This is a copy of an email from Union of Concerned Scientists regarding submitting personalized individual comments to USDA about the overhaul of biotechnology regulations for any of you who are interested.  Remember from 2007, rice contamination happens.  Regulation is at an all time low, shoddy level;deregulation rules and ruins:

Dear UCS supporters,
 
Thank you for signing up to submit personalized comments to the U.S. Department of Agriculture (USDA) Animal and Plant Health Inspection Service (APHIS) regarding its proposed overhaul of regulations of genetically engineered (GE) crops. As you know, UCS is focusing particularly on aspects of the proposal that deal with GE crops grown to produce drugs and industrial chemicals (pharma crops).
 
The full text of the proposed regulations may be found at:
http://edocket.access.gpo.gov/2008/pdf/E8-23584.pdf
 
Below, please find an in-depth analysis from UCS regarding the APHIS proposal. We hope that you will use this analysis as a source, along with materials we link to throughout this email, to craft your own thoughtful comments to the agency. While sending thousands of identical form letters helps send a message of broad support, personalized letters can carry great weight. (Note, if you have decided that you don't have time to write your own comments, look for an action alert from me on Friday that will allow you to submit a form letter through our action center.)
 
Before I get into the substance, I just want to offer a few general guidelines that will help give your comments the greatest impact possible.
Stay on topic. While you may be tempted to tell APHIS in ALL CAPS how you feel about Monsanto, the Administration, or other matters, this is not going to have a positive effect on the rulemaking process at hand. APHIS staff are looking for specific reactions to the specific text of the proposed regulations. They are required to consider and respond to comments which meet this criteria. So, while you can couch your comments in the context of your general view on agriculture, politics, or other broad topics, please keep this content limited and focus on the specific topic at hand.
Be polite, calm, and professional. Please, no ad hominem attacks. Check your spelling and your tone before you submit your comments.
Cite your credentials. If you are a farmer, an academic, a doctor, a parent... say so!
Please send me a copy. I'd like to see what messages our members are generating. After you submit your comments to USDA, please email me a copy at jpalembas@ucsusa.org.
HOW TO SUBMIT:
**DEADLINE: November 24**
 
--Submit electronically
Go to www.regulations.gov/fdmspublic/component/main?main=DocketDetail&d=APHIS-2008-0023. At the far right on the first page under "Add Comments," click on the yellow icon. Then follow the instructions for the Public Comment and Submission Form. Note that you can type your comments in the box provided OR attach a file (Word doc, pdf, etc.) containing your comments.   
 
--Submit in paper form via postal mail/commercial delivery
Send two copies of your comments to Docket No. APHIS-2008-0023, Regulatory Analysis and Development, PPD, APHIS, Station 3A-03.8, 4700 River Road Unit 118, Riverdale, MD 20737-1238. State that your comments refer to Docket No. APHIS-2008-0023
 

Please let me know if you have any questions or comments.

 

Sincerely,

 

Jenn Palembas

Outreach Coordinator, Food and Environment Program

Union of Concerned Scientists


--------------------------------------------------------------------------------

 
USDA APHIS PROPOSED CHANGES TO PHARMA CROP REGULATIONS
In early October, the U.S. Department of Agriculture (USDA) Animal and Plant Health Inspection Service (APHIS) released a proposed rule (Federal Register 73:60008-48) overhauling the agency's biotechnology regulations. UCS is particularly concerned about proposed changes to the agency's oversight of crops that are genetically engineered to produce drugs and industrial chemicals (pharma crops). These crops are not meant to enter the food supply and could be dangerous to humans if consumed, yet they are being grown outdoors in human food staples like corn and rice.

 

UCS has long called on the agency to ban the outdoor production of pharma crops in crops also used for food, and pointed out the sensible alternatives that would allow employment of this technology without the risks. Yet the agency's proposal-rushed through in the waning days of the current administration-goes in the opposite direction, weakening oversight of these crops.

 

Below, we have provided a preliminary analysis of the APHIS proposal. UCS will submit final comments to APHIS before the November 24, 2008 deadline.

