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Reply to; BUREAU OF LAND MANAGEMENT TO HOLD PUBLIC SCOPING March 3 2022
March 27, 2023

REPLY to; BUREAU OF LAND MANAGEMENT SEEKS PUBLIC INPUT ON FUTURE MANAGEMENT (this is a N.E.P.A request)

link to request here; https://www.blm.gov/press-release/bureau-land-management-seeks-public-input-future-management-gold-butte-national

Thank you for allowing me to submit a comment regarding my concerns. One of my concerns is Genetic engineering (G.E) being used in public lands 

First off, thank you for the opportunity to voice my concerns, questions, and feedback regarding the future management plans for the Gold Butte National Monument. My first concern regards the Climate Change Agenda. A major component of the Climate Change Agenda is contingent on a new proposed rule change, ( Draft Guidance for Requesting a Regulatory Status Review (RSR) under 7 CFR part 340 ), of which only 8 total public comments were submitted. It was said by APHIS that the new rule change is the largest overhaul of G.E regulations within the last 25 years. The new rule change will have a De-Regulated clause Confirmation of exemption (de-regulation) 8-31-2022. The proposed change creates an easier process for developers to obtain patents on GE technology with little to no regulatory oversight, for deregulation status. My main concern is focused on “restoration efforts'' on public lands, which are to be funded by US tax dollars. I felt these plans would lead to private lease agreements, inflated costs for technology patent licenses, and potentially result in unintended environmental consequences.

Genetic manipulation of our natural resources ignores millions of years of natural biodiversity. Failure of government agencies to address the need for precautionary regulation and robust oversight with records and location of all genetic engineering would potentially jeopardize the environment. If in the future, best science proves that this technology failed, with no record or documented, then I feel Land managers would have failed their mission to protect our public lands

Attached is a lawsuit filed by the Center for Food Safety against USDA APHIS. The lawsuit details allegations regarding the release of G.E organisms within our public lands. I request that you validate each and every allegation set forth in paragraphs 1 through 237 of the complaint attached (complaint_27939 ) 

 Complaint_27939 outlines a number of concerns I feel the BLM should consider looking at before allowing the release and implementation of GE technologies without an EIS on public lands.  The EIS that APHIS used fails to use the best available scientific information in order to develop an appropriate range of alternatives to minimize contributions towards climate change. ( EIS attached; 340-secure-rule-eis) 

I implore BLM to consider requiring that the release of GE organisms have a stipulation similar to the USDA organic certification (attached; What is Organic Certification (1).pdf )

 

I ask BLM to consider ethical, transparent management concerning the use of GE organisms on public lands. I also ask the BLM to take necessary steps towards fostering discussions and outreach with the public, academic and scientific researchers, policymakers, and regulatory agencies around this matter 


In closing, I ask that the public comment period be granted an extension, for more time to submit comments. I do feel the public meeting provided direction for a rough comment, however, I felt 14 days was not enough time to voice an opinion, not to mention a few companies in the Arizona Strip, and the Mesquite Chamber of Commerce would like to submit a comment as well 

Hyperlinks have been used to quickly navigate to the online information

Thank you for your time and attention, I truly appreciate it. 

Josh Wilson 

March, 3rd 2022


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