[DIYbio] Comment on APHIS regulatory proposals

Biohackers: it's comment on bad government GMO regulations time again. This time APHIS who is proposing to introduce process based regulation against the recommendations of the National Academy of Sciences. Please use this link to tell them this is a bad idea and will hurt innovation. Comments are due by Monday so let's get on this today.
https://www.regulations.gov/comment?D=APHIS-2015-0057-0001

Here's my full list of issues, more detail in the attached document. Feel free to use this to phrase your own comments.
1. It introduces process based regulation in violation of the 'product not process' principle of the coordinated framework and the recommendations of the National Academy of Sciences
2. This is a significant expansion of APHIS regulatory authority which is not justified by verifiable scientific risks, also in conflict with the principles of the coordinated framework. AHPIS own findings suggest GE plants pose no greater risk than conventionally bred plants
3. It inhibits innovation and disproportionally places the regulatory burden on small companies and academic researchers
4. The full negative impact of this clause has not been properly considered in the economic analysis of the rule
5. The breadth of the clause means many non-agricultural products will become regulated by APHIS which may be unintentional
6. No consideration has been made for grandfathering products which are currently legal to sell and distribute but which will become regulated under the new rules
7. The proposed weed risk assessment methodology is biased towards agricultural crops and is inadequate for the full range of plants which will be regulated by these proposals
8. Excessive regulation which is not aligned with actual risks could hurt USA competitiveness in the field of plant genetic engineering
9. The definition of Genetic Engineering proposed by AHPIS is not aligned with similar definitions being proposed by the FDA

thanks for your help!