 

CONTENTS

BACKGROUND
THE PROPOSED RULE WEAKENS OVERSIGHT OF PHARMA CROPS
THE PROPOSED RULE FAILS TO PROTECT THE FOOD SUPPLY
THE PROPOSED RULE FAILS TO TAKE ECONOMIC CONSEQUENCES FULLY INTO ACCOUNT
CONCLUSION

BACKGROUND

 

A primary purpose of the agency's rulemaking is to align the regulations with the Plant Protection Act (PPA) of 2000, which expanded APHIS's authority to control the risks of genetically engineered (GE) crops by consolidating a number of plant health laws including the Noxious Weed Act and the Federal Plant Pest Act (under which GE crops have been regulated since 1987).

 

In July 2007, APHIS asked for comments on a draft environmental impact statement (EIS) on various options for the regulatory overhaul. NGOs, food companies, the Grocery Manufacturers Association, and thousands of individual citizens responded by calling on the agency to adopt a ban on the outdoor use of pharma food crops.

 

After review, we have concluded, first, that the proposed rule weakens APHIS's already inadequate pharma crop regulations. Not only has the agency disregarded public comments calling for a ban, it has taken instead taken the proposed rule in the opposite direction. Second, the proposal does not adequately protect the food supply. Finally, the rule fails to take the economic consequences of the outdoor production of pharma food crops fully into account.

 

In response to the flawed proposed rule, UCS renews its recommendation for a ban on the outdoor production of pharma food crops.

 

In addition, from the beginning of its effort to overhaul biotechnology regulations, APHIS has followed an irregular process under the National Environmental Policy Act (NEPA). The draft EIS was published more than a year before the proposed rule, and because its content was more policy than scientific, it did not appear to meet NEPA requirements. Now, APHIS has proposed a new rule and requested public comment in the absence of a final EIS and without responding to comments about the adequacy of the draft statement. According to the proposal, the agency intends to publish a final EIS when it issues the final rule.

 

To correct the irregular NEPA process and provide for robust public participation in the rule making process, UCS has asked APHIS to prepare and publish a final EIS on the proposed rule as soon as possible, and extend the current comment period on the proposed rule until the public has had sufficient time (at least 60 days) to consider them in light of their likely environmental impacts.

 

Below are arguments supporting our conclusion. Page numbers in the text refer to pages in the Federal Register notice.

 

1.  THE PROPOSED RULE WEAKENS OVERSIGHT OF PHARMA CROPS

The rule, if it were finalized, would eliminate the class status of pharma crops, freeing the agency from the current requirement that all pharma crops be placed in a high-risk category accompanied by more stringent regulatory oversight than that for most other GE crops. Instead, APHIS would be able to place pharma crops in lower-risk categories and issue permits with weaker controls. Below we compare APHIS's current and proposed systems for assessing pharma crop risks and assigning regulatory controls.

 

Assessing risks

The proposed rule, by abandoning the current requirement to consider all pharma crops as higher risk, gives APHIS considerable discretion to place pharma crops in lower-risk categories.

 

Current program

Under the existing system, APHIS has no discretion in categorizing pharma crops according to risk. Rather the agency must place all pharma crops in a higher-risk category for which it requires permits before release into the environment. Each year about 10% of GE crop applications for field testing fall into the permit category (p 60010). Under the permitting process, the agency can require more stringent regulatory controls than it typically imposes on the other 90%, which fall under the notification process. APHIS set up the notification process in 1993 to expedite the review of GE-crop field trials that it categorized as lower risk.

 

Proposed program

In general-

The proposed rule, pp 60015-16, would establish a new permitting system requiring permits for all releases to the environment, thereby eliminating the notification process. We congratulate the agency for its decision to abandon notifications. The new system would establish four risk or permit categories, ranging, in increasing levels of risk, from A (lowest risk) to D (the highest).

 

APHIS explains the relationship between the proposed risk categories and the current system as follows (p 60019):

 

Category A will be associated with a level of regulatory oversight similar to environmental release notifications under the current system, and Categories B and C with a level of regulatory oversight similar to various permits that have been issued under the current system." .  Category D was created to acknowledge the possibility that some proposed releases may pose a very high risk of introducing a highly persistent or harmful plant into the environment. To date, APHIS has never been requested to allow releases that would fall into this category. If an applicant were to propose a Category D release, APHIS would only authorize such releases after imposing extremely strict levels of oversight akin to high security quarantine far exceeding that of Category C ..

