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2004 Essays - Part III (September)
"SEEDS, INDUSTRY GERMINATION AND CALIFORNIA ROOTS: A TASTE OF THE GENETICALLY MODIFIED FOODS DEBATE, PART III"
*This essay series began in June with a feature on the basics of genetically modified (GM) food, or "frankenfood" as it is sometimes called by its critics. [Click here to read Part I, "Genes, Beans and Greens: A Taste of the Genetically Modified Foods Debate."] It continued in Part II with a discussion of some of the products of genetic modification - some successful and some not - such as tomatoes, papaya, rice and wheat. That issue concluded with a look at the promise of and hopes for agricultural biotechnology in solving problems of hunger and malnutrition in developing countries. [Click here to read Part II, "The Products and the Promise."] The third and final essay of this series will begin by examining some of the foundations of the biotechnology industry and finish close to home with a focus on California.*
*As with Parts I and II, Part III will be interactive in the sense that the reader can go back and forth between the essay text and the links embedded within it. By clicking a link you can read more about the particular topic being discussed, then return to the essay by clicking your browser's "back" arrow. (The links are included for information purposes only. No guarantees are made as to the accuracy of the materials presented on the sites, although every effort has been made to search out reliable and respected sources of information.) (*Some of the links may have been changed since last year or are no longer valid. Where possible, they will be updated and corrected.*) Footnotes and a bibliography are also included at the end for anyone wishing to learn more about the subject. The materials represented here are only a small fraction of what is available on this very complicated issue. The glossary link below has been provided as a reference for use as needed. If your browser does not allow you to see text in the box, click here to reach the glossary.*
Have you ever seen a purple carnation? How about a lavender one? Think hard - and flowers that have had the color sprayed on don't count. A decade or two ago the colors would have been impossible, since carnations (and many other flowers) don't carry the gene coding for blue hues. However, an Australian company has now created carnations in that color range and made them available commercially -- another of the "firsts" in agricultural biotechnology. [Click here, then on "products" to view photos of the flowers.]
When the initial segment of this essay series debuted in June, it began with a look at the current status of agricultural biotechnology as applied to food products - genetically modified (GM) or transgenic food. In less than ten years, about 80% of the soybeans and 40% of the corn grown in the U.S. have come to be grown from transgenic seeds.(n1), and by some estimates as much as "70% of the human food products in the marketplace"(n2) today contain some ingredients made from these crops.
Although this may seem like a short time span for such rapid emergence of GM crops, the initial seeds were the products of decades of research. The first transgenic plant was produced in 1982 (n3), and the first field trials of transgenic plants began in 1987 (n4), well before the wide-scale plantings of the crops which began in 1996 (n5). In order to understand how the debate over GM food has reached its current status, this series will finish by taking a step back and looking at foundations of the biotechnology industry itself. Finally, since the first GM food product available commercially, the Flavr Savr tomato (see Part II), was developed by a (then) California company, the series will conclude close to home with a brief look at California agriculture and the state of the industry here.
The Creation of an Evolving Industry
"A number of applications for patents on recombinant DNA techniques are accumulating. None has yet been granted by the U.S. Patent and Trademark Office (USPTO) for organisms. The Patent Office apparently believes that it does not have the mandate under present law to allow patents on living bacteria created for these techniques . . . This position has put the Patent Office in conflict with the Court of Customs and Patent Appeals, which had twice held that forms of life are patentable under present law. The dispute is at present before the U.S. Supreme Court, which announced in October 1979 that it would accept the issue for review in the current session."
The discovery of the double helix structure of DNA by James Watson and Francis Crick in 1953 set in motion an era in science which has led to today's modern biotechnology industry. The first biotechnology company ever formed was the California firm Genentech (1976). One of its founders, Herbert Boyer of the University of California San Francisco, was one of the original inventors of the recombinant DNA technique along with Stanley Cohen of Stanford. In this same mid- to late-1970s period, several "small entrepreneurial firms [began forming] in the U.S. specifically to build on the growing body of fundamental knowledge in molecular biology." (n7)
A seminal year for the industry, however, was 1980. In that year the landmark Supreme Court decision (alluded to in the quote above) was issued, and two key pieces of legislation were passed by the U.S. Congress. In Diamond v. Chakrabarty (447 US 303) the Supreme Court allowed for the patenting of a genetically modified bacteria stating that "anything under the sun that is made by man" is patentable. In addition, both the Bayh-Dole Act (Public Law 96-517, 94 STAT 3019) and the Stevenson-Wydler Technology Innovation Act of 1980 (Public Law 96-480, 94 STAT 2311) were enacted into law.
