Environmental Assessments of Genetically-Modified Cotton, Soybean, and Corn in Support of Regulatory Management by USDA

U.S. Department of Agriculture (USDA);
Animal and Plant Health Inspection Service (APHIS);

Biotechnology Regulatory Services (BRS)

Overview

• Conducted Environmental Assessments of Genetically-Modified Organisms (GMO) under accelerated schedule
• Evaluation required multidisciplinary expertise including agronomy, plant physiology and genetics, entomology, wildlife ecology, agricultural economics, and National Environmental Policy Act (NEPA) experience
• Review and evaluation of Plant Pest Risk Assessments (PPRA) conducted for Bayer TwinLink Cotton, Monsanto 87705 Soybean and Dow Herbicide Tolerant Corn

Description

Avatar Environmental was contracted by USDA/APHIS/BRS to conduct Environmental Assessments (EAs) of several genetically-modified crops proposed for non-regulatory status. APHIS exercises its regulatory authority through a system that includes both permits and notifications. Following years of research conducted under APHIS oversight, a developer may request that APHIS no longer regulate a genetically-modified crop by submitting a petition for non-regulated status. APHIS’s permitting decisions and determinations of non-regulated status are subject to review under the NEPA. APHIS uses the conclusion of its NEPA review to inform its permitting decisions, as well as its decision to deregulate. In support of this review, Avatar prepared EAs of several products for which non-regulatory status was petitioned and included:

• Bayer Crop Science Insect Resistant and Glufosinate Ammonium-Tolerant (TwinLinkTM) Cotton, Gossypium hirsutum
• Monsanto Improved Fatty Acid Profile MON 87705 Soybean
• Dow Herbicide Tolerant DAS-40278-9 Corn

EAs were conducted to determine the significance of the environmental effects of the proposed use of these products and to look at alternative means to achieve the agency’s objectives of safe and productive development of agricultural crops. For each EA, Avatar prepared a concise document that (1) provides sufficient evidence and analysis for determining whether to prepare an Environmental Impact Statement (EIS); (2) aids USDA’s compliance with NEPA when no EIS is necessary; and (3) facilitates preparation of an EIS if and when one is necessary.