 

For pharma crops specifically-

The effect of the proposed rule would be to abandon the class status of pharma crops and give APHIS considerable discretion to place pharma crops in any of the four risk categories. The agency indicates how it might view the risks of pharma crops under the new system on pp 60031 and 60020, respectively:

·          "We have not see evidence suggesting that [pharma crops] present unique or uncontrollable risks, or risks higher than those that may be associated with many other uses for GE plants."

·          "Based upon APHIS experience to date, many releases of GE plants producing pharmaceutical or industrial substances would fall in Category C, and would carry the same level of oversight as current permits for [plants making pharmaceutical and industrial compounds]." 

 

The use of the word "many" in the second quote leads us to believe that APHIS intends to downgrade, in some instances, at least, its current practice of placing all pharma crops in a class equivalent to category C. Given the relatively benign view of pharma crop risks expressed in the first quote, we would expect that the other categories would be the lower-risk categories A and B.

 

That expectation is supported by the agency's discussion on pp 60017-20 of how it would place crops into the categories. The examples given there of the types of organisms that would fall into each category suggest to us that APHIS would place some pharma crops in categories A and B, which are lower risk than the category C that the agency says would be equivalent to the pharma class designation in the current system. We would expect that only rarely, if at all, would a pharma crop be placed in category D, which is reserved for "very high risk" organisms.

 

In summary, under the proposed rule, APHIS would abandon its current policy that all pharma crops belong in a higher-risk category and would have considerable discretion allowing placement of pharma crops in lower-risk categories.

 

Assigning regulatory controls

Under the proposed rule, APHIS would eliminate the specific regulatory controls currently imposed on pharma crops. Instead, the agency would have considerable leeway to assign regulatory controls commensurate with the level of risks, meaning that pharma crops placed in lower-risk categories would have less stringent controls than currently required.

 

Current program

The current program overseeing pharma crops is described in "Draft guidance for APHIS permits for field testing or movement of organisms with pharmaceutical or industrial intent," released in spring 2006. That document details:

·          the permitting process for pharma crops

·          the information requirements for submitting an application for a pharma crop permit

·          the permit conditions to be imposed on the pharma crop permit holder, and

·          APHIS's obligations for inspecting pharma crop field sites.

 

Specifically, permit conditions refer to practices and procedures that a permit holder must follow, including field test confinement practices, such as spatial separation from other crops, cleaning machinery, post-harvest land use, site security; personnel management; record keeping; and reporting requirements. For example, APHIS currently requires a pharma crop permit holder to submit five separate reports or notices: a pre-planting notice, a planting report, a pre-harvest notice, a field test report, and a volunteer-monitoring report.

 

Under the existing program, APHIS inspects pharma crop field tests more often than other permitted field tests or tests subject to notification. The Draft Guidance (p 30) states: "a field test may have five inspections during the growing season and two additional inspections postharvest; however APHIS may inspect more frequently in some cases." By contrast, other permitted field tests may be inspected only once a year and tests conducted under notification may not be inspected at all.

 

Proposed program

By abandoning the class status of pharma crops, the proposed rule would eliminate the specific regulatory controls, mentioned above, that are attached to pharma crop permits under the current program. Instead, pharma crops would be subject to the new permitting process where regulatory controls would be set at APHIS's discretion according to risk category. Moreover, the proposed rule, for the most part, would set only minimal basic regulatory requirements for the risk categories and would allow APHIS considerable leeway in determining the stringency of oversight, including information requirements, permit conditions, and frequency of inspections.

 

Even for pharma crops that might be placed in the higher-risk category C, the proposed rule would not require the same stringency in permit conditions imposed by the current class-based program. (APHIS could use its discretion to impose additional requirements to bring the oversight to today's level.)

 

In effect, under the proposed rule, APHIS could significantly reduce the stringency of  regulatory controls imposed on pharma crops compared with current practices.