The Patent and Trademark Law Amendments Act, more commonly referred to as the Bayh-Dole Act, allowed for universities and small businesses to patent and license inventions made using federal funds. Prior to the passage of the Act, "discoveries made by way of federally-funded research, if not simply dedicated to the public, were owned by the government with only a non-exclusive license available to private industry. As a result, companies lacked the incentive to undertake the financial risk to develop a product based on such research. . . The Bayh-Dole Act and [later] amendments thereto have provided the basis for current university technology transfer practices, which often involve co-development and commercialization by academic institutions and private industry." (n8). The Stevenson-Wydler Act, among other things, also facilitated the transfer of federally owned and originated technologies to the states and the private sector.
In that same year, the initial public offering of Genentech stock (based presumably on the value of the patents it was able to hold) set a record for the fastest price per share increase (in the pre-dotcom era), from $35 to $89 in 20 minutes. (n9) By the end of 1981, between 70 (n10) and 80 (n11) new biotech firms had formed, including Amgen (1980), Calgene (1980) Chiron (1981) and Genzyme (1981). (n12) By 1983, more than $500 million had been raised in the U.S. public capital markets by these new biotechnology firms. (n13)
In the following years, several other pieces of
legislation, though not directly targeted to biotechnology, furthered the
growth of the industry. These included:
Federal Technology Transfer Act of 1986 (Public Law 99-502, 100 STAT
1785) - This authorized government labs to enter into Cooperative
Research and Development Agreements (CRADAs) for publicly-funded
National Competitiveness Technology Transfer Act of 1989 (Public Law
101-189, 103 STAT 1674), part of the National Defense Authorization Act
of 1990 - 1991, Division C, Part C The
National Technology Transfer and Advancement Act of 1995 (Public Law
104-113, 110 STAT 775) - This amended the Stevenson-Wydler Act with
respect to inventions made under CRADAs The 2000
Technology Transfer and Commercialization Act (Public Law 106-404, 114
The Federal Technology Transfer Act of 1986 (Public Law 99-502, 100 STAT 1785) - This authorized government labs to enter into Cooperative Research and Development Agreements (CRADAs) for publicly-funded technologies
The National Competitiveness Technology Transfer Act of 1989 (Public Law 101-189, 103 STAT 1674), part of the National Defense Authorization Act of 1990 - 1991, Division C, Part C
The National Technology Transfer and Advancement Act of 1995 (Public Law 104-113, 110 STAT 775) - This amended the Stevenson-Wydler Act with respect to inventions made under CRADAs
The 2000 Technology Transfer and Commercialization Act (Public Law 106-404, 114 STAT 1741)
The numbers of scientific discoveries and advancements also continued swiftly during this same period, shaping and defining the direction of growth in the biotechnology industry. Foremost among these was the 1990 initiation and recent completion of the Human Genome Project for mapping all the genes in the human body. Since many of these advancements fall in the realm of medical biotechnology they will not be covered in the context of this essay. Suffice it to say that the pace of overall advancement has been so rapid that a popular principle know as "Monsanto's Law" was coined. This "law" states that "the ability to identify and use genetic information doubles every 12 to 24 months." (n14) However, as the number of gene patents have proliferated and the number of university-industry/public-private partnerships and collaborations have grown, distinct views and criticisms of the system have emerged.
"Milford Sound, New Zealand" © 1985, 2005 Dorothy A. Birsic
Of Patents and Partnerships
Despite refinements of the patent laws which have taken place since the Diamond v. Chakrabarty decision was issued, among some groups "the patenting of genetic inventions still raises questions of an ethical, legal and commercial nature. . . The most influential critics . . . are not against intellectual property rights, technological change and scientific advances in principle, but they feel a certain reticence about genetic inventions. For some, the issue is mostly ethical, a dislike of associating property rights with biological materials, especially if they are human. To others, genes are part of the 'common heritage of humanity' and should only be public property. . . Other argue that DNA sequences are not simply chemical compounds but also strings of information and that the genome should be viewed as a huge database whose information should be available to all." (n15)
In addition to the more philosophical concerns regarding patents on genetic material, practical concerns continue to be expressed on many levels that "by allowing genetic information to be patented, researchers will no longer have free access to the information and materials necessary to perform biological research." (n16). These "access" concerns generally fall under one of "three headings: 'research issues,' where access to information or material by third-party researchers [may be] impeded as a consequence of protection; 'commercialization issues,' where access by those who would develop other commercial products [may be] impeded; and 'clinical use issues,' where protection [may have] impeded access to information or materials in a clinical setting." (n17). The discussion of Golden Rice in Part II of the series provided an example of issues falling within the first two of the categories listed above.
