NCC Comments on EIS Notice Regarding GE Organisms

The National Cotton Council submitted comments to USDA's Animal & Plant Health Inspection Service on its Notice of Intent to prepare an Environmental Impact Statement in connection with potential changes to regulations regarding certain genetically engineered organisms.

Published: April 22, 2016
Updated: April 22, 2016

April 21, 2016

Mr. Sidney W. Abel
Assistant Deputy Administrator
Biotechnology Regulatory Services
4700 River Road Unit 147
Riverdale, MD 20737-1236

RE: Environmental Impact Statement: Introduction of the Products of Biotechnology.Docket No. APHIS-2014-0054

Dear Mr. Abel:

The National Cotton Council (NCC) appreciates the opportunity to comment on the Animal and Plant Health Inspection Service (APHIS) Notice of Intent to prepare an Environmental Impact Statement (EIS) in connection with potential changes to regulations regarding certain genetically engineered organisms.The NCC compliments APHIS for providing 28 years of scientific review and protection in a risk-based approach that has not diminished scientific discovery and development of tools and techniques to advance efficient agricultural production.

The NCC is the central organization of the United States cotton industry.Its members include producers, ginners, cottonseed processors and merchandizers, merchants, cooperatives, warehousers and textile manufacturers.A majority of the industry is concentrated in 17 cotton-producing states stretching from Virginia to California. The NCC represents producers who cultivate between 10 and 14 million acres of cotton.Annual cotton production, averaging approximately 16 to 20 million 480-lb bales, is valued at more than $5 billion at the farm gate.The downstream manufacturers of cotton apparel and home furnishings are located in virtually every state. Farms and businesses directly involved in the production, distribution and processing of cotton employ more than 230,000 workers and produce direct business revenue of more than $27 billion.Accounting for the ripple effect of cotton through the broader economy, direct and indirect employment surpasses 420,000 workers with economic activity well in excess of $120 billion. In addition to the cotton fiber, cottonseed products are used for livestock feed, and cottonseed oil is used as an ingredient in food products as well as being a premium cooking oil.

The NCC urges APHIS to proceed with updating regulations in a manner that maintains the risk-based scientific approach while reflecting advanced understanding for the development and commercialization of biotechnology products.The NCC encourages APHIS to ensure any updates clearly identify a role and responsibility of APHIS that is consistent with the Federal Coordinated Framework for the Regulation of Biotechnology.The NCC is pleased APHIS intends to ensure any process and procedural change is conducted in a clear and transparent manner.

The NCC has reviewed the four regulatory approaches presented for consideration.The NCC encourages APHIS to further develop the second alternative presented, while recognizing the need for efficiency, maintaining the scope of authority, and avoiding disruption of international trade.The NCC believes the two-step process proposed in the second alternative should enhance efficiency, but expresses concern that APHIS' proposed new definition of biotechnology seems to expand authority.The NCC appreciates the desire to "analyze first, regulate when necessary" but urges APHIS to consider expanding exemptions or maintaining the previous definition of biotechnology.Exemptions should include techniques, such as gene markers, that simply enhance efficiency of traditional, conventional plant breeding methods.

The NCC urges APHIS to cautiously recognize and avoid unnecessary international trade issues that could be disrupted by any changes to the U.S. regulatory practices. Additionally, APHIS should recognize the scope of authority of other agencies and avoid duplicative processes. As APHIS points out, the Plant Protection Act (PPA) provides authority to protect plant health in the United States.APHIS should maintain a focus on the risk of plant pests and noxious weeds while exercising caution to avoid expanding the scope by broadening interpretations.The NCC urges APHIS to maintain its historical focus.

The NCC emphasizes that biotechnology has provided tremendous efficiency in agricultural production and has greatly enhanced societal desires for improvements toward target specific pest control.The NCC is pleased that scientific advancements continue to enhance a producer's ability to provide food and fiber to a growing world population in a continually improved manner.The NCC appreciates APHIS risk based approach to ensure these advancements are scientifically sound without risk as plant pests or injurious to plant health.APHIS should use its 28 year history to become more timely and efficient in "analyze first, regulate when necessary" practices in support of scientifically sound agricultural practices.

Respectfully submitted,

Reece Langley
VP – Washington Operations
National Cotton Council of America