000 report's summary addressing pollen dispersal and the potential for hybridization with wild or cultivated relatives of Oil seed rape, sugar beet, maize, wheat and potato: "None of the crops considered in this report has pollen that can be completely contained. The use of appropriate vegetation or other barriers, and/or the use of border rows on the source and receptor crops can reduce dispersal from the fields and transport into other areas. However it is likely that in certain weather conditions medium to long range transport of some pollen will occur." Obviously corn is not considered as an isolated species as a candidate to pose a threat for long-distance pollen dispersal and transgenic contamination.

Treu and Emberlin further emphasize: "Maize presents a medium to high level risk for cross pollination with other maize crops as the pollen can spread on the airflow. ... The percentage of cross breeding with other maize crops in the vicinity will depend on factors such as separation distance, local barriers to pollen movement, such as woods and hedges, local climate and topography." Although Treu and Emberlin's report is written more for the corn crop grown in the UK, I maintain that their obvious concerns are directly applicable to Prodigene's pending pharm corn permit applications for Frio County, Texas, but USDA has apparently neglected to take into consideration this type of scientific information in preference to a desire to rubberstamp the pharm corn permits.

Treu and Emberlin cite the work of Tauber (1965, 1967) in creating his scheme to explain pollen load in the air and its potential travel distance downwind, which utilizes three basic components.


Gravity is Tauber's first component with pollen having only a short horizontal spread. Tauber proposed that applying the gravity component for anemophilous plants like corn means that most of the pollen is deposited very close to the parent plant and onto leaves of adjacent plant as well as the soil.

Tauber's second component is called "local pollen." "Local pollen" means that this component is dispersed downwind like a diffusion cloud with a centerline of concentration remaining parallel to the ground. The "local pollen" plume again has a steep gradient in concentrations with distance downwind.

But Tauber's third component, termed "the regional pollen," is the one creating the most concern for predicted long-distance dispersal of Prodigene's pharm corn pollen over a large area of Central Texas. As Treu and Emberlin eloquently point out and which USDA needs to carefully consider in this matter, "regional pollen" grains are those caught by upward air movements and are transported above the height of vegetation and the local air current conditions created by surface features. "Regional pollen"--including Prodigene's pharm corn pollen--may travel considerable distances downwind in Central Texas and even further distances to outlying regions of Texas.

The 1999 report by Emberlin et al. reviews available evidence from published sources and also communications from named authorities about corn pollen dispersal. Emberlin et al. present a wealth of background information on the characteristics of corn pollen, including morphology and duration of viability, together with pollen quantities produced and the salient features of pollination.

Dr. Emberlin's 1999 Soil Association paper also discusses relevant data from empirical studies, dispersion theory models and airborne particle deposition theory to provide estimates for pollen deposition rates and concentrations of pollen remaining airborne downwind from a source field. The authors honestly concede, however, that it's not possible to provide accurate assessments for practical crop field use, which is applicable in this case to Prodigene's pharm corn crops and the USDA's pending review, because most empirical corn pollen dispersal work has been done within a narrow range of weather conditions and many studies suffer from the constraints of pollen monitoring only close to the source and of errors in pollen sampling.

For example, the corn pollen dispersal evidence from previous work can be used as a basis for making only generalized estimates of percentages of the pollen concentrations remaining airborne downwind in low-to-moderate wind speeds compared with concentrations at 1 meter from the source. Based on such limited studies, these downwind corn pollen concentrations are approximately 2.0% at 60 meters, 1.1% at 200 meters and between 0.75% and 0.5% at 500 meters.

The implications of these concentrations for potential cross pollination are considered, but it's emphasized by the two reports of Emberlin et al. and Treu and Emberlin that the data should be used only as rough guidelines and not for the USDA prescribing an absolute regulatory limit established for Prodigene's pharm crop permit safety conditions. In addition, it should be especially noted for USDA's Prodigene review that pollen dispersal gradients would be altered by factors such as climatic conditions and local topography,


and the Sierra Club's concern here is that USDA has not adequately considered all reasonably possible climatic conditions occurring in Frio County and the Central Texas region during a typical growing season.

