Ellis Rubenstein, President
Rashid Shaikh, Director of Programs
New York Academy of Sciences
2 East 63rd St. New York, NY 10021

Dear Mr. Rubenstein and Mr. Shaikh,

We are concerned that the Academy is doing its members and readers of Update a disservice by publishing Lee Silver's error-filled and unsubstantiated piece ("The environment's best friend: GM or organic?",  May/June 2006 Update, online on Silver's website at http://24.225.233.42/SilverArticles/06NYASorganic.pdf).

Briefly, Silver's misstatements and factual errors include the following:

* Silver states that "SAll currently used pesticides ­ both natural and synthetic ­ dissipate quickly and pose a miniscule risk to  consumers.S." Interestingly, in a Newseek International article culled  from his piece, Silver stated this even more broadly, opining that ""Sall  commonly used pesticides dissipate so quickly that they pose a miniscule  health risk to consumers." Both statements are wrong. In fact, many toxic  pesticides persist for decades, and pesticide residues on food are routinely  found. Thirty years after they were banned, a review in 2001 found food  residues of the organochlorine pesticides DDT and dieldrin at levels that  scientists say could cause health problems[1]
. Other persistent organochlorine pesticides are still widely used on food today.[2] A 2002 peer-reviewed study found  pesticide residues on 90% of the samples of apples, peaches, pears,  strawberries and celery.[3]  Persistent toxic pesticides in  current use have also been widely implicated for contaminating groundwater  throughout the U.S.[4]  
* Perversely,  Silver implies that food from organic farms have dangerous residues from  botanical insecticides. In fact, there has never been a single study finding  residues from these products on organic food. Unlike many synthetic  pesticides, these botanicals degrade rapidly in the environment and have never  been demonstrated to pose food safety threats.[5]   

* Silver argues that meat from  the "enviropig" will be safe for human consumption. But in 2001 the developers  of the gene altered pig acknowledged that their frankenpig could cause food  allergies if the untested GE protein was found in the pig meat.[6] Last year, they admitted that the  gene altered protein was found in muscle tissue (ie, meat)[7] , at levels that could trigger  allergic reactions. Food allergy reactions can vary from mild discomfort to  sudden death.  

* Like other  proponents of factory farming, Silver misleadingly portrays the "enviropig" as  primarily a solution to pollution from massive hog farms. In fact, the  developers admit that their aim was to help pork producers skirt environmental  limits on phosphorous pollution and enable them to cram even more hogs into  their already massive industrial farms. In 1999, Reuters reported that OPork producers live under very stringent environmental regulations and can only raise so many hogs per hectare,' said John Phillips [one of the developers of the enviropig], molecular biologist at Guelph University. If the phosphorous found in a pig's manure is reduced by 50 percent, then theoretically farmers can raise 50 percent more pigs and still meet environmental restrictions. In North America, Europe and in some parts of Asia, the only thing holding back a farmer's hog output is the restrictions on phosphorous leaching into the water table, Phillips said. OIn the Netherlands, the environmental limitations on the number of animals they can raise per hectare of land is just squeezing that industry,' he added.[8]

* Silver ignores  environmental risks from the gene spliced pig that other scientists warn could  be severe. The National Academy of Sciences has warned that wild pigs are  already an environmental pest in several states, and noted that if the genetic  tinkering used to produce the enviropig were conferred to wild pigs, the  result could be an increase in these pest problems.[9]  

* Silver's  suggestion that GE farming is more productive has not been borne out. Studies  show that the world's most widely grown GE crop, Monsanto's GE soybeans, yield  fewer bushels per acre than natural soy. [10] We are disappointed that the Academy would print such a biased and poorly researched piece. We look forward to hearing from you and working together to address the misinformation presented in your publication. Signed,

