GE docket at USDA letter
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Lance Christie
Mar 9, 2009, 6:38:39 PM3/9/09
to canyonlands...@googlegroups.com
Go thou and write likewise:
March 9, 2009
Subject: Docket No. APHIS-2008-0023
To whom it may concern,
Docket No. APHIS-2008-0023
Regulatory Analysis and Development
PPD, APHIS, Station 3A-03.8
4700 River Road Unit 118
Riverdale, MD 20737-1238.
Re: Docket No. APHIS-2008-0023, Importation, Interstate Movement, and Release into the Environment of Certain Genetically Engineered Organisms.
I am very concerned about the risks posed by genetically engineered crops--especially those crops engineered to withstand repeated applications of herbicides and crops that produce drugs and industrial chemicals. Diffusion of these modified genes into the environment, which has occurred after past GE releases, threatens human health, family farmers, wildlife, and the environment. I urge USDA to withdraw the proposed rule, publish the Environmental Impact Statement, and suspend all new GE crop approvals in the interim.
After USDA releases the EIS, a comment period of at least 90 days is needed so the public has the opportunity to fully participate in a transparent process on this important issue. This will not only aid in the development of the final EIS but also in the drafting of a new proposed rule. The current proposed rule does little to close the loopholes in the regulations the rule is designed to replace and it creates more gaps than it fills. For example:
As currently proposed, the rule allows biotech companies to self-assess the safety of their own experimental GE crops to determine whether USDA should even regulate them. The proposed criteria are open-ended, subjective, and would substantially reduce USDA's oversight of a wide range of GE crops. Most egregiously, it is not genetic engineering that triggers regulation under the rule, it is the determination that the technology "poses a potential plant pest risk" and it is the developer that makes that initial decision. This is a clear abdication of regulatory responsibility by USDA.
The proposed rule would also allow companies to grow some GE crops with no oversight whatsoever. Under the proposed "tiered system," USDA could eliminate entire categories of GE crops or varieties with which they have "familiarity," despite the USDA's acknowledgment that doing so would "increase gene flow between GE and non-GE crops." This policy virtually ensures that contamination episodes will become more frequent. To add insult to injury, USDA has proposed to include a "Low Level Presence" policy in the law which excuses it from taking any action to remove experimental GE crop material from conventional or organic food, feed, and seed. Experience shows that such contamination often causes severe economic harm to farmers, and could threaten the environment as well. Further, USDA's proposal of "Conditional Exclusion" wrongly enables developers to obtain exemptions from permit requirements without publication, notice, or public comment. This unfairly limits transparency and blocks the public from participation in important decisions that affect public health, the environment, and the economy.
Despite repeated assurances that pharmaceutical and industrial GE crops would be subjected to increased monitoring, reporting, oversight, and management, USDA rejected scientifically-sound options that would have banned outdoor cultivation of GE pharmaceutical- and chemical-producing food crops. This is the only way to ensure that untested drugs and industrial chemicals don't end up in our food. It also ignores the strong support such protective action enjoys from citizens and the food industry. USDA has also refused to propose any controls on pesticide-promoting GE crops, despite documented increases in pesticide use caused by herbicide-tolerant crops and an epidemic of resistant weeds that have been fostered by these crops.
Finally, the rule includes language that bars state or local regulation of GE crops that are more protective than its own weak rule. I strongly oppose such preemptive language that would bar local or state authorities from putting meaningful regulations or restrictions on GE crops in place that best suit their communities.
In sum, I urge you to: (1) Withdraw the proposed rule; (2) Release the EIS for public review and comment, and to be used as a basis for further rule-making; and (3) Suspend all new GE crop approvals until the above has been satisfactorily completed and unless and until GE crops are proven safe.
Sincerely yours,
Richard Lance Christie
- 3018 Old City Park Road
March 9, 2009
Subject: Docket No. APHIS-2008-0023
To whom it may concern,
Docket No. APHIS-2008-0023
Regulatory Analysis and Development
PPD, APHIS, Station 3A-03.8
4700 River Road Unit 118
Riverdale, MD 20737-1238.
Re: Docket No. APHIS-2008-0023, Importation, Interstate Movement, and Release into the Environment of Certain Genetically Engineered Organisms.
I am very concerned about the risks posed by genetically engineered crops--especially those crops engineered to withstand repeated applications of herbicides and crops that produce drugs and industrial chemicals. Diffusion of these modified genes into the environment, which has occurred after past GE releases, threatens human health, family farmers, wildlife, and the environment. I urge USDA to withdraw the proposed rule, publish the Environmental Impact Statement, and suspend all new GE crop approvals in the interim.
After USDA releases the EIS, a comment period of at least 90 days is needed so the public has the opportunity to fully participate in a transparent process on this important issue. This will not only aid in the development of the final EIS but also in the drafting of a new proposed rule. The current proposed rule does little to close the loopholes in the regulations the rule is designed to replace and it creates more gaps than it fills. For example:
As currently proposed, the rule allows biotech companies to self-assess the safety of their own experimental GE crops to determine whether USDA should even regulate them. The proposed criteria are open-ended, subjective, and would substantially reduce USDA's oversight of a wide range of GE crops. Most egregiously, it is not genetic engineering that triggers regulation under the rule, it is the determination that the technology "poses a potential plant pest risk" and it is the developer that makes that initial decision. This is a clear abdication of regulatory responsibility by USDA.
The proposed rule would also allow companies to grow some GE crops with no oversight whatsoever. Under the proposed "tiered system," USDA could eliminate entire categories of GE crops or varieties with which they have "familiarity," despite the USDA's acknowledgment that doing so would "increase gene flow between GE and non-GE crops." This policy virtually ensures that contamination episodes will become more frequent. To add insult to injury, USDA has proposed to include a "Low Level Presence" policy in the law which excuses it from taking any action to remove experimental GE crop material from conventional or organic food, feed, and seed. Experience shows that such contamination often causes severe economic harm to farmers, and could threaten the environment as well. Further, USDA's proposal of "Conditional Exclusion" wrongly enables developers to obtain exemptions from permit requirements without publication, notice, or public comment. This unfairly limits transparency and blocks the public from participation in important decisions that affect public health, the environment, and the economy.
Despite repeated assurances that pharmaceutical and industrial GE crops would be subjected to increased monitoring, reporting, oversight, and management, USDA rejected scientifically-sound options that would have banned outdoor cultivation of GE pharmaceutical- and chemical-producing food crops. This is the only way to ensure that untested drugs and industrial chemicals don't end up in our food. It also ignores the strong support such protective action enjoys from citizens and the food industry. USDA has also refused to propose any controls on pesticide-promoting GE crops, despite documented increases in pesticide use caused by herbicide-tolerant crops and an epidemic of resistant weeds that have been fostered by these crops.
Finally, the rule includes language that bars state or local regulation of GE crops that are more protective than its own weak rule. I strongly oppose such preemptive language that would bar local or state authorities from putting meaningful regulations or restrictions on GE crops in place that best suit their communities.
In sum, I urge you to: (1) Withdraw the proposed rule; (2) Release the EIS for public review and comment, and to be used as a basis for further rule-making; and (3) Suspend all new GE crop approvals until the above has been satisfactorily completed and unless and until GE crops are proven safe.
Sincerely yours,
Richard Lance Christie
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