Anonymous public comment

This is a Comment on the Environmental Protection Agency (EPA) Notice: FIFRA Scientific Advisory Panel; Notice of Public Meeting

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The following statement has been submitted by 26 leading corn insect scientists
working at public research institutions located in 16 corn producing states. All of
the scientists have been active participants of the Regional Research Projects
NCCC-46 "Development, Optimization, and Delivery of Management Strategies for
Corn Rootworms and Other Below-ground Insect Pests of Maize" and/or related
projects with corn insect pests. The statement may be applicable to all EPA
decisions on PIPs, not just for the current SAP. It should not be interpreted that
the actions and opinions of these 26 scientists represent those of the entire group
of scientists participating in NCCC-46. The names of the scientists have been
withheld from the public docket because virtually all of us require cooperation from
industry at some level to conduct our research.


"Technology/stewardship agreements required for the purchase of genetically
modified seed explicitly prohibit research. These agreements inhibit public
scientists from pursuing their mandated role on behalf of the public good unless
the research is approved by industry. As a result of restricted access, no truly
independent research can be legally conducted on many critical questions
regarding the technology, its performance, its management implications, IRM, and
its interactions with insect biology. Consequently, data flowing to an EPA
Scientific Advisory Panel from the public sector is unduly limited."
Comment Period Closed
Feb 22 2009, at 11:59 PM ET
ID: EPA-HQ-OPP-2008-0836-0043
Tracking Number: 8084de39

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Date Posted: Feb 10, 2009
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