Comments on Draft Environmental Impact Statement Glyphosate-Tolerant Alfalfa

February 26th, 2010

The following comments concern the potential deregulation of Monsanto’s genetically engineered alfalfa. They are provided by Jim Munsch, a certified organic beef farmer and The Cornucopia Institute’s key advisor on this important issue. We are posting these as an aide to others still composing comments to the USDA and for those who seek to know more about this issue that is so critical to organic and conventional farmers.

Comments on Draft Environmental Impact Statement
Glyphosate-Tolerant Alfalfa

Docket No. APHIS-2007-0044

We own and operate Deer Run Farm, a certified organic beef-producing farm. This is a grass and forage based cow/calf to finished beef operation. It has been certified organic since 1999. Prior to 1995 we farmed conventionally. In addition I have a business consulting company specializing on performance analysis methods and general management for organic and small farms.

As an organic animal farmer I have easily co-existed with neighbors choosing to use genetically engineered (GE) corn and soybeans and the industry that supports them. This is done with simple – although costly – measures to minimize genetic contamination of my crops and the crops of seed producers. Six years ago I heard of the possibility of GE alfalfa from an alfalfa seed grower. I was concerned that because alfalfa is a perennial, is pollinated over long distances and seed is grown in geographically confined areas with shared equipment that there is high probability of significant contamination between GE and non-GE varieties especially in seed production. This would have the effect of eliminating alfalfa from the organic production model.

This concern is high because alfalfa is an important part of my production system just as it is for most organic meat and dairy producers and elimination would have significant, negative economic impact.

I was hoping that a strong strategy for containing contamination would evolve but it has not. The draft EIS does nothing to mitigate my concerns. I strongly reject the conclusion of the draft that Glyphosate-Tolerant alfalfa should be moved to non-regulated status.

Genetic Contamination

The primary deficiency in the study is the conclusion that genetic contamination between GE alfalfa and other alfalfa can be contained to some fraction of one per cent. The rationale for this conclusion relies on all farmers of seed and forage following “Best Practices” defined by the patent holders. In the real world “best” is an “ideal” with actual practices always something less than that – and always with some cases significantly less. Here are the specific problems with the effectiveness of the practices. The bullets correspond to those in the FGI “Best Practices” on page 103 of the EIS.

  • On selling seed. Good practice but exactly how is it detected and contract terms enforced? In addition, this subject brings up something that was mentioned in the input comments to the EIS but not addressed by the EIS. A seed producer asked what action from the patent holder would follow if the producer had planted a non-GE alfalfa for seed and it was significantly contaminated (his question used 10% as an example) through no fault of his own. This question should have a second part: if the producer sells the seed it will be contaminated. He has nothing to force him to test for the genes. Will the sale be contested by the patent holder? The EIS is deficient in not addressing these questions.
  • Beehive removal. There is a significant deterrent to accomplishing the intent. The hives are not the property of the farmer under contract. Unless the apiarist is party to the license contract what is keeping him/her from removing his own property? Further, there is no provision for hives owned by others on land owned by others but adjacent to fields where GE alfalfa is grown. The EIS does not address these situations.
  • Isolation. This is covered in two bullet points. The first establishes isolation distances. The second puts all responsibility on maintaining these distances on producers who wish to grow non-GE seed. Not surprising because the methodology is parallel to that for organic grain crops. This just plain won’t work in practice for alfalfa. With isolation distances in miles it is obvious that not all non-GE seed producers will have control over land between GE fields and their own fields. Without control they will run the risk of having someone between the two locations decide to grow either GE alfalfa for seed (required to register) or forage (not required to register) after they have made the decision to plant their fields. At the very least it guarantees non-GE alfalfa producers will be put at a significant competitive disadvantage. APHIS knows this. There is no plan in the EIS to control it. This is a major flaw in the whole case made for deregulation.
  • Stand removal. Sounds good on paper but in practice complete stand removal is problematic. I’m not a seed grower but I’ve talked to 3-4 of them, I’ve talked to degreed university forage specialists and I have seen correspondence that indicate this to be virtually impossible to achieve. As a user of non-GE seed I have no faith in the methodology concluded in the EIS to stop contamination.
  • Cleaning of equipment. As an organic producer we have to do equipment cleaning. It’s very difficult to achieve. Combines have hiding places for big seeds like cereal grain where it is even more likely for small seeds to hide. Unless you have a custom operator who does only organic crops you will have contamination. The EIS takes a very naïve stance on this subject.
  • MTA requiring forage to be cut at 10% bloom. They may “require” it but field conditions make it impossible. Fields can be too wet at that point. Fields can change hands during mid-season. Plants can be missed at cutting. Seeds can be accidentally dropped anywhere leading to plants not in fields to be cut. Seeds can be co-mingled with non-GE seeds and planted. I’ve seen all of this right here in my county and on my own farm. The EIS totally misses the real-world situation.

Organic Production Practices & Markets

From the standpoint of someone who understands the characteristics and economics of the organic market and organic production systems there are several areas where the EIS misses the reality of the facts of the real world.

