Re Comment Period Extension

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					October 20, 2008

Hon. Ed Schafer, Secretary
U.S. Department of Agriculture
1400 Independence Avenue S.W.
Washington, DC 20250

        Re: Comment Period Extension
            Proposed APHIS Rule
            Docket No. APHIS-2008-0023

Dear Secretary Schafer,

The undersigned farm organizations respectfully request that the time permitted for comment in
the above-entitled Docket be extended to 120 days from the date of publication (10/9/08) to
provide adequate time for farm groups and their membership to analyze the Proposed Rule and
make thoughtful comments.

Last year, the draft Environmental Impact Statement (EIS), which provides the basis for the
regulations being proposed in this Docket, was published on July 17, 2007. Comments on the
draft EIS were accepted through September 11, 2007. Despite nearly four years of inaction on
the EIS Docket, the USDA chose to publish the draft EIS to coincide with fall harvest and the
debate in Congress on the 2007 Farm Bill, effectively disenfranchising farmers and farm groups
from participation in the comment process.

The USDA characterizes these Proposed Rules as “the first comprehensive review and revision of
(agricultural biotech) regulations since they were first established in 1987.” Providing 45 days to
review, analyze and submit comments on issues of this magnitude and importance to the
American farmer is wholly insufficient, especially in light of the fact that these regulations are
again published during the height of harvest season.

The regulation of agricultural biotechnology has had a significant impact on farmers and their
livelihoods which must be addressed in this Docket. Systemic failures in the management and
oversight of regulated crop field trials led to widespread contamination of U.S. rice that cost
producers an estimated $1.25 billion – failures that were predicted by the USDA’s Inspector
General in a 2005 Audit. New legislative mandates for USDA management and oversight of field
trials were enacted in the 2007 Farm Bill and are purportedly being implemented in the Proposed
Rules. Farmers and farm groups will need time to assess and prepare comments on the
implementation of that legislation as we can ill afford another major contamination event.

Significant shortcomings with USDA’s deregulation process have been identified in recent court
cases. Monsanto’s Roundup Ready Alfalfa was re-regulated and an EIS ordered after a federal
District Court determined that the USDA had failed to adhere to the mandates of the National
Environmental Policy Act (NEPA) in deregulating that genetically engineered (GE) crop variety
and approving it for commercial use. The precedent established in that case requiring inter-
related economic impacts to be considered in the deregulation process is vitally important to
American farmers and time will be required to analyze and comment on its inclusion in the
Proposed Rules.

These are merely two examples of significant issues that need to be addressed in this Docket and
it is imperative that farmers and farm groups are provided ample time to assess how the proposed
regulatory framework will impact their livelihoods and that of the communities in which they
live. Many farmers will still be in the fields harvesting crops if the 45 day comment period, as
currently proposed by the USDA, is upheld. This debate is too important to the American farmer
to effectively disenfranchise his/her participation a second time around. A 120 day comment
period is not only reasonable but necessary to ensure that farmers’ voices are heard.

Thank you for your cooperation and support in this request. If you have any questions, please
feel free to contact Bill Wenzel, Director of the Farmer to Farmer Campaign on Genetic
Engineering, at (877) 968-3276 or via email at


American Agriculture Movement                   American Corn Growers Association

Farmer to Farmer Campaign on Genetic            National Family Farm Coalition

National Farmers Union                          Rural Advancement Foundation International

Western Organization of Resource Councils       Dakota Resource Council

Kansas Rural Center                             Missouri Rural Crisis Center

Rice Producers of California                    Rural Vermont