Few would disagree that the ability to patent genetic material has formed the basis of and is a necessity for the attraction of investment capital to private biotechnology firms. These companies, especially if small (entrepreneurial) start-ups, would be hard-pressed to attract the tens or hundreds of millions of dollars necessary to bring a product to market without the ability to profit from the investment(s). As a result of this and the rapid pace of new genetic invention, "the number of patents granted has risen dramatically in the last decade. In 2001, over 5000 DNA patents were granted by the USPTO, more than the total for 1991 - 1995 combined." (n18)
Unlike many other industries, "biotechnology owes much of its growth to academic science." (n19) Even from the early 1980s, "states hoped to attract and retain dedicated biotechnology companies as well as major pharmaceutical, chemical and agricultural corporations" by creating biotechnology expertise in the university systems. (n20) One 1988 document said of California that "the strength of the University of California (UC) system has been the instrumental force in establishing a healthy biotechnology industry in California. The climate, the large venture capital pool and expanding markets are additional inducements to industry." (n21)
There are few better illustrations of how the laws, patent protection and business realities have interacted in the growth of the biotechnology industry than in California. The state is home to more biotechnology companies than any other state in the nation. Although there are companies scattered from north to south, the two primary clusters of companies are in the San Francisco Bay area and around the University of California San Diego in the La Jolla/San Diego area. One biotechnology-oriented website, www.biospace.com, has designated these as two "hotbed" areas and provides stylized maps with links to biotechnology company profiles and product information. To view the "Biotech Bay" (San Francisco area) map, click here. To view the "Biotech Beach" (Southern California/San Diego) map, click here.
If anything, the ties between industry and the campuses
of the UC system have only grown closer in the last two decades. On one
page of a UC website, it is stated that:
1 in 4
biotech companies is within 35 miles of a UC campus 1 in 3
California biotech companies was founded by UC scientists 85% of CA
biotech companies employ UC alumni with graduate degrees (n22)
1 in 4 biotech companies is within 35 miles of a UC campus
1 in 3 California biotech companies was founded by UC scientists
85% of CA biotech companies employ UC alumni with graduate degrees (n22)
In general, Bayh-Dole has "revolutionized"(n23) university-industry relations. However, one criticism that has emerged over the years is that the legislation and ensuing practices have also blurred the traditional lines between the public sector's goal of "expanding knowledge for the benefit of science and humanity" (n24) through basic (not profit-motivated) research, and the private sector's role in applying and commercializing the research for profit and to "maximize returns." (n25)
Even in the early days following the passage of the 1980 legislation there was debate about what effect the laws would have on science and industry. Some viewed Bayh-Dole as "essential to provide an effective exploitation of the research base, . . . [and] critical to our national well-being in an increasingly competitive world marketplace." (n26) Others said, "To the long familiar military-industrial complex a fraternal twin has been added: an academic-industrial complex through which American and multinational corporations siphon the publicly created resources of our Universities and thereby convert publicly financed research into private gain."(n27)
These issues came to the forefront in California in the year 2000. In May of that year hearings were held in the California legislature on "The Impact of Genetic Engineering on California's Environment: Examining the Role of Research at Public Universities."(n28) One particular segment of the hearings concerned a $25 million agreement between UC Berkeley and the Swiss multinational Novartis, a producer of pharmaceuticals and genetically modified crops. The agreement had gained a certain amount of notoriety as it was spotlighted in March of the same year in a cover article in Atlantic Monthly magazine entitled "The Kept University."(n29) At that time, the fact "that the University had the backing of a private company was hardly unusual. That a single corporation would be providing one third of the research budget of an entire department at a public university [was what] had sparked an uproar."(n30)
Proponents of the Berkeley and similar agreements argue that such funding is a necessity due to the "changing economic realities of [the] educational system." (n31) Part of this "changing reality" is the fact that while "the rate of growth in federal support [for academic research] has fallen steadily over the past twelve years, . . . the cost of research, particularly in the cutting edge fields of computer engineering and molecular biology, has risen sharply. State spending has also declined." (n32) In that same twelve-year period, the percent of UC Berkeley's overall budget supplied by the State of California decreased from 50 to 34 percent. (n33) Corporate giving grew "from $850 million in 1985 to $4.25 billion less than a decade later, . . . [spurred in part by] generous tax breaks for corporations willing to invest in academic research."(n34) Statistics supplied by UC for the hearings show, however, that "excluding the UC-managed national laboratories, in fiscal year 1999 the federal government supplied 71 percent of all UC's external research funding as opposed to 9 percent for industry. Federal-funded basic research comprised almost two-thirds of all research conducted at UC [campuses]."(n35)
"Peloponnesus II" © 1984, 2005 Dorothy A. Birsic
Seeds of Change
The discussion so far has primarily concerned the growth of the biotechnology industry via the new companies which have formed its base. Equally important, especially in agricultural biotechnology, is the consolidation which has taken place in the seed industry specifically, and more generally in the structure of world agriculture at every stage of the food chain. (n36) The Swiss company Novartis, discussed in the previous section, is a pertinent example of this.