 

2.   THE PROPOSED RULE FAILS TO PROTECT THE FOOD SUPPLY.

APHIS turned down opportunities afforded by the expanded authority of the PPA, specifically the provisions related to noxious weeds, to strengthen oversight of the food safety risks of pharma and other GE crops.


 

Under the PPA, APHIS has the authority to evaluate "whether a particular GE plant may be a noxious weed because it poses a public health risk when growing in the environment" (p 60014). However, the agency failed to take advantage of the expanded authority despite acknowledging that noxious weeds could potentially threaten public health if they entered the food supply and despite its assertion that the agency "plays an important supporting role in safeguarding the food supply by protecting the health of plants and animals at the farm level" (p 60014).

 

Instead the agency offers what appears to be a narrow interpretation of its responsibility for protecting the food supply from noxious weeds by noting that "the noxious weed definition should not be interpreted so broadly as to provide APHIS with the legal responsibility or authority to . prevent GE crops from entering the food supply" (p 60029). 

 

We are left only with vague indications of how APHIS will safeguard the food supply within this narrow interpretation. In terms of risk assessment, the agency merely states, without explanation, that it "would consider available information about toxicity and other food safety information in assessing noxious weed risk posed by the plants growing in the environment" (p 60014) and "it is also likely that existing [Food and Drug Administration (FDA)] food safety evaluations will prove to be useful and relevant to APHIS evaluations.." (p 60029).

 

In assigning regulatory controls, APHIS says, again without explanation, that food safety concerns would be one of several factors taken into account when considering permit conditions or exemptions from permit requirements (p 60029).

 

Finally, the agency promises to "contact" the Food and Drug Administration if it is "concerned" about food safety risks of a GE crop (p 60029) but offers no explanation of what would trigger "concern" nor does it propose any interagency process for dealing with these concerns.

 

3.   THE PROPOSED RULE FAILS TO TAKE ECONOMIC CONSEQUENCES FULLY INTO ACCOUNT

The Plant Protection Act gives APHIS the authority to consider the economic consequences of harm caused by a noxious weed (pp 60012-60014). However, the proposed rule too narrowly defines the scope of economic harm because it would not "consider significant economic effects alone that are not linked to physical damage to be sufficient to determine a plant is a noxious weed" (p 60014).

 

In other words, the agency would not consider the economic losses incurred by the food industry, grain elevators, and others if a pharma crop contaminated the food supply but did not cause physical harm. APHIS writes: "the economic loss is never simply the result of marker preference to have commodities free of certain noxious weed seeds in and of itself, in the absence of any potential physical damage or harm" (p 60014).

 

APHIS should expand the definition of economic harm to include the adverse effects of contamination by unapproved GE traits on customers and markets.

 

CONCLUSIONS

UCS urges APHIS to correct its irregular NEPA process by publishing an EIS on the proposed rule before issuing the final rule and to extend the comment period on the proposed rule for 60 days beyond the release of the EIS.
UCS calls on APHIS to reconsider its weakening of pharma crop oversight. The agency should instead adopt a ban on all outdoor production of all pharma food crops.
 

--------------------------------------------------------------------------------

Jenn Palembas, Outreach Coordinator
Food and Environment Program
Union of Concerned Scientists
P. 202.331.5435 F. 202.223.6162  E. jpalembas@ucsusa.org

1825 K Street NW, Suite 800
Washington, DC   20006-1232
 
Make your voice heard on important environmental and security issues.
Join the Union of Concerned Scientists Action Network at http://www.ucsaction.org

DMS appreciate the post on wanting all GMO'd crops banned. Anyone in the child bearing years could face infertility for life? Like I always felt cancer, kidney problems, infertility now, just don't happen or is heriditary - the chemicals in the food, air and water all do damage only its a cumulative effect - can't pin it down from years of being exposed and eating this stuff day after day after day, etc.

