UPDATE: The Alfalfa EIS docket comment period has been extended 15 days until March 3rd.
Send Your Comments to USDA on Draft Environmental Impact Statement
Late last year, the USDA released a court-ordered Environmental Impact Statement (EIS) on Monsanto’s new genetically engineered Round-up Ready Alfalfa. A federal lawsuit, led by the Center for Food Safety and joined by The Cornucopia Institute and other plaintiffs, was won in 2007 compelling the USDA to conduct their first-ever environmental impact statement on a genetically engineered (GE) crop, alfalfa.
Perhaps unsurprisingly, the USDA’s assessment approves of releasing a new genetically modified crop into the environment, despite the known risks this version of alfalfa poses to organic livestock agriculture.
Public comments are being accepted until February 16. Please let the USDA hear your voice. A broad coalition, composed of both organic and conventional farmers, is opposing Monsanto’s RR Alfalfa and the USDA particularly needs to hear from those involved with organic agriculture.
Alfalfa is the fourth most widely grown crop in the U.S. and as a farmer, you know it is a fundamental source of livestock forage. Here are some key observations, based on reviewing the 1400 page EIS.
• This would be the first perennial crop to be approved for genetic modification and release. Alfalfa is open-pollinated by bees. With bees traveling 4-6 miles, they can potentially spread the patented, foreign DNA to distant conventional and organic crops. The potential for biological contamination from a neighbor’s field, even miles away, threatens the livelihood of organic farmers, dairies and other livestock producers. U.S. organic standards prohibit genetic engineering. Buffer strips and other devices required with other GE crops are essentially useless.
• As a perennial, it is very likely that genetically engineered volunteers will escape from farm fields and/or be scattered along roadsides from harvest and transport equipment. Escaped or feral plants will live on for years producing GE pollen to contaminate non-GE alfalfa.
• The USDA’s EIS maintains that avoiding GE contamination would be your responsibility as an organic producer. They say that all you have to do is change your planting and harvest schedules to “avoid simultaneous flowering” with RR alfalfa in your neighbor’s field, and “disallow or remove commercial beekeepers’ hives anywhere near your alfalfa field.” Is this feasible? Tell the USDA that they need to protect all farmers and the livelihoods of those who choose not to grow RR alfalfa.
• Ninety percent of all the alfalfa seed sold in the US comes from 5-6 compact geographic areas ideal for growing the seed in the Pacific Northwest and Canada. Yet the USDA’s EIS fails to recommend significant isolation zones where the planting of GE alfalfa would be illegal, and help to protect the vital nature of uncontaminated alfalfa seedstock.
• The vitality of the $25 billion organic industry is at risk. Our partners, the consumer, support organics because they want healthy foods, sustainability and economic opportunity for family farmers. How will they react to contamination of the organic dairy and beef sector by genetically modified crops? Genetic engineering is prohibited in organics and organic consumers, as well as organic farmers, don’t want it.
• The USDA’s EIS concludes that RR alfalfa will cause production to shift to larger farms, but they say this is “not significant.” Let them know that this is significant to you as a family-scale farm operator (you could very well become collateral damage under their forecast).
• The EIS predicts that export markets for alfalfa will be lost, but again does not consider this impact “significant” nor offer any possible means to prevent it. The majority of alfalfa seed exports go to Saudi Arabia and the majority of alfalfa hay exports go to Japan and South Korea, all of which will reject GE-contaminated seed and hay, causing significant harm to the export industry. How does this help American farmers?
• During our discussions with many seed and plant experts, not associated with Monsanto, they all said in a few short years, all alfalfa seed will contain considerable GE contamination. This is what has happened with canola seed, as an example. Should the USDA proceed with introducing alfalfa, as suggested in the EIS, there will soon be no organic seed available from the US. Then the patent holders can, if they wish, push all non-GE seed growers out of business the same way they have hurt soybean seed savers; Monsanto will end up having a monopoly on all alfalfa seed grown in the US. Organic producers will have two choices: switch to other legumes or buy organic seed from foreign sources. Tell the USDA you want your chosen form of agriculture protected, not taken from you by the development of RR alfalfa.
The USDA’s stated basic mission is “protecting American agriculture.” They say they support the “coexistence” of all types of agriculture. Let them know that they must include a future that protects organic and alfalfa farmers and conventional exporters from contamination by RR alfalfa.
SEND YOUR COMMENTS TO THE USDA BY FEBRUARY 16.
Comments can be filed online at: http://www.regulations.gov/search/Regs/home.html#submitComment?R=0900006480a6b7a1
Written and mailed comments (please send two copies) should be sent 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 at the top of your written or electronic comments that they refer to Docket No. APHIS-2007-0044.
If you would like more information, you can review the draft EIS here: http://www.aphis.usda.gov/biotechnology/downloads/alfalfa/gealfalfa_deis.pdf