Novartis was formed in 1996 by the merger of two Swiss life science giants, Ciba-Geigy and Sandoz. Sandoz brought to the merger Northrup-King, a brand name company acquired in 1976 that was well-established in field crops, especially hybrid corn and sorghum. Northrup-King's own position in the market was the result of its past acquisitions of field seed companies, including Pride Seed Company, Stauffer Seeds, and Coker Pedigreed Seed. Ciba-Geigy also contributed to the merger with a long list of previously acquired seed companies. . . The merger gave rise to a new . . .division called Novartis Seeds, which controlled 7 percent of the seed market for major crops in 1997. In 1999, after operating as a complete life sciences company for only 3. 5 years, Novartis announced plans to merge its agricultural business with the Swedish/English pharmaceutical giant AstraZeneca which had been formed only 6 months earlier. The agricultural spinoff, Syngenta, became a global leader in both seed and pesticide sales. According to the most recent sales figures from Merrill Lynch, Syngenta is only second to Pioneer with $1.2 billion in annual seed sales, and first in pesticide sales with more than $7.0 billion in annual sales. (n37) Novartis also currently owns the Gerber baby food company.
Similar activity took place in the United States with the Dupont Company's acquisition of Pioneer Hi-Bred (the largest player in the corn seed market) (n38), and Monsanto's transition from a chemical, then pharmaceutical, company to a company "based on seeds and traits that deliver[s] solutions to farmers."(n39)
These consolidation trends also had their roots in the 1980s. First, there was a period of stagnation in the chemical industry during which "the sale of chemical units. . . freed up capital for diversification into new industries."(n40) Second, the processes involved in the emerging biotechnology industries "required understanding of both chemical and biological processes. . . For chemical companies already involved in agriculture, seed companies were logical acquisitions because of complementarities between their chemical inputs and new genetically engineered traits."(n41) This activity prompted talk of an emerging "life sciences" industry "organized around the development of such products as agricultural chemicals, seeds, food and food ingredients and pharmaceuticals based on related research in biotechnology and genetics." (n42) The industry in still in the process of transition, however. Given the rapid pace of change it is impossible to say what it may look like even 5 or 10 years from now.
An understanding of the concerns surrounding the consolidation of the seed industry would be incomplete without a brief look at the overall changes which have taken place since the early 1900s. At that time, "most U.S. farmers depended on seed saved from the previous [year's] crop and did not purchase significant quantities of seed from commercial sources." (n43) This is a practice which still continues in some parts of the developing world. In the early 1900s, better-yielding hybrid varieties (especially of corn) began to be developed. One characteristic of hybrid seeds is that they do not breed true in subsequent generations, so seeds need to be purchased regularly in order to maintain uniform production characteristics. Following the passage of the Plant Patent Act of 1930 (which gave protection to asexually or vegetatively reproduced plant varieties as well as hybrids), "approximately 150 companies formed to produce hybrid corn seed," (n44) By 1965, "over 95% of American corn acreage was planted with hybrid seed."(n45)
The Green Revolution, ushered in at about this time (see Part II), brought with it dramatic improvements in agricultural productivity based not only on superior seeds, but also on "modern plant breeding, improved agronomy and the development of inorganic fertilizers and pesticides." (n46) In the developing world, many of the improved strains of crops came as the products of research and development in international and public organizations. After new strains of crops were developed, "adapted local varieties were . . . replicated by national seed companies and given away to farmers. Intellectual property rights were not an issue, since government agencies wanted the seeds to spread as fast as possible. (n47)
In the United States during this time period, two other intellectual property measures came into force. First, the Patent Act of 1952 "extended patent rights to agricultural innovations under a much more general category, . . . the. . . broad definition of [which] leaves an important opening for covering innovations in biotechnology and genetic engineering." (n48) Second, the Plant Variety Protection Act (PVPA) of 1970 gave breeders exclusive rights to market new plant varieties. The stated purpose of the act was "to encourage the development of novel varieties of sexually produced plants and to make them available to the public, providing protection to those individuals who breed, develop, or discover them, and thereby promoting progress in agriculture in the public interest." (n49) This was partly accomplished by researchers' and farmers' exemptions incorporated into the Act.