Not exactly what I was hoping to hear:

http://gristmill.grist.org/story/2008/11/19/6373/9820

Update [2008-11-20 5:47:7 by Tom Philpott]: Correction: Jill Richardson of La Vida Locavore pointed me to an error in the original post. About former Monsanto vice-president and FDA official Michael R. Taylor, I had written that "He was particularly useful in the effort to prevent abstaining dairies from advertising their milk as rBGH-free." Not so, Jill informs me. Taylor actually supported allowing dairies to label their milk rBGH-free, so long as they made no health claims. The error has been removed from the below text. I regret the error.
Whither [edited]'s food/ag policy?

I don't think I'm a jaded enough observer of Washington's ways to figure it out. But here's what I know.


The transition named its "team members" looking at energy and natural resources agencies, which includes USDA. The list includes Michael R. Taylor, a man who spent his career bouncing between the employ of GMO-seed giant Monsanto and Bill Clinton's FDA and USDA. Taylor is widely credited with ushering Monsanto's recombinant bovine growth hormone (rBGH) through the FDA regulatory process and into the milk supply.

Over on Ethicurean, Steph Larsen of Center For Rural Affairs has a good post on the dreary real politics around who gets to be the next USDA chief. Have you seen those lists (like this one) that contain names like Hightower and Pollan? Forget about it, Steph says. According to Steph: "The process of becoming Secretary of Agriculture begins long before a presidential election. Candidates typically have myriad political connections and make themselves useful in the campaign of the eventual winner. By election time, the list of possibilities is already well-established." That means the petition currently being circulated to demand Pollan be chosen is doomed. And anyway, who would leave an endowed Berkeley professorship and a regular gig at The New York Times Magazine to run a sprawling bureaucracy?

So who are the serious candidates for USDA chief? Steph's post contains a list, and here's one from Reuters and another from an ag trade publication. These are hardly inspiring names. Even in this era of "change," it seems like you generally need to have proven your fealty to GMOs and corn-based ethanol to win serious consideration as USDA chief. Former Iowa governor Tom Vilsack, who briefly vied for the Democratic presidential nomination in 2007, is emerging as a front-runner. Vilsack hews tightly to the biotech-industry party line; and he hotly promoted corn-based ethanol while governor. On the other hand, none other than Grist's own David Roberts declared his energy plan during last year's Democratic primaries the "ballsiest and most detailed any candidate from either party has offered." And Ferd Hoefner of the Sustainable Agriculture Coalition told me that Big Ag commodity groups had mounted a backroom campaign against Vilsack's bid for USDA chief. Evidently, the former governor is more of a champion of conservation programs than they can tolerate.

There are certainly more egregious names on the short list than Vilsack. Last week, Pennsylvania ag secretary Dennis Wolff emerged as a contender. Wolff is notorious for unilaterally trying to prevent his state's dairy farmers for labeling their milk rBGH-free. Former Texas congressman and Big Ag lobbyist Charles Stenholm is another profoundly depressing name.


One name I'm intrigued by is John Boyd, president of the National Black Farmers Association. Boyd helped lead the fight to hold USDA accountable for its long history of stiffing black farmers; his nomination is being championed by the Congressional Black Caucus. Virginia-based Boyd himself runs a relatively small-scale farm; seems like his position as a USDA outsider might lead him to champion the interests of small farmers in an agency that's long been beholden to large industrial operations.

Michael Pollan,  who recently laid out an ambitious blueprint for ag policy in the next administration that [edited] says he has read, recently appeared on the Brian Lehrer show. Pollan expressed optimism that [edited] would move in progressive directions on ag, declaring the president-elect the most synthesis-oriented   chief executive we've had in a long time. Pollan laughed off speculation that he could be appointed USDA chief, noting that the marijuana chapter of Botany of Desire would cause vetting trouble; and pushed the idea, which he first floated on Grist, that [edited] name a "food czar."
==============================

Hopefully, that won't mean "sythesis" as in more genetically engineered food!  Or biofuel crops, but I think the president elect leans that way.  Let him know what you think, either way.

http://www.growersforbiotechnology.com/

Sugar from genetically engineered sugar beets will begin entering the food stream in the next several months, although exactly when will be difficult to determine. U.S. law does not require genetically engineered sugar to be segregated from non-engineered sugar, nor to be labeled for the consumer. (Sugar beet sugar accounts for roughly half of total U.S. sugar production, with the balance of U.S. sugar coming from sugarcane.)

