I've taken the liberty of forwarding this. I  haven't seen it discussed here, 
but it doesn't seem too sustainable to me.
Pegi> To: [EMAIL PROTECTED]> From: [EMAIL PROTECTED]> Date: Wed, 19 Nov 2008 
16:28:06 -0800> Subject: [Odairy] Fwd: USDA Rushing Through Dangerous New Rules 
on GE and Pharmaceutical Crops> > I know we all have a ton on our plate with 
the NOP livestock rule and many> other things, but this one (deadline for 
comments Monday) is extremely> important. Perhaps it is only a coincidence that 
the long-delayed timing of> the NOP livestock grazing rule proposal means that 
we are> pre-occupied precisely in time for this rulemaking on GMOs to go more 
under> the radar. In any case, we can't just let this one go by.> > 
<http://www.centerforfoodsafety.org/>> > USDA Rushing Through Dangerous New 
Rules on GE and Pharmaceutical Crops> > Greetings,> > In the waning months of 
the Bush administration, the U.S. Department of> Agriculture (USDA) has joined 
the ranks of federal agencies rushing through> new regulations that weaken 
protections for human health and the> environment. *USDA has released a 
proposed rule that would significantly> weaken oversight of all genetically 
engineered crops, and which continue to> allow companies to grow food crops 
engineered to produce drugs and> industrial chemicals.*> > The USDA began this 
process over four years ago by promising stricter> oversight. Unfortunately, 
improvements considered early on have been> dismissed, and *the proposed rule 
now has the same gaping holes as the> policy it is replacing, and creates a few 
new ones, as well. For instance:*> > * USDA has created a huge loophole 
allowing biotech companies to assess> their own crops to determine whether USDA 
should regulate them. And the> criteria are open-ended, very subjective, and 
will certainly reduce USDA's> oversight of GE crops.> > * The proposed rules 
could also allow companies to grow untested GE crops> with no oversight 
whatsoever: "Over time, the range of GE organisms subject> to oversight is 
expected to decrease...," a move which USDA itself admits> will make 
contamination of conventional/organic crops with untested GE> material more 
likely.> > * To add insult to injury, USDA has proposed to write into law its 
"Low> Level Presence" policy, which excuses it from taking any action to 
remove> untested GE crops from conventional or organic food, feed and seed. 
This> contamination often occurs through cross-pollination or seed dispersal, 
and> has cost farmers hundreds of millions of dollars in lost sales and 
lowered> profits.> > * USDA rejected options that would have banned outdoor 
cultivation of> pharmaceutical-producing GE (food) crops, the only way to 
ensure that> untested drugs don't end up in our food, despite strong support 
from> citizens and the food industry.> > * USDA has refused to propose any 
controls on pesticide-promoting GE crops,> despite increasing pesticide use and 
an epidemic of resistant weeds that> have been fostered by these crops.> > * 
Finally, USDA snuck in a last-minute "correction" that bars state or local> 
regulation of GE crops more protective than its own weak rule. CFS strongly> 
opposes 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. This last-minute change should be cause to> extend 
the public comment period.> > The USDA is treading dangerous new ground here. 
The structure of the new> proposal opens loopholes that can be exploited by 
biotech companies and> expose consumers to more untested and unlabeled 
genetically engineered> foods.> > *After denying requests for an extension to 
the short comment period given> for the proposed rules, USDA's comment period 
closes on Monday. Sign our> petition to the USDA today and demand stronger—not 
weaker—regulations for> genetically engineered crops!*> > > > [image: Sign this 
petition]<http://ga3.org/campaign/GMOregs/wedx7xsry7kiixxt?>> > Sign this 
petition :> > 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 genetically engineered 
crops--especially> those engineered to produce drugs and industrial 
chemicals--pose to human> health, family farmers, wildlife, and the 
environment. I urge USDA to close> the gaping loopholes in its proposed rules, 
and put stronger--not> weaker--regulations in place. In particular:> > 1)Please 
follow the advice of the National Academy of Sciences and make> genetic 
engineering the trigger for USDA oversight so that ALL experimental> GE crops 
are properly regulated. This approach is scientifically sound,> 
administratively efficient, and more protective of public health, the> 
environment, and the interests of farmers. Eliminate loopholes that exempt> any 
GE crop that has not undergone a determination of non-regulated status> from 
USDA regulatory oversight.> > 2)Please do NOT incorporate the "Low Level 
Presence"> policy in the final rule. Instead, make zero presence of> 
experimental GE crops in food and feed your management goal, and gear your> 
implementing regulations to achieve it as fully as possible. In particular,> 
make all field trials of experimental GE crops subject to strict gene> 
containment standards at least as stringent as those now applied to> 
pharmaceutical-producing GE crops.> > 3)Please reconsider your "business as 
usual" pharma crop policy, and instead> adopt one of two alternatives you 
proposed in the Draft Environmental Impact> Statement - a simple ban on outdoor 
cultivation of all> pharmaceutical-producing crops, or at least 
pharmaceutical-producing food> crops - to best protect public health and the 
environment.> > 4)Please regulate as necessary pesticide-promoting,> 
herbicide-tolerant GE crops in order to address the rise in pesticide use> 
these crops have fostered, and to mitigate the growing threat posed by> 
herbicide-resistant weeds to farmers and the interests of American> 
agriculture.> > 5)Remove any preemption clause that bars state and local 
authorities from> enacting laws or regulations to control GE crops as they best 
see fit.> [image: Sign this 
petition]<http://ga3.org/campaign/GMOregs/wedx7xsry7kiixxt?>> > Sign this 
Petition!> > Instructions:> Sign this petition 
<http://ga3.org/campaign/GMOregs/wedx7xsry7kiixxt?>> > Tell-A-Friend:> Visit 
the web address below to tell your friends about this.> Tell-a-Friend! 
<http://ga3.org/campaign/GMOregs/forward/wedx7xsry7kiixxt?>> > What's At 
Stake:> > > > > Campaign Expiration Date:> November 25, 2008> > 
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subject line).> > <http://www.convio.com/>> > > > -- > Mark Lipson> Senior 
Policy Analyst> Organic Farming Research Foundation> 831-426-6606 x109> 
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