Transport on the airflow patterns jetting over longer distances than merely the one mile safety/buffer zone proposed by USDA for Prodigene is likely to occur under a range of weather situations, including uplift and horizontal movement in convection cells, turbulent conditions, and uplift and transport in frontal weather storms. Since corn pollen grains typically remain viable for about 24-hours in the normal weather conditions representative of those occurring in the Central Texas/Frio County area during a typical growing season, pollination could occur at receptive corn field sites quite remote from the Prodigene source (e.g. 180 km or 108 miles, a distance well beyond Frio County borders extending into over thirty nearby counties of Comal, Guadalupe, Hays, Travis, Caldwell, Bastrop, Atascosa, Wilson, Gonzalez, Karnes, Lavaca, De Witt, Goliad, Victoria, Bee, Live Oak, McMullen, La Salle, Dimmit, Zavala, Duval, Jim Wells, Webb, Maverick, Uvalde, Bandera, Real, Kerr, Kinney, Gillespie, Kendall, Edwards, and Blanco Counties; square mileage is 36,644 for the 108 mile radius - Note that a number of these nearby thirty counties are growing thousands of acres of commercial corn crops).

Corn pollen dispersal away from the fields of the Prodigene pharm crop can also take place by transport on bees and other pollinating insects likely to occur in Frio County. Emberlin et al. cite evidence (Bateman, 1947a; Percival, 1955; Vaissiere and Vinson, 1994) that corn pollen is typically collected by area bees in notable amounts, and we expect this bee activity to occur in the Frio County area of the Prodigene pharm corn fields, that is unless the USDA can manage to control the bee populations and keep them away from the Prodigene pharm corn. Crop fields of fertile corn tassels would likely be closely observed by local wild and commercial bee populations and the bees would begin to collect the pharm corn pollen in significant quantities when it becomes available, especially since Prodigene is not proposing to cover the tassels so as to prevent bees from harvesting the pollen. Once collected by bee populations, the pollen is transported several miles from the crop plot in suitable weather conditions.

But Bateman (1947a) suggests that bees are more likely to visit the tassels to collect pollen and less likely to visit the silks where there is no pollen. With the tassels and silks separated on corn plants since corn is diclinous, cross pollination by bees may be less plausible than by other mechanisms. Of course, the pharm pollen collected by bees can become a constituent of honey, which will present difficulties of organic beekeepers whose bees are foraging in Frio County.

Has USDA surveyed how many organic beekeepers, if any, are present in Frio County (or the adjoining counties closest to the Prodigene site) and how close they are to the Prodigene pharm corn sites? The Sierra Club requests that the USDA check with the Texas Department of Agriculture, the Texas Department of Health, Texas Organic Farming organizations, Texas Organic Beekeeper organizations, and the Frio County Extension Agent, including Extension Agents in adjacent counties closest to the Prodigene site, to inquire if there are known local organic beekeepers.


Prodigene, Inc.'s Pharm Corn Pollen Production in Frio County, Texas: Implications for Probable Long Range Dispersal Airflow Currents for Statewide Transgenic Contamination in Texas.

In certain weather conditions airborne particles, including pollen grains such as we would expect even from Prodigene's pharm corn fields, can travel long distances on the airflow. Long-distance dispersal of corn pollen needs to be seriously considered by the USDA within the constraint of its viability time (in the region of 24-hours under normal weather conditions, Purseglove, 1972; however, Emberlin et al. cite corn pollen with a duration of viability from 3 hours up to 8 days depending on conditions). Reports by Treu and Emberlin (2000) and Emberlin et al. (1999) both explore the weather conditions that corn pollen can travel for long distances within its viability period, given the right conditions for doing so.

Palynology research has shown, for example, that typical corn pollen is relatively large and heavy averaging approximately 100 microns in size (larger than most wind-pollinated grass species and species in other angiosperm families), and which is also an expected characteristic of Prodigene's pharm corn pollen. Corn pollen does vary in size and can range from 90-125 microns.

Empirical work on corn pollen dispersal has indicated relatively steep declines in pollen concentrations with distance away from the source and limited upward spread of the plume. However, what's extremely relevant to the USDA's consideration of Prodigene's pharm corn proposal is that Emberlin et al. point out a serious experimental flaw, among the several flaws they discovered, in these corn pollen studies where the researchers investigated pollen dispersal only to limited heights of about 4.6 meters above ground in the downwind direction and to short distances of approximately 500 meters maximum downwind away from the source. As USDA recognizes, there is no invisible atmospheric barrier to prevent Prodigene's pharm corn pollen from being transported to heights above 4.6 meters above ground or carrying downwind for more than 500 meters.

Furthermore, Emberlin et al. also reveal another major problem with these flawed experimental pollen studies since they have been conducted in a narrow, selective range of weather conditions. In this regard, they note that no research has been performed specifically on the movement of corn pollen in convection currents, or on movement aloft in turbulent conditions or during the passage of weather fronts. Studies done on the dispersal of other pollen types has demonstrated that long range transport does take place including pollen from low level sources. But USDA has failed to comprehensively evaluate this obvious concern with Prodigene's pharm corn plans for Frio County fields or else Prodigene's proposal would have already been rejected as unsound for the economic impacts it will have on contaminating significant non-pharm corn acreage.