The likelihood of genetically engineered DNA from Roundup Ready sugar beets migrating into chard and beet seed packets is high. Sugar beets, chard and table beets are all members of the beta genus and sexually compatible. These kissing cousins are wind-pollinated, and the overwhelming majority - 90 percent or more - of the nation's sugar beet and chard seed, along with some of its table beet seed, is grown in a single location, Oregon's Willamette Valley.

Contamination won't be apparent and will go undetected unless every chard and table beet seed lot is tested for genetic purity. Even with testing, risk of contamination remains. "They can only test 10,000 seeds at a time, so what you get is essentially a test that tells you to 1 in 10,000 parts whether or not it is contaminated, so you are only accurate down to about .01 percent," Morton said.
-----------------------------
Now the good news:
----------------------------
Legal Tussle Over Modified Sugar Beets
- Deborah K. Rich, San Francisco Chronicle, Nov. 8, 2008

Home gardeners seldom grow sugar beets, but the commercialization of Roundup Ready sugar beets could toss genetically engineered DNA into many a garden-fresh salad unless a lawsuit prevails.

The suit, filed by the Center for Food Safety, Organic Seed Alliance, High Mowing Organic Seeds and the Sierra Club, is expected to be heard April 3 in U.S. District Court in San Francisco. It seeks to halt the planting, sale and use of Roundup Ready sugar beets until the U.S. Department of Agriculture conducts an in-depth environmental study of this latest genetically engineered crop. Roundup Ready sugar beets - which can withstand repeated applications of glyphosate, the active ingredient in Monsanto's Roundup herbicide - gain their chemical tolerance from a gene that Monsanto plucked from a soil bacterium and pasted into the sugar beet genome.

Among the environmental concerns the plaintiffs want the Agriculture Department to consider is the potential for DNA from genetically engineered sugar beets to contaminate the U.S. chard and table beet seed stock.
---------------------------------------------

Geez!  You think the safety study might have already been done--since the crops are in the ground and some are already harvested. 

More on Micheal Pollan's advice to the next president.  The president-elect did refer to this article in a speech.  I just hope he truly considers it.  After all of the preceeding gloom and doom, I am happy to end my posts to Pandora today with this glimmer of sunshine:

http://www.ecoliteracy.org/publications/michael_pollan_farmer.html

Farmer in Chief
By Michael Pollan

Michael Pollan, a contributing writer for The New York Times Magazine, is the Knight Professor of Journalism at the University of California, Berkeley. He is the author, most recently, of In Defense of Food: An Eater's Manifesto.

Dear Mr. President-Elect,

It may surprise you to learn that among the issues that will occupy much of your time in the coming years is one you barely mentioned during the campaign: food. Food policy is not something American presidents have had to give much thought to, at least since the Nixon administration – the last time high food prices presented a serious political peril. Since then, federal policies to promote maximum production of the commodity crops (corn, soybeans, wheat and rice) from which most of our supermarket foods are derived have succeeded impressively in keeping prices low and food more or less off the national political agenda. But with a suddenness that has taken us all by surprise, the era of cheap and abundant food appears to be drawing to a close. What this means is that you, like so many other leaders through history, will find yourself confronting the fact – so easy to overlook these past few years – that the health of a nation's food system is a critical issue of national security. Food is about to demand your attention.

Which brings me to the deeper reason you will need not simply to address food prices but to make the reform of the entire food system one of the highest priorities of your administration: unless you do, you will not be able to make significant progress on the health care crisis, energy independence or climate change. Unlike food, these are issues you did campaign on – but as you try to address them you will quickly discover that the way we currently grow, process and eat food in America goes to the heart of all three problems and will have to change if we hope to solve them. Let me explain.

Put another way, when we eat from the industrial-food system, we are eating oil and spewing greenhouse gases. This state of affairs appears all the more absurd when you recall that every calorie we eat is ultimately the product of photosynthesis – a process based on making food energy from sunshine. There is hope and possibility in that simple fact.