After the passage of the PVPA, "more than 50 seed companies were acquired by pharmaceutical, petrochemical and food firms. . . Many chemical firms entered the U.S. seed market because the agricultural chemicals market had reached maturity and profits in the sector were declining." (n50) The series of mergers and consolidation continued in the 1980s as "companies sought to offset the high costs of biotechnology R & D." (n51) The net result of this activity was that many of the "key technologies in the [agricultural] biotechnology field became protected as intellectual property and concentrated in the hands of a small number of large multinational corporations based in North American and Western Europe." (n52) "During the 1996 - 2000 period, 75% of over 4,200 new ag biotech patents went to private industry." (n53)
Agricultural Biotechnology in California
California is the top agricultural producer and exporter in the United States. The state's cash income from agricultural production in 2001 was $27.6 billion, almost double that of the number two state, Texas. (n54) The state is also the nation's sole producer (99% or more) of a large number of specialty crops including: almonds, artichokes, clingstone peaches, dates, figs, kiwifruit, nectarines, olives, persimmons, pistachios, dried plums (prunes), raisins and walnuts. (n55). Despite California's status as a "leader in agricultural innovation, . . . only cotton, among [the genetically modified] crops, has seen significant production" here. (n56) According to USDA statistics for 2004, about 52% of the cotton grown in the state was from genetically engineered upland cotton varieties. (n57).
As was outlined in previous issues of the essay, the vast majority of the major GM food crops (i.e. corn, soybeans and canola) are grown in the midwest farm-belt states. In comparison, only about 75,000 acres of transgenic corn were planted in California in 2001, and most of it was likely used as animal feed. (n58). The only other food crop to receive regulatory approval was a squash engineered to resist viruses. Only about 10 acres of the commercial production of the squash was in California. (n59)
Despite the minor presence of commercially available transgenic crops in the state, there are a number of field trials of potential future crops taking place here. A searchable public database of genetically modified crop information called Information Systems for Biotechnology can be found at www.nbiap.vt.edu. [Click here to view the information on field tests and releases of GMOs.] And why is there such a minor presence of transgenic crops in California? "Costs are probably one reason the [overall] market has so far favored biotech crops that are grown on a very large scale (soybeans, corn, cotton). The economics are less favorable for California, which grows a great number of small, high-value crops rather than a few large-acreage crops." (n60) Other factors have to do with the diversity of species and varieties of the state's crops, small niche markets for some products, processor and distribution requirements, and a lack of consumer benefits to develop demand for the products. (n61)
In contrast to the acceptance transgenic crops have found in many of the farm-belt states, anti-GM food activism also has been on an upswing here. As mentioned in part one, Mendocino County recently became the first in the nation to pass a measure specifically prohibiting the cultivation of GM crops within the county limits. [Click here to see the text of the measure.] A few other counties have followed suit with their own ballot initiatives for the November elections. [To view the website for the Butte County proposition, click here.]
These county efforts to ban GM products within their borders may raise the question of what role the state government plays in the oversight of biotechnology in California. The answer is that "the State of California, like most states, has deferred to the federal government for regulation of biotech products." (n62) Last near in a study prepared for the states's Food Biotechnology Task Force, it was reported that California "follows federal oversight of biotechnology in lieu of specific state regulations on the issue. Food derived from GE sources is regulated under the same rules that govern conventional food. The state requires no special labelling, special permits, technical review of genetic engineering production methods, or any special tracking of movement, sale or planted acreage. (n63) Is this adequate? The conclusion, arrived at in a Senate Office of Research report of June 2003, stated that "the appropriate role of the state in the monitoring and oversight of biotechnology has yet to be clearly defined or determined." (n64) But when?
