Comment from LOWER, THOMAS

The USDA's GMO regulatory framework fails to adequately protect the environment because it evaluates genetically engineered crops too narrowly and ignores many of their predictable real-world impacts. For decades, USDA regulation has centered on determining whether a genetically engineered plant is likely to act as a plant pest. While that question may be relevant, it is far from sufficient. Modern GMO crops are often designed to function within larger agricultural systems that rely heavily on herbicides or built-in insecticidal traits. Evaluating the crop while disregarding those intended uses results in an incomplete assessment of environmental risk. The environmental consequences of herbicide-tolerant cropping systems are well documented. Herbicide drift has damaged neighboring farms, organic operations, home gardens, trees, and wildlife habitat. Increased herbicide use has also raised concerns regarding impacts on pollinators, endangered species, biodiversity, and ecosystem health. Dicamba-resistant crops illustrate these concerns. The widespread injury caused by dicamba drift demonstrates that environmental harms can occur even when products are used according to their approved labels. Such outcomes should have been anticipated and incorporated into regulatory evaluations. In addition, insect-resistant GMO crops containing plant-incorporated protectants can contribute to the development of resistant insect populations, undermining long-term effectiveness and increasing pressure for additional pesticide use. The rapid expansion of gene-edited crops and synthetic biology applications makes comprehensive oversight more important than ever. New technologies should not be granted exemptions simply because existing regulations were written before these technologies existed. The USDA should adopt a precautionary, science-based regulatory framework that evaluates the cumulative environmental impacts of genetically engineered organisms and the agricultural systems in which they are intended to operate. EVIL IS AFOOT !!! $$$$$$$$$$$$$$$$$$$$$$$$$$