At issue is not only the availability of food, which may be held hostage by a hostile state, but its safety: as recent scandals in China demonstrate, we have little control over the safety of imported foods. The deliberate contamination of our food presents another national-security threat. At his valedictory press conference in 2004, Tommy Thompson, the secretary of health and human services, offered a chilling warning, saying, "I, for the life of me, cannot understand why the terrorists have not attacked our food supply, because it is so easy to do."

This, in brief, is the bad news: the food and agriculture policies you've inherited – designed to maximize production at all costs and relying on cheap energy to do so – are in shambles, and the need to address the problems they have caused is acute....The American people are paying more attention to food today than they have in decades, worrying not only about its price but about its safety, its provenance and its healthfulness. There is a gathering sense among the public that the industrial-food system is broken. Markets for alternative kinds of food – organic, local, pasture-based, humane – are thriving as never before. All this suggests that a political constituency for change is building and not only on the left: lately, conservative voices have also been raised in support of reform. Writing of the movement back to local food economies, traditional foods (and family meals) and more sustainable farming, The American Conservative magazine editorialized last summer that "this is a conservative cause if ever there was one."

There are many moving parts to the new food agenda I'm urging you to adopt, but the core idea could not be simpler: we need to wean the American food system off its heavy 20th-century diet of fossil fuel and put it back on a diet of contemporary sunshine. True, this is easier said than done – fossil fuel is deeply implicated in everything about the way we currently grow food and feed ourselves. To put the food system back on sunlight will require policies to change how things work at every link in the food chain: in the farm field, in the way food is processed and sold and even in the American kitchen and at the American dinner table. Yet the sun still shines down on our land every day, and photosynthesis can still work its wonders wherever it does. If any part of the modern economy can be freed from its dependence on oil and successfully resolarized, surely it is food.

Would be so nice if this is really going to be considered. But DMS with all the huge factory farms out there - will they fight this tooth and nail? It may be too late for them to fight it anyway as more and more are turning to organic, local, grass fed, etc since trust in the food supply is been deeply shattered. The article above says what a lot of people are doing and feeling.

More on, or is that "moron," the pharma crop debate:

http://www.ucsusa.org/assets/documents/food_and_agriculture/ucs-economics-pharma-crops.pdf

Disposal of crop residues. Another potential
cost, depending on the pharma crop, is disposal
of the residue remaining after the pharma portion
of the crop has been harvested and processed. If
stalks, seed pods, and husks contain drug residues,
this could represent a signifi cant expense. Disposal
of portions of the kernel remaining after drug
processing could also present costs and challenges.
Some have considered using these by-products
in the livestock feeding industry,
[doesn’t that ultimately end up in the human food chain?]
 but doing so would
increase the risk of commingling with the food
supply. Several tons of these by-products are produced
per acre of pharma crop, and depending on
the type of crop being grown, residue left in fi elds
could also pose environmental hazards to wildlife.

Pharma crops:

"Disposal of crop residues. Another potential
cost, depending on the pharma crop, is disposal
of the residue remaining after the pharma portion
of the crop has been harvested and processed. If
stalks, seed pods, and husks contain drug residues,
this could represent a signifi cant expense. Disposal
of portions of the kernel remaining after drug
processing could also present costs and challenges.
Some have considered using these by-products
in the livestock feeding industry,
[doesn’t that ultimately end up in the human food chain?]"

Once again...  Instead of PROPERLY DISPOSING of industrial wastes, let's shop around for an outlet to make some money.  What better place?  Once again, animals for human consumption is a possible dumping ground.  Unbelievable!  Well, not really.  Remember the chicken feed studies of adding glycerin (bio-diesel waste) to their diets to see how much can be added to their rations so the garbage can be marketable, but still not affect the chickens' appetite so they can reach slaughter weight?

These rich CEO's, who can easily afford organic and locally-grown meats and produce, wouldn't feed their OWN FAMILIES these meats!  You can bet on that!   

With our government being controlled by big Ag/Food  and Pharma industries, the masses are at great risk, especially those on modest budgets!  People should spend the bulk of their money on the very best food, pay their rent/mortgage/heating bills, and do without or trade for other items.