Office of Pesticide Programs
Environmental Protection Agency
1200 Pennsylvania Ave. NW
Washington, DC 20460-0001
RE: Docket ID No. EPA-HQ-OPP-2020-0585:
To Whom It May Concern:
I am writing to comment on the Draft Endangered Species Act Biological Evaluations.
I would like to tell a tale of three industries. Big-Pharma; Big-Telecomm and Big-Ag. Seemingly unrelated, they have a lot in common. All are controlled by powerful money, with powerful influence and big expansive business models. All have cozy relationships with their regulators and each have the power to make or break life on this planet as we know it.
All use science with fundamental flaws at their core, to justify their business expansion.
- Big Telecomm relies on science that tests cell phones based upon the penetration of the heat of the phone to the brain rather than the obvious risk, non-thermal transmission of electromagnetic currents.
- Vaccines rely on science that uses a ‘spiked’ placebo rather than an inert placebo and refuse to do a vaccinated vs unvaccinated study.
- Big Ag relies on science that says humans and animals do not have the shikimate pathway, therefore glyphosate cannot harm them. This however, does not account for the bacteria in the gut that does have the shikimate pathway and responds just like a weed in the field.
You don’t have to have a Phd in Biology to know that we have a real environmental problem in this country. The bees are dying in swarms. We are losing endangered species at an alarming rate. If this isn’t due to the chemicals you license, with scientific studies as your authority, what do you imagine it to be?
Before you mentally answer that question with more proof from a scientific study, let us review the principles of Propaganda as created by Edward Bernays in the 1920s. Bernays was the nephew of Sigmund Freud and used the ideas of his famous uncle to sell cigarettes. One of his major contributions to the mess we are currently in, was how he used scientific studies.
Bernays set up third party organizations, funded by the tobacco industry, to create scientific studies that could prove anything they wanted. If the study did not provide the desired results, it was not used. The more studies the better and they churned them out, taking control of the narrative by virtue of the sheer number of studies.
There is a natural friction of influence at play here. There is a scientific body of evidence that says that glyphosate is harmless. These studies are what industry touts. There is also a scientific body of evidence that says it is harmful. This is usually backed by people like myself who do not represent organizations, just our own health and well-being.
As the regulators of the chemical industry, taking a new look at glyphosate, you have a big decision on your shoulders. May the decision you make personally and collectively be for the highest good of people, animals, plants and our planet.
MY BIG CONCERNS
First, I am one, who has to avoid GMO foods to maintain my physical health. Contrary to industry belief, GMO corn is completely different than natural corn. The body knows, all living organisms know, and cannot be tricked by the alteration of corn for the purposes of patenting. As you might imagine, avoiding GMOs is getting harder to do and is headed in the direction of being impossible to do. What solution do you suggest for me if you re-license glyphosate? Or what do you propose for the endangered species after they are gone?
I have the proof in my living organism, my body. But scientists are now confirming my body’s wisdom. A new study was conducted by an international team of scientists based in London, France, Italy, and the Netherlands, led by Dr Michael Antoniou of King’s College London. It is published in the journal Environmental Health Perspectives.
“Our study highlights the power of multi-omics approaches to investigate the toxic effects of pesticides. Multi-omics revealed that glyphosate and MON 52276 inhibited the shikimate pathway in the rat gut microbiome. Our findings could be used to develop biomarkers for epidemiological studies aimed at evaluating the effects of glyphosate herbicides on humans”.
Second, the World Health Organization has listed glyphosate as a “probably carcinogenic to humans” and “sufficient” evidence of cancer in experimental animals.
“In March 2015, IARC classified glyphosate as “probably carcinogenic to humans” (Group 2A).
This was based on “limited” evidence of cancer in humans (from real-world exposures that actually occurred) and “sufficient” evidence of cancer in experimental animals (from studies of “pure” glyphosate). IARC also concluded that there was “strong” evidence for genotoxicity, both for “pure” glyphosate and for glyphosate formulations.”
Third, we already know that glyphosate herbicides have been found in streams, ocean water, rain and by the EPA’s own acknowledgment, is highly toxic to aquatic life. Glyphosate herbicides harm 93% of endangered species and 97% of their critical habitats. I ask you to remember that we too, live in these habitats.
Fourth, the following quote summarizes industry’s aggressive expansion of GMO foods and therefore glyphosate, as well as their status as invasive species:
“Without any social licence, pesticide companies have thrust GMOs into the foodscape. The release of GMOs has generally been unwelcome, there has been no ‘pull’ factor from consumers and there has been vocal resistance from many”
“The evidence is that GMOs are invasive species, they are unwelcome by consumers, peaceful coexistence with non-GM varieties is a fiction, and GMOs are appropriately managed as a biosecurity issue.”
John Paull, Geography and Spatial Sciences, School of Technology, Environments and Design, University of Tasmania, Hobart, Australia
Fifth, Glyphosate directly impacts animals.
Glyphosate use directly impacts a variety of nontarget animals, including insects, earthworms, and fish, and indirectly impacts birds and small mam-mals.47
Roundup kills beneficial insects, including parasitoid wasps, lacewings and ladybugs.48
Repeated applications of glyphosate significantly affect the growth and survival of earthworms.49
Environmental factors, such as high sedimentation, increases in temperature and pH levels increase the toxicity of Roundup, especially to young fish.50
Roundup, in sublethal and environ-mentally relevant concentrations, causes morphological changes in two species of amphibians by interfering with hor-mones.51
It is “extremely lethal” to amphibians in concentrations found in the environment.
I am guessing you may have children or grandchildren. I wonder what story you tell them about the state of the world you are leaving them. I wonder if you lay awake nights trying to make sure you did all you could to protect the people, plants, animals and our planet. I certainly hope so.
I ask you to stand up for people and the planet and refuse to relicense glyphosate. Now that would be a story to tell your grandchildren.
For the people and the planet,
Priest River, ID