BIO comments to APHIS on 2,4 D- and dicamba-tolerant crops

July 17, 2013

Docket No. APHIS-2013-0042
Docket No. APHIS-2013-0043
Regulatory Analysis and Development
PPD, APHIS, Station 3A-03.8
4700 River Road Unit 118
Riverdale, MD 20737-1238

Re: Notice of Intent to Prepare an Environmental Impact Statement for Determination of Nonregulated Status of Herbicide Resistant Corn and Soybeans - Dow AgroScience

Notice of Intent to Prepare an Environmental Impact Statement for Determination of Nonregulated Status of Herbicide Resistant Soybeans and Cotton - Monsanto Company

To whom it may concern:

The Biotechnology Industry Organization (BIO) appreciates the opportunity to comment on the above-captioned Notices of Intent (Notices) to prepare Environmental Impact Statements (EISs) for herbicide tolerant crops under the National Environmental Policy Act (NEPA) issued by the Animal and Plant Health Inspection Service (APHIS), U.S. Department of Agriculture (USDA), 78 Fed. Reg. 28,798 and 28,796 (May 16, 2013).  BIO respectfully submits that these EISs are not required under the law, are an unnecessary expenditure of scarce government resources, will not advance or assist APHIS's decision-making, and will only delay unnecessarily the availability of these crops that, under APHIS's governing statute and regulations, are strong candidates for determinations of nonregulated status or "deregulation."

 

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