Comments: Docket No. APHIS-2007-0044
Regulatory Analysis and Development PPD/APHIS
4700 River Road
Riverdale MD 20737-1238
farm we raise certified organic seed potatoes and vegetable and grain
northern Maine. We
have been farming organically for 34
We have been
for 28 years. We have been selling directly to organic consumers for
years and we are keenly aware of their expectation that organic food
be bonafide organic, pure and free of contaminants.
after studying the draft Roundup Ready Alfalfa Environmental Impact
(EIS) is that USDA-APHIS has done a remarkably inadequate and
incomplete job in
preparing the draft EIS which has led them to the erroneous position of
advocating for RR Alfalfa deregulation. USDA
needs to reverse course and prevent the planting of GMO alfalfa.
absolutely astounded by the baseless APHIS assertion on pgs 135-136
contamination of organic crops such as corn, soybeans and canola is not
impeding development of the organic sector. Because
of widespread genetic contamination of organic canola by GMO
canola, the organic canola industry has collapsed causing millions of
farm gate and
market loss. We
consider collapse an impediment to market development. It must be
and clearly stated that the organic consumer equates organic with
The customer is
right. It is incomprehensible and impossible to imagine that USDA-APHIS
be unaware that another USDA agency, the National Organic Program, in
received well over 200,000 written responses, at that time the largest
of public participation in the history of U.S.
administrative procedure, to
its early draft National Organic Rule. The principle reason for
common to virtually all letters submitted, was outrage that GMO crops
from the proposed
federal definition of organic. In time, USDA-NOP revised their Rule and
GMOs as an “Excluded method” [See NOP Rule Section
205.2 “Excluded methods” and
prohibition under Section 205.105(e)] prohibited in organic production.
there be no confusion: organic consumers absolutely do not want GMOs or
contamination in their food and seed.
here to read the rest of our comment on our blog.
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