Comments are due March 3, 2010. For written, mailed comments please send three copies of your comment (plus the original) to Docket No. APHIS-2007-0044, Regulatory Analysis and Development, PPD, APHIS, Station 3A-03.8, 4700 River Road Unit 118, Riverdale, MD 20737-1238. Please state that your comment refers to Docket No. APHIS-2007-0044.

 

Comments can also be filed online at: http://www.regulations.gov/search/Regs/home.html#submitComment?R=0900006480a6b7a1

Review the draft EIS here: http://www.aphis.usda.gov/biotechnology/downloads/alfalfa/gealfalfa_deis.pdf

Reviews Supplemental documents here:
http://www.aphis.usda.gov/biotechnology/alfalfa_documents.shtml.

 

Talking points:

 

 

*Tell USDA That You Care About GE Contamination of Organic Crops and Food: 

 

USDA claims that there is no evidence that consumers care about contamination of organic alfalfa and alfalfa-derived foods with Monsanto’s GE Roundup Ready alfalfa.

 

-  Prohibition of genetic engineering (GE) is a fundamental tenet of the Organic Standard.  In fact, USDA’s failure to exclude GE crops from the first version of the organic rule was one of the main reasons that 275,000 people filed public comments in 1997-- the largest outpouring of public participation in the history of U.S. administrative procedure.  Consumers care deeply about organic integrity, and genetic engineering is fundamentally at odds with organic.  More than 75% of consumers believe that they are purchasing products without GE ingredients when they buy organic.[i]

 

*Tell USDA You Will Reject GE Contaminated Alfalfa and Alfalfa-Derived Foods:

 

USDA claims that consumers will not reject GE contamination of organic alfalfa if the contamination is unintentional or if the GE material is not transmitted to the end milk or meat product.

 

-  The Organic Standard requires that livestock feed for animals used for meat, milk, eggs, and other animal products is 100 percent organic.  Protecting organic alfalfa, the main source of feed for the organic dairy industry, is crucial to the health of that important sector of U.S. agriculture.  Additionally, as the Court found in the lawsuit that required this EIS, to “farmers and consumers organic means not genetically engineered, even if the farmer did not intend for his crop to be so engineered.”  Whether or not the end product is impacted is not the issue.  Farmers’ fundamental right to sow the crop of their choice is eliminated when it is contaminated with transgenes, and so is the public’s ability to support meaningful organic food and feed production.  The public’s trust in the integrity of the organic label is essential to the continued vitality of the organic foods industry.  Tell USDA you reject GE contamination of organic by any means or at any stage of sustainable food production.

 

*Tell USDA to Protect Organic Farmers and All Farmers Who Wish to Choose to Grow Non-GE Crops:

 

Although USDA says it supports “coexistence” of all types of agriculture, USDA refuses to even consider any future for alfalfa that would include protections from contamination for organic and conventional farmers and exporters.

 

- USDA can approve GE crops in whole or in part. Partial approval could include use restrictions, geographic limitations or planting isolation distances.  Yet, in the court-ordered analysis, USDA analyzed only two options: 1) Full approval, allowing GE alfalfa to be grown and sold without restriction like any other crop; and 2) No action, meaning GE alfalfa could only be grown under USDA permit, as at present.  USDA’s “all or nothing” approach leaves un-analyzed any potential options to protect farmers.  This is contrary to law and logic.  USDA’s basic mission is “protecting American agriculture.”  Yet, USDA refused to even consider any options that might protect organic and conventional agriculture from contamination and the resulting loss of markets and ability to sow the crop of their choice. 

 

*Tell USDA That Protecting Farmers is Its Job and That Relying Solely on Monsanto’s Business as Usual “Best Practices” Ensures Widespread GE Contamination:

 

USDA claims that Monsanto’s seed contracts require measures sufficient to prevent GE contamination, and that there is no evidence to the contrary.

 

- In the lawsuit requiring the EIS, the Court found that GE contamination had already occurred in the fields of several Western states with these same business-as-usual practices in place! 

 

- The EIS itself acknowledges that GE contamination may happen and includes studies that honey bees can cross-pollinate at distances over 6 miles, and Alkali bees at 4-5 miles,[ii] much further than any distances under Monsanto’s “best practices.”

 

-In general, where other GE crops were approved without restriction, contamination of organic and conventional seeds and crops is widespread and has been documented around the world.[iii]  A recent report documented 39 cases in 2007 and more than 200 in the last decade.[iv]  The harms incurred by organic farmers and food companies from GE contamination are many and include: lost markets, lost sales, lower prices, negative publicity, withdrawal of organic certification, expensive testing and prevention measures, and product recalls.[v]  In at least one case, pervasive GE contamination eliminated an entire organic sector. According to an article in the journal Nature Biotechnology: “[T]he introduction of GEherbicide-tolerant canola in Western Canada destroyed the growing, albeit limited, market for organic canola.”[vi]

 

*Tell USDA That GE Alfalfa Would Significantly Increase Pesticide Use and Thereby Harm Human Health and the Environment:

 

USDA admits (correctly) that introduction of Roundup Ready alfalfa will increase Roundup use.  However, USDA’s claims that the increase is not significant and that Roundup will replace other, more toxic herbicides are flat-out wrong.

 

- The great majority of GE crops grown today are Roundup Ready, and their widespread introduction has vastly increased Roundup use and fostered an epidemic of Roundup-resistant weeds.  To kill Roundup-resistant weeds requires higher doses of Roundup, often in combination with other toxic herbicides.  Over the past 13 years, Roundup Ready crops have significantly increased overall herbicide use on corn, soybeans and cotton - by 383 million pounds[vii] - and Roundup Ready alfalfa will only make matters worse.

 

- As the agency’s own studies here show, the great majority of alfalfa is currently grown without the use of any herbicides at all.[viii]  So Roundup Ready alfalfa will increase Roundup use and exacerbate the resistant weed epidemic without displacing other herbicides on most alfalfa farms. 

 

- Roundup has been associated with increased rates of several cancers in pesticide applicators (e.g. non-Hodgkin’s & multiple myeloma),[ix] and is highly toxic to frogs at field-relevant concentrations.[x] The Environmental Protection Agency (EPA) is currently re-assessing the safety of glyphosate, the active ingredient in Roundup, for the first time in over 15 years.  USDA should wait for this new EPA assessment before it considers approving GE alfalfa.

 

*Tell USDA That Harm to Small and Organic Farmers is Significant:

 

USDA concludes that GE alfalfa will cause production to shift to larger farms (that can afford built-in isolation distances) and conventional growers who are not threatened by GE contamination, but that these economic shifts are not significant.

 

- Small, family farmers are the backbone and future of American agriculture and must be protected. Organic agriculture provides many benefits to society: healthy foods for consumers, economic opportunities for family farmers and urban and rural communities, and a farming system that improves the quality of the environment. However, the continued vitality of this sector is imperiled by the complete absence of measures to protect organic production systems from GE contamination and subsequent environmental, consumer, and economic losses.