* * *
The biotechnology industry as a whole is one of the world's newest, and it is in a continuous state of flux and evolution. Although the pace of change in the medical biotechnology industry continues unabated, as noted in Part II the rate of commercial introduction of new products (beyond the transgenic soy, corn, cotton and canola already on the market) in agricultural biotechnology has slowed. The next generation of products, including the plant-made pharmaceuticals (PMPs) discussed in the previous essay, have the possibility of blurring the boundaries between the agricultural and medical biotechnology fields. Whether the public will resist or accept these products remains to be seen.
This essay series continued the tradition started last summer of an in-depth exploration of a topic of current interest for visitors to the site. Hopefully you've found the series informative and can end the summer with a better understanding of what biotechnology is and what the genetic modification of food products means for you. If you have any questions about the series, or if you'd like to suggest a future topic, please send an email to email@example.com. Thanks and hope to see you next summer!
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"Caracas, Venezuela" © 1988, 2005 Dorothy A. Birsic
The following are the footnotes indicated in the text in parentheses with the letter "n" and a number. If you click the asterisk at the end of the footnote, it will take you back to the paragraph where you left off.
n6 - U.S. House of Representatives, Committee on Science and Technology, Subcommittee on Science, Research and Technology, "Genetic Engineering, Human Genetics and Cell Biology: Evolution of Technological Issues in Biotechnology (Supplemental Report III), 96th Congress, 2nd Session, Serial DDD, August 1980, pp. 32 - 33 (*)
n8 - Judge, Linda R. "Biotechnology: Highlights of the Science and Law Shaping the Industry," Santa Clara University Computer and High Technology Law Journal, Vol.20, November 2003, p. 4 0f 15 in online version or article from infotrac.galegroup.com. (*)
n10 - U.S. Congress, Office of Technology Assessment (OTA), New Developments in Biotechnology: U.S. Investment in Biotechnology Special Report, OTA-BA-360, Washington D.C.: U.S. GPO, July 1988, p. 78 (*)
n24 - Summers, Teresa M., "The Scope of Utility in the Twenty-First Century: New Guidance for Gene-Related Patents," 91 Georgetown Law Journal 475, January 2003, p. 4 of 23 in Lexis-Nexis Academic online document. (*)
n28 - California Legislature, Senate Committee on Natural Resources and Wildlife/Senate Select Committee on Higher Education, "Impacts of Genetic Engineering on California's Environment: Examining the Role of Research at Public Universities", Senate Publication 1054-S, Sacramento, May 15, 2000 (*)
n37 - Fernandez-Cornejo, The Seed Industry in U.S. Agriculture: An Exploration of Data and Information on Crop Seed Markets, Regulation, Industry Structure and Research and Development, AIB-786, Washington D.C.: United States Department of Agriculture, Economic Research Service, February 2004, p. 32 (*)
n40 - King, John L., Concentration and Technology in Agricultural Input Industries, Electronic Report/AIB 763. Washington, D.C.: United States Department of Agriculture, Economic Research Service, March 2001, p. 6 (*)
n49 - Fernandez-Cornejo, Jorge and Schimmelpfennig, David, "Have Seed Industry Changes Affected Research Effort?", Amber Waves, USDA, Economic Research Service, February 2004, p. 2 of 5 (online document available at www.ers.usda.gov/AmberWaves/February04/Features/HaveSeed.htm) (*)
n54 - State of California, Department of Food and Agriculture, Resource Directory 2002 - California Agriculture: A Tradition of Innovation, Sacramento, CA: CA Department of Food and Agriculture, 2002, pp. 28 - 29 (*)
n56 - Bruening, George, "Chapter 4: Spliced-DNA Crops in California," in California Council on Science and Technology (CCST), Benefits and Risks of Food Biotechnology, Sacramento, CA: CCST, 2002, p. 85 (*)
n57 - United States Department of Agriculture, Economic Research Service, Briefing Room: Adoption of Genetically Engineered Crops in the U.S., Genetically Engineered Upland Cotton Varieties by State and United States, 2000 - 2004. Washington, D.C.: USDA, ERS, 2004. Online data available at www.ers.usda.gov/Data/BiotechCrops/ExtentofAdoptionTable2.htm (*)
n62 - Luscher, David and Steggall, John, "Chapter 6: State Regulations," in California Council on Science and Technology, Benefits and Risks of Food Biotechnology, Sacramento, CA: CCST, 2002, p. 123 (*)
The links included in Part III of the essay series are listed below. (*Please note: some of the links may have changed since last year or no longer be valid. Where possible, they will be updated or corrected.*)
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