Charles Margulis Center for Food Safety

Neil J. Carman, Ph.D. Sierra Club Genetic Engineering Committee

Patricia Lovera Food & Water Watch

Mark A. Kastel The Cornucopia Institute

Peter Melchett Soil Association

[1]
Brian P. Baker, Charles M. Benbrook,
Edward Groth III, and Karen Lutz Benbrook, "Pesticide residues in conventional, IPM-grown and organic foods: Insights from three U.S. data sets," Food Additives and Contaminants, Volume 19, No. 5, May 2002, pages 427-446, summary online at http://www.consumersunion.org/food/organicsumm.htm ; also,
"Report Card: Pesticides in Produce," Environmental Working Group, October
2003, online at http://www.foodnews.org/reportcard.php

[2]
See "Case Study: Organochlorine
Pesticides," Coming Clean, online at http://www.chemicalbodyburden.org/cs_organochl.htm

[3]  Brian P. Baker, op sit, note 1

[4] See, e.g., U.S. Geological Survey, "Pesticides in the Nation's Streams and Ground Water, 1992-2001," Circular 1291, online at http://pubs.usgs.gov/circ/2005/1291/

[5]  Ibid; also, Charles Benbrook,
"Minimizing Pesticide Dietary Exposure Through the Consumption Organic Food," Organic Center Report, May 2004, p. 24-25.

[6]
Helen Branswell, "Guelph Scientists
Work On Cleaner Pig," Canadian Press, April 30, 2001, online at

http://cattlefeeder.ab.ca/manure/env010430.shtml

[7]  Treena Hein, "Focus on...
Biotechnology: Gene splicing improves pork farm waste." New Agriculturist, Feb 2005, online at www.new-agri.co.uk/dl/05-2/focuson.rtf

[8]
Reuters, "And This Little Piggy Was
Environmentally Friendly," June 24, 1999, online at http://www.genet-info.org/genet/1999/Jun/msg00051.html

[9] National Academy of Sciences, 2002. "Animal Biotechnology: Science Based
Concerns." National Academies Press, p. 84, online at http://newton.nap.edu/openbook/0309084393/html/84.html

[10] Elmore et.al., 2001. "Glyphosate-Resistant Soybean Cultivar Yields Compared with Sister Lines," Agron J, 93: pp. 408-412 (finding a 5-10% yield drag in side-by-side trials comparing RR and related varieties of natural soy); Charles Benbrook, 2001. "Troubled Times Amid Commercial Success for
Roundup Ready Soybeans: Glyphosate Efficacy is Slipping and Unstable Transgene Expression Erodes Plant Defenses and Yields," Northwest Science
and Environmental Policy Center, Sandpoint, ID, May 3, online at http://www.biotech-info.net/troubledtimes.html (finding a 4% yield drag in RR soy); Ron Eliason, 2004. "Stagnating National Bean Yields," presentation, Midwest Soybean Conference, Des Moines, IA, cited by Dan Sullivan, NewFarm.org, online at http://www.newfarm.org/features/0904/soybeans/index.shtml

From: Twittman@aol.com [mailto:Twittman@aol.com] Sent: Wed 5/10/2006 9:05 PM
To: undisclosed-recipients
Subject: The Environment's best friend: GM or Organic?

Dear Readers,

Directly below is an interesting skewed view of the problem with how organic advocates think.  The author of this piece is geneticist Lee Silver who wrote "Remaking Eden".  For much more on his work I highly recommend that you google him.  I also suggest you go to the Agbioworld site as well (www.agbioworld.org http://www.agbioworld.org/ ). To add some balance to this article I am adding one from February this year about a debate between these very different factions on biotech and organic. Peace, Thomas

The Environment's best friend: GM or Organic?
Wednesday, May 10, 2006 By Lee Silver

Ecological degradation has reached crisis levels in heavily populated areas of northern Europe, China, Korea, and Japan. Pig-caused ecological degradation is a complex problem, and no single solution is in the offing.

But any approach that allows even a partial reduction in pollution should be subject to serious consideration by policy makers and the public.

