federal deregulation of GEOs leaves local municipalities facing a much tougher challenge in prohibiting them. Jurisdictional issues bring into question the legal standing of county ordinances regulating GEOs. Federal pre-emption statutes may override them if challenged. GE crops are regulated by the EPA under the pesticide guidelines in FIFRA (Federal Insecticide, Fungicide and Rodenticide Act) according to which "…a state shall not impose any requirements for labeling or packaging in addition to or different from those under" FIFRA. Some legal experts contend that any regulation of GEOs must take place at the federal level because of this statute. Since the passage of measure H, counties in California followed Mendocino’s example with eight similar initiatives making it to the ballots. Of the eight counties that voted on anti-GEO initiatives, four passed and four were defeated. In addition, eleven counties passed pro-GEO ordinances banning their prohibition. Table-1 lists the counties and their voting percentages. In 2005, state senator Dean Florez attempted to pass a state preemptive bill prohibiting counties from banning GEOs. The bill passed in the assembly but got stalled in the senate where it had previously passed. California remains a challenging regulatory environment for GE producers and the farmers who wish to use their seed. The Federal District Court of Northern California has undergone a protracted regulatory battle with the USDA regarding two crops in particular, GE Alfalfa and GE Sugar Beets. In 2005, the USDA had deregulated Roundup Ready Alfalfa (RRA). Two years later, in response to a lawsuit filed by Earthjustice and the Center for Food Safety, the district court ruled that the deregulation was in violation of the National Environmental Policy Act (NEPA) because an environmental impact statement (EIS) had not been done. In Geertson Farms Inc., et al. v. Mike Johanns, et al., Judge Charles R. Breyer imposed an injunction on planting any further seed. In June 2010, the Supreme Court overturned the injunction, stating that it was unnecessary because the USDA’s deregulation was, in fact, in violation of NEPA and thus there was no legal standing to plant the seed in the first place obviating the need for an injunction. It was ordered that an EIS be done, which was projected to be complete in 2012. Another injunction was ordered by Judge Jeffrey White against the planting of GE sugar beets in August 2010. When it was discovered that GE sugar beets had been planted