Appendix A1

Costs of Regulating Transgenic Pest-Protected Plants

Erik Lichtenberg, University of Maryland


The bulk of this report is devoted to the potential risks posed by transgenic pest protected plants and the ways that regulation can mitigate those risks. In other words, this report focuses primarily on the benefits of regulating transgenic pest protected plants, even though those benefits are presented in neither quantitative terms (magnitudes of risk and risk reduction) nor economic ones (the public 's willingness to pay for reduction of these risks, increases in sales due to allayed fears about safety, etc.). Yet regulation is desirable only if its benefits outweigh its costs; the mere existence of risk does not imply that regulation is necessary or desirable. This appendix considers potential costs of regulating transgenic pest protected plants and provides evidence regarding the potential magnitudes of some of those costs. Two forms of regulation are considered. One involves regulating transgenic pest protected plants as pesticides under the Federal Insecticide, Rodenticide, and Fungicide Act (FIFRA). The other involves regulating environmental effects under the Federal Plant Pest Act (FPPA) and related legislation and regulating food safety under the Federal Food, Drug, and Cosmetic Act (FFDCA) administered


This appendix was authored by an individual committee member and is not part of the committee's consensus report. The committee as a whole may not necessarily agree with all of the contents of appendix A.

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