seems to have been done to increase the toxin concentration to more than 100 times the concentration in pollen1 or nectar. That is justified, but it would also be ecologically relevant to determine effects of the actual pollen and nectar produced by the plants under field conditions. In soil-degradation studies in which the bacterially produced toxin is used at concentrations that could be obtained from the plant itself, there seems to be less justification for not using the plant itself. It is surprising that in the Bt soil-degradation studies, either bacterially produced toxin or freezedried and highly pulverized Bt-potato plant material is used (Keck and Sims 1993). An ecologically more realistic approach was used in peer-reviewed studies by Donegan et al. (1995) and by Palm et al. (1996): where Bt and non-Bt plant material was placed in the field and monitored for decomposition, microbial diversity, and Bt-toxin titer. Donegan et al. (1996) also used an ecologically realistic system to test for differences in rhizosphere and leaf-dwelling microorganisms associated with field-grown transgenic Bt and non-Bt potatoes. No biologically significant differences were found. Similar tests would be valuable in regulatory assessments.

Overall, the data presented to EPA by Monsanto demonstrate that the transgenic Bt potatoes are likely to be environmentally much less disruptive than current chemical control practices against the Colorado potato beetle.

The concentration of toxin produced in the foliage (19.1 µg/g ) of Bt potatoes (EPA 1995a) far exceeds the concentration needed to kill young Colorado potato beetles (Perlak et al. 1990 and 1993). This level of toxin is expected to fit the EPA Scientific Advisory Panel's (SAP 1998) definition of a “high dose” that can be useful in delaying evolution of resistant pest strains (see section 2.9). The concentration of toxin in the tubers themselves is low (1.01 µg/gm), but potato beetles do not typically feed on the tubers.


Unlike the Colorado potato beetle, which can devastate potato production in some areas when not controlled with insecticides, the European corn borer, which is the major target of transgenic Bt field corn, has not commonly been controlled with insecticides. A survey of the literature (Gianessi and Carpenter 1999) indicates that across the corn belt only


Some varieties of potatoes (for example, Russet Burbank) produce very little pollen, so the discussion of pollen refers to other potato cultivars that have been commericialized (for example, Superior).

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