Vertical transport of lightweight corn pollen particles high above the corn fields takes place by several mechanisms and would be expected to take place in Frio County at the Prodigene pharm corn site, since USDA and Prodigene can not control the local weather patterns. Texas is well known to have particularly warm-to-hot summer days when vertical transport weather patterns routinely develop at the same time that Prodigene's pharm corn is producing


viable pollen, with an average-sized corn plant capable of producing between 14-50 million pollen grains (Miller, 1985) over 2-14 days and more typically 5-8 days (Purseglove, 1972). During warm-to-hot Texas summer days with characteristic low wind speeds, local convective currents driven by the heating of the ground by the sun lead to mixing through the boundary layer. This activity has a marked diurnal influence with particles being dispersed laterally through convection cells during the day, and later descending when the convection subsides (Oke, 1978). As long as there is a positive convective air movement, the net result will be to keep pollen up in the atmosphere. Settling out of pollen usually occurs during cooling in the evening when the majority of pollen grains will return to the surface. Of course, Texas' hottest summer days are in July and August when Prodigene's pharm corn is most likely to be flowering and releasing its pollen in the air. Nights in July and August in Texas tend not to cool off as they might in a northern state with night time temperatures often staying in the 80s.

According to the lucid analysis by Emberlin et al., most anemophilous (wind pollinated) pollen will be liberated during day time hours in dry, warm weather, which will be predominant in the Texas summers as around Prodigene's Frio County sites. What USDA must be made aware of is that Texas summer days like this frequently have thermals rising turbulently that will have a positive effect in bringing pollen grains up into the higher strata, as Emberlin et al. explain; in this respect Prodigene could not have picked a worse location for a high probability to cause widespread transgenic contamination across a large portion of Texas.

The upper limit for convective ascent is marked by the thermal inversion, often shown by the presence of cumulus clouds. Convective cells are typically 1-3 km in diameter, reaching some 1,000-2,000 meters in height and last about 20 to 30 minutes each, during which time they can move downwind. The individual cells may form composite cells reaching 5-10 km across and last for several hours. Upward velocity of cell tops reaches 0.5-1.5 meters per second and horizontal expansion of 0.5-1.0 meters per second (Hardy and Ottersten, 1968).

Therefore, as a consequence, a measurable portion of Prodigene's pharm corn pollen grains will have reached the inversion layer when the bubble collapses. The pollen may then be transported horizontally considerable distances depending on weather conditions. During the evening and night time, the convection building process will cease and the pollen will tend to fall towards the ground but this may be impeded by low level inversions. The usual length of time available for pollen to travel as it's kept aloft by convection is a maximum of one day. This would be equivalent to a distance of about 50 - 180 km or 30 - 108 miles, although it is well known that much longer transports do occasionally take place (Faegri & Iversen, 1989) when suitable meteorological conditions occur.

Another important point is that on cooler, cloudy days with less solar heating and higher wind speeds, pollen can be dispersed vertically by turbulence generated either by instability in the lapse rate or by rough surfaces such as uneven topography; although Frio County has large flat areas, unfortunately, USDA has kept the Prodigene pharm corn site confidential, yet Sierra Club maintains that relevant topographical information should be made public to allow for a more thorough evaluation of the site. Biological particles introduced into the boundary layer have been


observed in detectable concentrations to distances of several hundred kilometers downwind (e.g. Hjelmroos, 1991), and so we expect that similar observations can occur with Prodigene's corn pollen grains over large areas of Central Texas' corn growing region. Penetrative transport to great atmospheric heights can also take place through updrafts generated by deep intense convective storms. In such storms, large masses of air, originally lying near the surface, are transported in a few tens of minutes to heights typically of the order of 8 to 12 km. At such heights, in the middle latitudes, winds are often very strong, in the range 25 to 50 meters per second, so that pollen can travel great distances in a matter of hours (Mandrioli et al., 1984). Why has USDA ignored this information?

Researchers Hirst and Hurst (1967) sampled the ambient air for pollen and spores over the north seas and observed pollen and fungal spores at heights between 500m and 1500m. Their results include a case in which a pollen cloud generated over Britain was later found traveling as a pollen concentration cloud over the North Sea. Hirst and Hurst (1967) concluded that "...it seems safe to assume that distant transport is both frequent and extensive and probably important in temperate latitudes over the summer." Pollen released during one day was found the following day 300-400 km off the coast. Transport took place over the sea where dispersal conditions could be different from those over land depending on the weather. For example, pollen transport over land could be enhanced by increased convection but conversely the concentrations could be depleted by more deposition due to turbulence. Another researcher, Tyldesley (1973), likewise found appreciable quantities of arboreal pollen (up to 30 grains per cubic meter) in the air in the basically treeless Shetland Isles, which lie some 250-380 km (150-228 miles) away from the nearest forests, in connection with favorable meteorological conditions, i.e. cyclonic storms. In Central Texas centering around Frio County, a radius distance of 150-228 miles consists of a huge region where Prodigene's pharm corn pollen could be transported. The number of Texas counties encompassed by a radius of 150-228 miles is dozens, certainly more than the 30+ counties touched by the 108 mile radius.