1.     Alfalfa is much more important to organic producers than to their conventional counterparts. Thus not having organic alfalfa available because of contamination would have a dramatic and negative cost impact. Factors that make alfalfa more valuable for organic producers are:

  • The study focuses on dry matter yield, quality and market price of alfalfa hay as main parameters for evaluation of trends and markets. (Pp 48-51) This approach looks at alfalfa primarily as a cash crop. Organic production and conventional grass based pasture models approach alfalfa and other crops in a system of production with the saleable product being meat or milk or milk products. An important cost difference for hay grown in an animal system versus as a cash crop is the availability of animal manure as a nutrient source. A cash crop system usually depends on purchased nutrient inputs – in the case of alfalfa this is usually potash. Organically approved sources of purchased potash are, on average, double conventional sources. By careful use of animal sources, the cost of producing hay on our farm is about the same as hay production on non-organic farms in our area. Yields since we became certified are no different than when we used conventional practices. The conclusion on pp 48 and 49 that “value” or “price” of organic alfalfa is 15-20% more expensive than conventional is confused. The study mixes the concepts of price, value and cost. Price comes from the dynamics of the supply and demand of hay in a market. This has only slight relationship to cost. If you don’t purchase alfalfa hay then cost is the cost of production and not the market price.
  • Alfalfa is high in protein (20% or so if harvested right) and with hay costs about equal to conventional hay this provides forage protein at conventional costs. Protein from organic grain sources is 2.5 to 3 times more expensive than conventional protein. For example, early last year our local price for conventional 44% soy meal was $325/ton while organic meal was $960. Therefore, using protein from alfalfa is an important cost containment practice.
  • Chemical and petroleum based nitrogen fertilizer is not available to organic producers. Nitrogen is available in the form of animal manure but often not in sufficient quantity on a self-contained animal farm. Legumes like alfalfa are a good source of nitrogen for crops following alfalfa and accompanying it as in mixed hay and pasture.
  • Because alfalfa is a perennial it has the potential through management to persist as a hay crop. The same is true of grasses grown with it. On our farm, for instance, we let alfalfa go to full bloom or beyond at least once a year to build root reserves and make sure there is stubble left in the fall to mitigate damage from icing. We regularly have stands last 6-8 years. This cuts down on total cost of hay because establishment cost is spread over more years. On erodible land this dramatically cuts down on soil loss. Weeds in these grass/alfalfa stands are not a problem with timely cutting.
  • Organic producers must graze animals more than conventional farmers. This is currently driven by consumer preference but is now part of the NOP. Alfalfa is an important addition to pastures. It makes them more drought resistant and is a perennial legume versus many popular pasture legumes that are not.
  • There is an overlapping niche market where alfalfa is extremely central: grass fed beef and milk from grass fed cows – both organic and non-organic . Contrary to the model explained first on p 139 where beef is finished in feed lots and thus has little input from alfalfa, the grass fed producers in the upper Midwest make ample use of alfalfa in pastures and harvested forage. Feed is usually 65% of total cost of an animal going to slaughter and composed entirely of legumes and grass. It is common for the legume content to be 60-70% of hay and 50% of pasture. The legume of choice in hay is alfalfa and about half of the graziers use alfalfa in their pastures.

2. Throughout the EIS there are many descriptions of market trends and forces in terms of averages or majorities. See especially pages 56-60. The conclusion seems to be that the consumer-driven market for GE food is not real because on average American eaters don’t care if they eat GE food – especially after education. This may be true but there is a small group of people who consider themselves well educated on these subjects and totally reject GE food. You may disagree with their “education” but that’s what they believe. These consumers have this and other reasons for buying organic. This is nature of a niche market. Table 3-16 indicates that the organic niche is growing at a CAGR of 24% for dairy and 38% for beef. To those of us who sell organic products to this niche, growth rates of this magnitude allow pricing and other marketing opportunities that are important. In real terms that means we can sell organic pasture based beef at $2.00 per pound Hot Carcass Weight (after processing, transportation and all marketing costs) versus conventional at $1.40 (USDA AMS Feb 2010). Thus, if we lost organic certification and had to sell on the conventional market we’d experience a 30% reduction in revenue per head.

3.     Nowhere in the EIS is there mention of producer preference per se for non-GE feed for his cattle – that is, not solely driven by market or the NOP. This would include anyone not convinced of the safety of the modified proteins found in GE feed/food. (See page 33 of EIS.) There is a long list of studies that say it’s no different than other proteins found in foods but there is a list (shorter) of compelling studies that say differently. With the emergence of epigenetic research the whole subject becomes even more important. Therefore, some elect to stay with traditional feed/food and avoid the risk. With approval of GE alfalfa this choice will be taken away as conventional alfalfa is significantly contaminated.

4.     The EIS discussion of organic alfalfa seed doesn’t fit with reality. On pp 53, T12 & T13, the study implies that there are so few sources of organic seed that organic farmers use non-organic seed free of prohibited coatings. (The EIS leaves out a crucial proviso: there can be no GMO’s in such seed.) I have four local sources of organic alfalfa seed. I have purchased certified organic alfalfa seed for six years without difficulty. Attachments 1 and 2 are lists of seed producers and suppliers who have alfalfa seed. Of course there are few suppliers; only 3,000 acres of organic alfalfa were seeded last year. And it is true that there are fewer varieties available than for non-organic alfalfa. However, the most important attributes from variety differences are winter hardiness, pest resistance and disease resistance; there is an array of these attributes that along with good management make these seed varieties quite sufficient for organic systems.

I am extremely concerned that if Glyphosate-Tolerant GE alfalfa is de-regulated that American and Canadian alfalfa seed sources will be contaminated so much as to mean alfalfa can no longer be certified organic and, for that matter, anyone electing to use non-GE alfalfa will no longer have that choice. I will be faced with some very painful alternatives. One alternative is to keep alfalfa in our system but give up organic certification. This means a 30% reduction in revenue with the same cost – not really a solution. Another alternative is to move to other forage legumes that can be certified organic. This will result in our needing about 40% more land to keep the same revenue (the difference in yield from alfalfa to the next best: red clover.) It would also result in more establishment events and increased possibility of erosion because these other higher yielding legumes are not perennials.

GE alfalfa should not be deregulated.

James Munsch
S995 Bagstad Lane
Coon Valley WI 54623

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