N.O.R.M. enters rebuttal to FDA presumptions on Federal Register

680 E. 5 Point Hwy. Charlotte, Mich. (48813) 517-543-0111

http://www.normeconomics.org

NORMeconomics@att.net

“FDA is not and, by the construction of this government, cannot be authorized to determine its own jurisdiction. It must operate within the bounds of the administrative structure authorized by the legislative power harmonious with the limited, delegated powers identified in our constitutional system.”

 

June 7, 2010

RE: FDA-2010-N-0085

To Whom it may concern:

This document is submitted by:

National Organization for Raw Materials (NORM, http://www.normeconomics.org)

and:  See list below for names of those submitting)

_______________________________________

This comment seeks to inform the development of an FDA regulation establishing “safety standards for fresh produce at the farm and packing house” and sanctions for non-compliance. In doing so, it rebuts the jurisdictional presumption through which, under the guise of “food safety,” FDA seeks to vastly exceed the reach of its federal regulatory sphere of action.

Federal executive regulatory power is seated in and restricted to the delegations specified within the Constitution. As stated in Art. I, §8, cl. 18, “Congress shall have power to make all laws which shall be necessary and proper for carrying into execution the foregoing powers, and all other powers vested by this Constitution in the government of the United States, or in any department or officer thereof.” Regulatory jurisdiction statutorily delegated to any agency cannot exceed the jurisdiction of the legislative authority as constitutionally specified.

Taxpayers continue to foot the bill for wild horse removals, welfare cattle and extractive industry

The Cloud Foundation

Media Contact:                

Makendra Silverman 

Makendra@TheCloudFoundation.org 

Tel: 719-351-8187

Anne Novak

Anne@TheCloudFoundation.org

Tel: 415-531-8454

Media and Public Advisory:

Public Encouraged to Attend Meeting on BLM Plans to Round up Hundreds of Utah’s Wild Mustangs 

 

Salt Lake City, UT (June 8, 2010)—On June 9, 2010 the Bureau of Land Management (BLM) will hold a public meeting in Salt Lake City, Utah to discuss the use of helicopters and motorized vehicles during massive wild horse roundups scheduled to begin throughout the state in August. Advocates are encouraged to attend this meeting at the West Desert District office at 6:30 p.m., 2370 South 2300 West, Salt Lake City, Utah. 

This meeting will impact pending roundups of Utah wild horse herds including those in the Winter Ridge area of NE Utah (slated for complete removal this summer) and the Confusion and Conger (where a planned spring roundup was successfully delayed) as well as the famous Sulphur herd, all of Western Utah, among others. Additional herds in danger of removal include North Hills (Iron and Washington Counties), and Chokecherry and Mt. Elinor (Beaver and Iron Counties).

“Surface natural gas lines crisscross much of these areas, particularly Winter Ridge and Hill Creek,” said Herd-Watch Project Manager Laura Leigh, who visited the area recently, noting steep drop-offs and canyons, which could be deadly in a helicopter roundup. “Yesterday in Texas we had a buried line apparently hit by a piece of equipment and three people are presumed dead. The lines in Winter Ridge lay on the surface. Not just one line, but many, that in places are hidden from immediate view by vegetation. A roundup in this area could be devastating.”

The Winter Ridge and Hill Creek Herd Areas are slated for removal of 450 horses beginning July 18, 2010 and concluding July 31 despite thousands of public comments urging BLM to cancel the roundups in the West before all the horses are gone. Nearly 12,000 wild free-roaming mustangs and burros are to be permanently removed at a cost of over $30 million in 2010 alone.

The interested public is asked to attend the meeting and raise concerns about the natural gas lines and the current protocol utilized for roundups in Utah, characteristic of those across the West.

“The majority of Utah’s iconic mustangs will be warehoused for life at an enormous expense to the American taxpayer,” states filmmaker and director of the Cloud Foundation, Ginger Kathrens. “At the same time, taxpayers will continue to shell out their tax dollars for the thousands of head of cattle that will remain on Utah’s legally designated wild horse ranges. In addition we have an expanding extraction industry on our public lands. When does management for multiple use cross the line into management that has nothing to do with wild horses?”

Information on attending the meeting is posted online at http://bit.ly/UtahRoundupMtg

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