# International Certification Services, Inc.

301 5^th^ Ave Southeast, Medina, North Dakota 58467 USA Ph: (701)
486-3578 Fax: (701) 486-3580

E-mail: info@ics-intl.com Website:
[www.ics-intl.com](http://www.ics-intl.com/)

## 

## Corporate Headquarters in Rural North Dakota

### Operating the FVO Organic Certification Program

##### The FVO Program is accredited by IFOAM, Conseil des appellations agroalimentaires du Québec (CAAQ), and (USDA) ISO 65

**Date:** 20 April, 2005

**To:**

Animal and Plant Health Inspection Service (APHIS)

EDOCKET

http://www.epa.gov/feddocket

**Comments Pursuant to:**

**Docket No. 03-101-4**

Environmental Impact Statement; Petition for Deregulation of Genetically
Engineered Glyphosate-Tolerant Creeping Bentgrass

**Submitted by:**

International Certification Services, Inc.

5449 45^th^ St. SE

Medina, North Dakota 58467

Tel: 701-486-3578 Fax: 701-486-3580

e-mail: info@ics-intl.com

**Comments:**

International Certification Services, Inc. (ICS) is an certification
agency based in North Dakota, USA, doing business worldwide. The program
currently does business under the name International Certification
Services, as well as Farm Verified Organic (FVO) and has done so since
1980. ICS is accredited by The United States department of Agriculture
under the National Organic Program (NOP), International Organic
Accreditation Services, Inc. (IOAS) to the program requirements of the
International Federation of Organic Agriculture Movements (IFOAM)
Accreditation Program. ICS also holds accreditation by USDA for
compliance under ISO Guide 65 requirements.

We are pleased to have this opportunity to offer comments on this
important issue. ICS strongly opposes any allowance to plant, propagate,
or otherwise introduce genetically engineered bentgrass into any
environment that is not fully enclosed or otherwise contained. Extreme
caution is warranted for this proposed plant variety, for the following
reasons:

Creeping bentgrass is a perennial crop, able to propagate itself on its
own with no human interaction necessary. It reproduces vegetatively via
stolons (it "creeps") and sexually via seed. Seed is very light and
easily airborne, making it transferable to other locations. Furthermore,
bentgrass is wind-pollinated, the pollen being extremely fine in size
and correspondingly lightweight. In fact, studies have already shown
that pollen from genetically engineered bentgrass was found to have
drifted 13 miles from a test site in Oregon. The genetically modified
grass pollinated natural growths of wild grass of a different species
nearly nine miles away.

One thing is certain: the genetically engineered trait *will* escape
into the environment. The extent of the impact after that happens is
unknowable and potentially destructive. The petitioners argue that
escape of the genetically altered traits into the environment is a low
risk. However, their studies were, in our opinion, generally too small
scale to amplify the negative effects of what might occur in a more
real-world situation. Even if an escape is small, the effects over time
can and likely will be amplified and more widespread. Experience with
other genetically engineered crops has shown that environmental and
nutritional effects of such novel plants are often unintended,
unexpected, and deleterious.

There are essentially two categories of hazards:

(i) escape of the engineered seed or plant into the environment and/or
    production stream; and

(ii) the outcrossing of the trait to other species.

Each aforementioned category its own potentially dangerous corollary
effects as well, only some of which are predictable at this point in
time. Discussing these categories in turn:

\(i\) Escape of the engineered plant could occur as drift of the seed to
other locations via wind, animals, or other vectors. Additionally,
pollution of traditional bentgrass seed stocks with the engineered
variety could occur. The likelihood of both of these phenomena, based on
our observations of other genetically engineered seed, is all but
certain. The spread of genetically engineered bentgrass would thus
increase out of human control. If wider scale introduction to the
environment were to be allowed (either regulated or deregulated),
specifically designed segregation systems should be in place to handle
genetically modified seed. This would help mitigate the aforementioned
deleterious effects, but not eliminate them.

Where the engineered grass is found and deemed a weed, it will not be
controllable with glyphosate, making certain people resort to more toxic
herbicides. Contrary to what many biotech seed companies claim,
increased use of herbicides is a result of herbicide-resistant
varieties. The use of glyphosate increases greatly on the crop itself,
and the emergence of glyphosate-resistant species due to increased
exposure and subsequent evolution of species has also been increasingly
observed.

All this makes the exposure of people and the rest of the ecosystem to
increased levels of all kinds of toxic herbicides greater. The
convenience afforded a small minority of citizens (most notably owners
and users of golf courses) is far outweighed by the potentially
destructive impact of the deregulation of the genetically engineered
bentgrass.

\(ii\) Outcrossing of the genetically altered trait to other species
will most likely result in its establishment in wild populations where
it provides a selective advantage, that is, where glyphosate is used
often. Where the hybrids are already weeds, a new ability to resist
glyphosate may make them more difficult to control. In some cases,
resistance to glyphosate may help grasses that are not now weeds evolve
into weeds.

The chances of hybridization with other bentgrass plants or related
species ranges from low to enormous, depending on the specifics of the
site. If deregulated, glyphosate-tolerant creeping bentgrass could be
planted within pollinating distance of many populations of native and
naturalized sexually compatible relatives, creating in some cases weedy
hybrids. As a result, the deregulation of the genetically engineered
bentgrass may lead to the establishment of engineered traits in
potentially dozens or even hundreds of wild plant populations in the
United States. In fact, the U.S. Forest Service said earlier this year
that the grass \"has the potential to adversely impact all 175 national
forests and grasslands.\"

Furthermore, as an organic foods certification agent, ICS is also
concerned about the crossover of the genetically engineered traits to
such relatives as perennial ryegrass, a common forage in organic
livestock husbandry. This is an entry point for the genetically
engineered trait and its heretofore-unknown corollary nutritional
effects to enter the food stream unchecked. Furthermore, USDA National
organic program rules prohibit the use of such materials in all phases
or production. Aside from regulatory issues, consumer confidence in the
quality of many certified organic foods may suffer greatly in the
not-too-distant future as a result of pollution of organic crops with
the engineered trait.

The economic damages to organic farmers, grass seed producers, and other
parties could be significant. Legal claims against trespassers, and
ultimately against APHIS as well, could result if diligence is not
carefully done to evaluate the impacts of the proposed deregulation. ICS
urges APHIS to conduct its review of the petition using a qualified body
of non-interested scientific experts from a variety of backgrounds,
though an iterative process that is transparent and allows for continued
public input.

In closing, we appreciate the opportunity to offer our comments and
share our concerns. We appreciate that APHIS has agreed to receive
comments from a variety of stakeholders. ICS urges extreme caution by
APHIS with regard to the introduction of such potentially high-impact
novel plants into the environment. We would be pleased to contribute to
efforts to improve the current situation.

End of comments.

Respectfully submitted,

International Certification Services, Inc.