Request for Comment Extension RE: Docket No. APHIS-2014-0054 – Environmental Impact Statement; Introduction of the Products of Biotechnology
February 18, 2016
Regulatory Analysis and Development
PPD, APHIS, Station 3A-03.8
4700 River Road Unit 118
Riverdale, MD 20737-1238
Submitted Electronically via Federal eRulemaking Portal (http://www.regulations.gov)
Re: Docket No. APHIS-2014-0054 – Environmental Impact Statement; Introduction of the Products of Biotechnology
Dear Sir or Madam:
We, the undersigned organizations, appreciate the opportunity to provide comment on APHIS’ Notice of Intent (NOI) to prepare an environmental impact statement in connection with potential changes to APHIS biotechnology regulations (7 CFR 340). Our member organizations represent a broad cross-section of stakeholders having a significant interest in the future of U.S. agriculture, including farmers, grower groups, handlers, marketers, processors, manufacturers, distributors and exporters of agricultural products, as well as seed companies and technology providers.
Our organizations all have a significant stake in the ability of U.S. growers to have access to products of cutting-edge technologies, in fostering continued public confidence in the U.S. regulatory system and in preserving U.S. access to international markets. Innovative plant and animal breeding techniques, including biotechnology, hold enormous promise for improving the productivity and environmental sustainability of food, feed, fiber, biofuels, and animal production. We are fully committed to engaging constructively with APHIS to help the agency reach its regulatory goals and to develop a successful, broadly-supported system of regulation that provides risk-appropriate oversight that is consistent with the need for growers to have timely, reliable access to the products of innovative breeding techniques while at the same time not disrupting access to markets.
We are supportive of APHIS’s efforts to take a hard look at its regulations, to ensure that they are up-to-date with the best-available science and utilize the more than 20 years of experience APHIS has in reviewing the safety of these crops. However, because the options that APHIS is considering include potential major departures from the current regulatory framework, it’s critically important that adequate time be given so stakeholders may fully evaluate the NOI and its implications, including whether the regulatory alternatives presented are compatible with regulatory approaches utilized by other competent government authorities particularly those in important U.S. export markets, or, conversely, will pose a risk of trade disruptions...