A prototypical example of what directed genetic modification (GM) technology can deliver is the transgenic Enviropig, developed by Canadian biologists Cecil Forsberg and John Phillips. Forsberg and Phillips used an understanding of mammalian gene regulation to construct a novel DNA molecule programmed for specific expression of the E. coli phosphorus-extraction gene (phytase) in pig saliva. They then inserted this DNA construct into the pig genome.

The results obtained with the first generation of animals were dramatic: the newly christened Enviropigs no longer required any costly dietary supplements and the phosphorus content of their manure was reduced by up to 75%. Subtle genetic adjustments could yield even less-polluting pigs, and analogous genetic strategies can also be imagined for eliminating other animal-made pollutants, including the methane released in cow belches, which is responsible for 40% of total greenhouse gas emissions from New Zealand.

Environmentally friendly GM

Not all GM projects are aimed specifically at reducing the harmful effects of traditional agriculture on the environment. Other GM products approved to date, developed almost entirely in the private sphere, have aimed to reduce production costs on large-scale farms. But as molecular biology becomes ever more sophisticated, the universe of potential environmentally friendly GM applications will expand. Scientists have begun research toward the goal of obtaining pigs modified to digest grasses and hay, much as cows and sheep do, reducing the land and energy-intensive use of corn and soy as pig feed.

The most significant GM applications will be ones that address an undeniable fact: every plot of land dedicated to agriculture is denied to wild ecosystems and species habitats. And that already amounts to 38% of the worlds landmass. Genetic modifications that make crop production more efficient would give us opportunities to abandon farmland that, in many cases, should cede it back to forests and other forms of wilderness, as long as world population growth is ameliorated.

So why are many environmentally conscious people categorically opposed to all uses of GM technology? The answer comes from the philosophy of organic food, whose fundamental principle is simply stated: natural is good; synthetic is bad.

The roots of organic farming: Before the 18th century, the mate- rial substance of living organisms was thought to be fundamentally different in a vitalistic or spiritual sense from that of non living things. Organisms and their products were organic by definition, while nonliving things were mineral or inorganic. But with the invention of chemistry, starting with Lavoisiers work in 1780, it became clear that all material sub- stances are constructed from the same set of chemical elements.

As all scientists know today, the special properties of living organic matter emerge from the interactions of a large variety of complex, carbon-based molecules. Chemists now use the word organic to describe all complex, carbon-based molecules whether or not they are actually products of any organism.

Through the 19th and 20th centuries, increased scientific understanding, technological innovations, and social mobility changed the face of American agriculture. Large-scale farming became more industrialized and more efficient. In 1800, farmers made up 90% of the American labor force; by 1900, their proportion had decreased to 38%, and in 1990, it was only 2.6%.

However, not everyone was happy with these societal changes, and there were calls in the United States and Europe for a return to the preindustrial farming methods of earlier times. This movement first acquired the moniker organic in 1942, when J. I. Rodale began publication in America of Organic Farming & Gardening, a magazine still in circulation today.

According to Rodale and his acolytes, products created by and processes carried out by living things are fundamentally different from lab-based processes and lab-created products. The resurrection of this pre-scientific, vitalistic notion of organic essentialism did not make sense to scientists who understood that every biological process is fundamentally a chemical process. In fact, all food, by definition, is composed of organic chemicals. As a result, the U.S. Department of Agriculture (USDA) refused to recognize organic food as distinguishable in any way from non organic food.

Yet, according to self-imposed organic rules, precision genetic modification of any kind for any purpose is strictly forbidden, because it is a synthetic process. If conventional farmers begin to grow Enviropigs or more sophisticated GM animals that reduce nearly all manure-based pollution organic pig farmers will then blindly continue to cause much more pollution per animal, unless they are prevented from doing so by future EPA regulations.

Many organic advocates view genetic engineering as an unwarranted attack not just on the holistic integrity of organic farms, but on nature as a whole. On the other hand, spontaneous mutations caused by deep-space cosmic rays are always deemed acceptable since they occur naturally. In reality, laboratory scientists can make subtle and precise changes to an organisms DNA, while high-energy cosmic rays can break chromosomes into pieces that reattach randomly and sometimes create genes that didn't previously exist.

