More than 200,000 comments sent to USDA about EIS on Roundup Ready Alfalfa

More Than 200,000 NGOs, Farmers, Consumers
and Organic Producers Call for USDA to Prohibit
Genetically Engineered Alfalfa!

Read the update from The Center for Food Safety.

USDA has released its draft Environmental Impact Statement (EIS) on Monsanto’s Genetically Engineered (GE), Roundup Ready alfalfa.

BACKGROUND

This is the first environmental impact statement conducted for any GE crop, so the outcome of this EIS will set a precedent for the future of genetically engineered crop regulations, protection of organic and non-GE agriculture, consumer choice and the environment.
 
The Center for Food Safety has begun analyzing the EIS and believes that USDA has not addressed the concerns of non-GE alfalfa farmers, organic dairies, environmentalists, or consumers seriously. USDA has dismissed the fact that GE contamination will threaten the environment, export and domestic markets, and organic meat and dairy products.

USDA states that there is no evidence that consumers care about such GE contamination (also known as transgenic contamination or biological pollution) of organic.  USDA’s preliminary determination is to deregulate GE alfalfa without any limitations or protections for farmers, consumers, or the environment.

In 2006, the Center for Food Safety (CFS) sued the Department of Agriculture (USDA) for its illegal approval of Roundup Ready alfalfa. USDA failed to conduct an environmental impact statement (EIS) before deregulating the crop. The federal courts sided with CFS and banned the sale of GE alfalfa seed until the USDA fully analyzed the impacts of the GE plant on the environment, farmers, and the public in an EIS.

Please send this Center for Food Safety's consumer-based alert or farmer-based alert to as many folks as possible so they may comment on the EIS about Roundup Ready Alfalfa seed and protect the future of organic agriculture. CFS is working to ensure that all affected parties are involved in the public process and have the opportunity to submit public comments. 

This is the first time USDA has complete an environmental impact statement for any GE crop.  Therefore, the final version (and resulting decision) will have broad implications for all GE crops. The failure of the agency to address the environmental and related economic impacts of GE alfalfa will have far-reaching consequences for organic and conventional agriculture, food producers, consumers and the environment.

The judge who ordered this EIS clearly stated that USDA needed to analyze “real-world” scenarios, and not base its analysis on “ideal-world” conditions where alfalfa hay is always cut before it goes to flower, RR alfalfa farmers always follow Monsanto-FGI guidelines, feral RR alfalfa is always controlled, etc.

In short, the judge ordered USDA to take account of the waywardness of Mother Nature and human nature, which the USDA failed to do in the EIS.  Instead, USDA relied heavily on Monsanto and a handful of pro-Roundup Ready alfalfa farmers and academics in writing this EIS, which is strongly biased in their favor and against conventional and organic growers, and completely dismisses the threats posed to the environment by RR alfalfa. 

We urge you to write to the USDA and explain the realities of the situation, describing all the ways in which the deregulation of RR alfalfa will impact you or your members or supporters, and drawing from your knowledge of consumer and environmental issues. Be specific. Below, we have included talking points from the Center for Food Safety to help you prepare your comments. 

Talking Points

Tell USDA That Consumers Do 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. [1]

Additionally, more and more consumers are looking for Non-GMO products when they shop for food. According to the Nielsen Co. GMO-free claims are the fastest growing labels among store brands, with sales of these items increasing 67% in 2009 to $60.2 million [2].

Tell USDA Consumers 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 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, [3] 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. [4]  A recent report documented 39 cases in 2007 and more than 200 in the last decade. [5]  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. [6]  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 GE herbicide-tolerant canola in Western Canada destroyed the growing, albeit limited, market for organic canola.” [7]

USDA dismisses the potential for RR alfalfa to cross-pollinate feral alfalfa, or RR alfalfa volunteers to escape and establish feral populations (EIS, p. 98-99).  In either case, this feral RR alfalfa can serve as a bridge for transferring the RR trait back to conventional alfalfa in later years.  The EIS states that if such feral RR alfalfa does arise, it can be controlled with non-glyphosate herbicide.  However, “Roadside and ditch bank feral alfalfa also will be a concern since Roundup has traditionally been used for weed control in those areas.” (Ron Vargas, weed control specialist and farm advisor in Madera and Merced counties in the San Joaquin Valley, California) [8].

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. 

Throughout the EIS, USDA assumes that all conventional alfalfa growers regularly use large quantities of herbicides.  USDA argues that RR alfalfa is environmentally friendly because it will lead to Roundup replacing more toxic herbicides (EIS, pp. 120-21).  However, as the agency’s own studies here show, the great majority of alfalfa is currently grown without the use of any herbicides at all. [9]  This means that RR alfalfa will increase Roundup use without significantly displacing other herbicides. USDA also admits that RR alfalfa will require 2,4-D, dicamba, clopyralid, or picloram for taking out old stands (EIS, App. N, p. N-109). 

Roundup has been associated with increased rates of several cancers in pesticide applicators (e.g. non-Hodgkin’s & multiple myeloma), [10] and is highly toxic to frogs at field-relevant concentrations. [11] 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.

Additionally, more than 130 species of birds visit alfalfa fields each year, including endangered species.5 The USDA did not analyze the possible impacts on birds, mammals, insects, and other beneficial organisms in its Environmental Assessment before approving RR alfalfa.

In the case that ordered the EIS, the judge criticized USDA for not considering the potential for RR alfalfa to worsen the glyphosate-resistant weed problem that we see in other RR crops like soybeans, cotton, and corn.  He said that it was “unclear from the record whether any federal agency is considering the impact of the introduction of so many glyphosate resistant crops; one would expect that some federal agency is considering whether there is some risk to engineering all of America’s crops to include the gene that confers resistance to glyphosate.”

 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, more 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 [12] - and Roundup Ready alfalfa will only make matters worse. 

Rotating RR alfalfa with RR corn, soybeans or cotton will accelerate the development of glyphosate-resistant weeds through frequent, repeated use of glyphosate. 

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.

Comments were due March 3rd, 2010. For written, mailed comments please send three copies (plus the original) of your comment 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.

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

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

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

Review the Network's letter about RoundUp Ready Alfalfa to USDA, sent 2/6/08.