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Ray Clark Provides Expert Testimony on NEPA and Genetically Modified Organisms

March 13, 2008

The Domestic Policy Subcommittee of the House Oversight and Government Reform Committee requested Ray Clark provide testimony at a hearing on the U.S. Department of Agriculture’s (USDA) compliance with the National Environmental Policy Act (NEPA) with respect to the regulation of genetically modified organisms.

One of the critical issues addressed during the hearing was USDA’s obligations under NEPA to analyze economic impacts on farmers resulting from a USDA decision to deregulate and / or permit field testing of genetically modified organisms. Mr. Clark testified that USDA has a responsibility to take a “hard look” at the environmental and socioeconomic impacts of its decisions in the NEPA analytical process. At the hearing, Mr. Clark stated, “There is a very strong case here for the linkage between the biophysical environment and the social and economic well-being of the farming community at large. The linkage between environmental, social, and economic effects is precisely the kind of analysis that Congress intended with the [NEPA] statute and it is precisely the kind of linkage that CEQ saw when the [NEPA] regulations were drafted in 1979.”

Mr. Clark also provided recommendations on opportunities for USDA to promote better decision-making through NEPA, including on the use of programmatic analyses and an ecosystem approach to analyses that includes environmental monitoring and adaptive management.

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