The CaMV 35S promoter is being used in almost all GM crops currently grown or tested, especially GM maize. It is the promoter of choice for plant genetic engineering, as it is a strong and constitutive promoter. Failure to recognise or to take into account its capacity to be universally active in almost any organism is irresponsible and careless and shows a serious lack of scientific rigour and commitment to safety.
Any safety assessment can be expected to be flawed that does not resort to actual laboratory test of the capacity of bacteria and fungi to utilise the particular genes and their promoters.

In the face of the multiple crises of biodiversity loss, ecosystem degradation and climate change plus economic turbulence and injustice, it is strange that there is so little discussion about controlling corporate power and exploitation in the run-up to Rio+20. There are proposals for increasing the participation of women, youth and communities in decision-making. There are calls to reduce land degradation and deforestation, promote sustainable production and consumption, increase energy and resource-use efficiency, and protect ecosystems. But there is almost nothing about tackling the corporations that are doing so much of the damage. There is also no visible discussion about the advertising and public relations activities that corporations use to promote consumption and drive forward the wasteful consumerist development model that generates corporate profits but that also threatens the wellbeing and even survival of present and future generations.

Industrial scale bioenergies, including biofuels are rapidly expanding, creating massive new demand for wood, vegetable oil and agricultural products. Already these demands are inflicting serious and irreversible impacts on forests and other natural ecosystems, soils and water resources. Expansion of industrial monocultures, including tree plantations, to meet this demand occurs at the expense of biodiversity and food production, while also contributing to “land grabs”, undermining the rights of peasant farmers and indigenous peoples, and hampering efforts to achieve food sovereignty and agrarian reform.
The CBD Secretariat's report rightly acknowledges many of these negative impacts. However, in line with COP10 decision X/37, it focuses predominantly on 'tools', i.e. standards and certification, to address the often complex direct and indirect negative impacts, without assessing whether those tools are credible instruments.
Standards and certification schemes per se have not been effective and are no match for countering the drivers of bioenergy expansion: targets, mandates and subsidies, especially in Europe and North America. To effectively address the negative impacts, those incentives need to be eliminated.