Regardless, organic enthusiasts maintain their faith in the beneficence and superiority of nature over any form of modern biotechnology. Charles Margulis, a spokesman for Greenpeace USA, calls the Enviropig a Frankenpig in disguise .

The European Commission states as a fact that organic farmers use a range of techniques that help sustain ecosystems organisms are not really chemicals, but rather organic constituents of nature. Since pyrethrin is produced naturally by chrysanthemums and rotenone comes from a native Indian vine, they are deemed organic and acceptable for use on organic farms

However, the most potent toxins known to humankind are all natural and organic. They include ricin, abrin, botulinum, and strychnine highly evolved chemical weapons used by organisms for self-defense and territorial expansion. Indeed, every plant and microbe carries a variety of mostly uncharacterized, more or less toxic attack chemicals, and synthetic chemicals are no more likely to be toxic than natural ones.

Less-allergenic GM food All currently used pesticides both natural and synthetic dissipate quickly and pose a miniscule risk to consumers. Nevertheless, faith in natures beneficence can still be fatal to some children. About 5% express severe allergic reactions to certain types of natural food. Every year unintentional ingestion causes hundreds of thousands of cases of anaphylactic shock with hundreds of deaths. The triggering agents are actually a tiny number of well-defined proteins that are resistant to digestive fluids. These proteins are found in such foods as peanuts, soybeans, tree nuts, eggs, milk, and shellfish. They linger in the intestines long enough to provoke an allergic immune response in susceptible people.

No society has been willing to ban the use of any allergenic ingredients in processed foods, even though this approach could save lives and reduce much human suffering. GM technology could offer a more palatable alternative: scientists could silence the specific genes that code for allergenic proteins. The subtly modified organisms would then be tested, in a direct comparison with unmodified organisms, for allergenicity as well as agronomic and nutritional attributes.

USDA-supported scientists have already created a less-allergenic soybean. Soy is an important crop used in the production of a variety of common foods, including baby formula, flour, cereals, and 40% of the greenhouse gas emissions in New Zealand come from livestock

Eliot Herman and his colleagues embedded a transgene into the soy genome that takes advantage of the natural RNA interference system to turn off the soy gene responsible for 65% of allergic reactions[9]. RNAinterference can be made to work in a highly specific manner, targeting the regulation of just a single gene product. Not only was the modified soy less allergenic in direct tests, but the plants grew normally and retained a complex biochemical profile that was unaltered except for the absence of the major allergen. Further rounds of genetic surgery could eliminate additional allergenic soy proteins. Meanwhile, other scientists have reported promising results in their efforts to turn off allergy-causing genes in peanuts and shrimp.

Some day perhaps, conventional soy and peanut farmers will all switch production to low-allergenicity GM crop varieties. If that day arrives, organic food produced with GM-free organic soy or peanuts will be certifiably more dangerous to human health than comparable nonorganic products.

Unfortunately, conventional farmers have no incentive to plant reduced-allergy seeds when sales of their current crops are unrestricted, especially when the public has been led to believe that all genetic modifications create health risks. In the current social and economic climate, much of the critical research required to turn promising results into viable products is simply not pursued. Anti-GM advocates for organic food may be indirectly and unknowingly responsible for avoidable deaths in the future.

At some future date, as the power of biotechnology continues to expand, our understanding of plant and for the regrowth of dense forests. As a result, biodiversity would expand, the extinctions of many species might be halted, and a large sink for extracting greenhouse gases from the atmosphere might be created.

Of course, this scenario is wild biotech speculation. But current-day organic advocates would reject any technology of this kind out of hand, even if it was proven to be beneficial to people, animals, and the biosphere as a whole. This categorical rejection of all GM technologies is based on a religious faith in the beneficence of nature and her processes under all circumstances, even when science and rationality indicate otherwise.

Copyright AgBioWorld