A recent study of pollen in rain in Northwest India identified pine tree pollen, which is also from a wind-pollinated species with 100 micron average pollen size similar to corn's average pollen size. The researchers concluded that long-distance dispersal of pollen could allow the grains to travel 600 km or 360 miles by finding pine pollen at that distance downwind from the closest pine trees (Singh et al., 1993). Due to the large size of both pine and corn pollen, the report by Singh et al. provides additional evidence that Prodigene's pharm corn pollen will probably be dispersed toward far greater distances than USDA believes is possible in Central Texas.

Emberlin et al. explain that a frontal storm can lift air masses several kilometers up in the air in a very short time and thus place pollen grains, such as Prodigene's, far above the day and night cycle (Faegri & Iversen, 1989). Once pollen has arrived in the upper atmosphere (such as over Frio County, Texas), it can travel for many hundreds of miles on the airflow with a high wind speed usually in the range of 25-50 meters/second (15-30 mph) until finally being deposited or it may be captured by water drops and return to the surface in precipitation (Mandrioli et al., 1984). In general, long range pollen transport occurs most efficiently in dry conditions with limited mixing depth and moderate to high wind speeds. We see lots of summer days in


Texas with these kinds of hot, dry conditions where long range pollen transport from Prodigene's pharm corn fields will predictably transpire.

Pollen grains can also be re-suspended from surfaces in gusts of wind and re-deposited at other locations. For example, Erdtman (1938) described finding Zea pollen in the air in Sweden during midwinter (Faegri & Iversen, 1989). Erdtman (1943) also cites finding atmospheric pollen at all points across the Atlantic ocean with a mid ocean figure of 0.7 grain per 100m3 compared to 18 grains per 100m3 on the Swedish mainland. If re-suspension took place within the time of corn pollen viability, it could extend the effective transport distance. USDA needs to recognize the potential for Prodigene's pharm corn pollen re-suspension and subsequent dispersal as another challenge to this unsound proposal.

The available evidence reveals why it's reasonable to assume that corn pollen, including from Prodigene's pharm corn fields, can remain viable and capable of effective fertilization for at least 24 hours in most weather conditions prevailing in Frio County, Texas. This means that with mean horizontal wind speeds of only 2 meters per second, that can occur routinely on Texas summer days with convection currents that could keep the pollen grains aloft, Prodigene's pharm corn pollen could travel downwind 1.0 km (0.6 miles) in 4.16 minutes, 7.2 km (4.3 miles) in an hour (potentially 172.8 km in a day, or 103.7 miles).

Applying higher wind speeds of 10 meters per second, which occurs in Central Texas, some pharm pollen grains would travel greater downwind distances before descending by dry or wet deposition than in slower wind speeds. Winds of 10 meters per second would give rise to turbulent conditions in the boundary layer keeping some Prodigene pharm corn pollen airborne for longer than in non-turbulent air flows.

If the Prodigene pharm corn pollen remained airborne, it could travel 36 km (22 miles) in an hour and nearly 864 km (518.4 miles) in 24 hours. The key question for USDA and Prodigene is how much of Texas' corn growing regions would be covered by a radius of 518 miles from Frio County?

The area enclosed by 518.4 miles is 844,269 square miles and encompasses the whole core of Central Texas extending well across the State of Louisiana to the East, well into the State of Arkansas to the Northeast, nearly to El Paso in the West, deep into Mexico to the South close to where native maize populations are growing, past the Oklahoma State border to the north, and even well into the Texas Panhandle to the Northwest. Is the USDA proposing to allow Prodigene to contaminate a significant portion of non-pharm corn growing in Texas? The wild maize populations in Mexico?

If USDA grants additional comment time, further comments may be submitted. In conclusion, the USDA needs to step back from its Environmental Assessments of Prodigene's pharm corn and reassess the phenomenal potential for regional corn contamination from the Prodigene pharm corn field trials.

Sincerely yours,

Vice Chair
Sierra Club Genetic Engineering Committee
54 Chicon Street
Austin, Texas 78737
Tel 512-472-1767
Fax 512-477-8526
Email: Neil_Carman@greenbuilder.com

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