Reject deregulation of a genetically engineered plum

July 12, 2006

Docket No. APHIS-2006-0084
Regulatory Analysis and Development
PPD, APHIS
Station 3A-03.8,
4700 River Road,
Unit 118,
Riverdale, MD 20737-1238

Re: Docket No. APHIS-2006-0084 - Agriculture Research Service; Availability of Petition and Environmental Assessment for Determination of Nonregulated Status for PLUM GENETICALLY ENGINEERED FOR RESISTANCE TO PLUM POX

Our company urges you in the strongest possible terms to reject deregulation of the genetically engineered (GE) plum. Allowing commercialization of the GE plum is a bad economic risk and threatens the economic health of Washington state and the U.S. tree fruit industry.

In Washington, the State Horticultural Society reports that the tree fruit industry accounts for more than 142,000 jobs, from field work to advertising and sales. The economic value is more than $2 billion a year in the Yakima Valley alone. In north central Washington, it's worth $1.5 billion a year and in the Columbia Basin, more than $800 million annually. The total cumulative value is greater than that from Microsoft or Boeing combined, according to Jim Hazen at the horticultural society. It is vital to do no harm to this economic base.

The deregulation of GE papaya, another tree fruit, provides clear warning of the economic devastation caused by commercialization. When GE papaya was introduced in Hawaii 5 years ago, proponents claimed it was a 'solution' to the papaya ringspot virus problem. But instead it is an environmental and economic disaster.

The rejection of GE papaya by overseas markets caused the selling price of GE papaya to fall 30-40 percent below production costs; the price that farmers get for their GE papaya is 600 percent lower than the price for organic papaya. Farmers also have discovered that GE papaya is more easily infected by new plant fungi and diseases like 'blackspot' fungus, a discovery that came five years after GE papaya was approved for commercial growing. Now farmers must spray toxic chemical fungicides on GE papaya plants every 10 days.

Deregulating a GE tree fruit on the mainland, where farms are not surrounded by a vast ocean, very likely could cause even greater economic and environmental devastation. Because plums are pollinated by bees, the commercialization of GE plums could threaten our very food security.

Bees are extraordinarily sensitive to unnatural, foreign contamination in the field. Bees never develop resistance to fungicides or other pesticides; if they come into contact with toxins while collecting pollen, they'll die before reaching the hive.

It appears that no studies have examined the potential impact of GE plums on bees, which pollinate plum orchards. In fact, bees pollinate about 40 percent of our food crops. No bees, no food. It would be minimally prudent to halt deregulation of the GE plum to evaluate the potential impact on bees and whether GE plums could in fact be a "plant pest."

As a retail grocer, we approached $100 million last year in sales at our eight stores in the Seattle area. Our success is due in no small part to the close partnerships we have with regional farmers, including tree fruit farmers.

We urge you to reject deregulation of the genetically engineered plum, to protect tree fruit farmers, the tree fruit export industry, and in turn the stability and health of our business.

Sincerely,

Tracy Wolpert
Chief Executive Officer
PCC Natural Markets
www.pccnaturalmarkets.com

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