Comment from Brooks, Dorothy

I have trust in other commenters here to thoughtfully answer the questions. What is more important than addressing those issues is pointing out how odious and disgraceful it is to publish such an important request for information without any general announcement to the public or APHIS customers. The USDA sends out countless stakeholder messages about the most trivial things, not for amusement, but because transparency is an essential part, by far the most important part, of ethical governance. The process of collecting comments for these questions is the opposite. Not only was there no press release, this posting is not even mentioned on the APHIS webpage for Biotechnology Commenting Opportunities! You know that this is wrong, shameful, and unacceptable. You know that it is not going to work. You also know that it is not lost on your stakeholders that the top legal positions in the department, who spearheaded this announcement, have deep connections to a company that stands to gain enormously by having a hand in alterations to biotechnology regulations. I don't imagine most of you care right now, but know that we know these things as well, and will not forget. I anticipate a proposed rule coming, and am excited to see what nonsense you all throw together. To your questions, of course genetically modified organisms pose risks that non-modified organisms do not. Modification opens up plants to millions more protein combinations, the uncertainty and potential are absolutely enormous. If there was no difference between modified organisms and organisms that are conventionally bred, there would be no interest in genetic modification. How one regulates a modified organism must depend on what trait is being added, along with the potential for unintended effects. The SECURE dealt with this rather well. Plants with no risk were deregulated rather quickly, in much larger numbers than before, and the process was getting more efficient. Of course, the definition of plant pest will always be controversial, different government agencies still need to work together to clarify their roles, non-plants needed to have a way to be moved out of regulation, and the public was (under SECURE) unable to see what was being deregulated in many cases, but overall, those are issues that can be addressed through policy. . Barring larger changes to biotechnology regulation throughout the government, moving back to that paradigm, with quick deregulation of organisms assessed to pose a low risk, would be extremely helpful for large and small developers and restore common sense to USDA regulation of biotech.