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Date:

February 22, 2010

Subject:

Special Action Alert: AgBioWorld Community Calls for Comments on USDA Environmental Impact Statement Regarding Roundup Ready Alfalfa

 

Special Action Alert: AgBioWorld Community Calls for Comments on USDA Environmental Impact Statement Regarding Roundup Ready Alfalfa

As many of you know already, the US Department of Agriculture recently decided to extend the public comment period on its intent to deregulate, or grant commercial approval for, Roundup Ready alfalfa. The comment period will now end on March 3, 2010. We at AgBioWorld are encouraging supporters of sound science and rational biotechnology regulation to weigh in with comments, which can be submitted by following this link: http://www.regulations.gov/search/Regs/home.html#submitComment?R=0900006480a7ba3f.

You may recall that, in 2007, a group of environmental activists sued the USDA for not sufficiently investigating the economic impacts that growing RR alfalfa might have on neighboring growers of non-biotech varieties and other effects on the “human environment.” A federal court suspended the sale of RR alfalfa seed and ruled that USDA had to prepare an Environmental Impact Statement (EIS) before again granting deregulated status.

USDA completed the EIS in November 2009, and it concluded that deregulating RR alfalfa would pose no significant impact on the human environment that would not also be expected with the release of non-biotech varieties.

Although a handful of plant scientists and other technical experts have submitted comments in favor of deregulation, the docket has been overwhelmed with more than a thousand submissions by radical biotech opponents. It is unrealistic to expect that our side can submit enough comments to outnumber the anti-biotech activists, but the science is on our side. So, we need only show that there is some reasonably-sized groundswell of support for food biotechnology in order to convince USDA to do what it knows is right

Importantly, this EIS has ramifications that go far beyond Roundup Ready alfalfa, since every new biotech crop variety could be challenged using the same process. Regardless of whether we believe alfalfa is an important crop, if we don’t vigorously defend this product, it will be much easier for the anti-biotech activists to defeat others in the future.


The primary issue in question is that of co-existence: whether biotech varieties can biologically and economically co-exist with non-biotech varieties, particularly organic crops. We therefore urge those submitting comments to make particular note of the following items:


• Herbicide Tolerance Traits Are Not Unique: Managing herbicide tolerance in crop plants is not unique to Roundup Ready alfalfa or to bioengineered plants more broadly. Herbicide tolerance has been bred into dozens of crop species by a number of non-biotech methods, and farmers and plant breeders have developed common sense methods for keeping the herbicide resistant trait from crossing into other crops or weeds. In addition, several state agricultural departments and university extension services have developed co-existence programs and guidelines that farmers can adopt to eliminate or reduce the cross-pollination of biotech alfalfa with conventional and organic varieties and vice-versa.

• Cross Pollination Would Be Very Rare: USDA has carefully studied the possibility of cross-pollination from biotech to non-biotech crops and found that it would happen less than once in every one-hundred-thousand plants. Because the feed quality of alfalfa drops rapidly after flower blooms appear, nearly all RR alfalfa would be harvested before flowering. That alone makes the possibility of cross pollination extraordinarily unlikely. Although some RR alfalfa plants will inevitably flower, alfalfa pollen is not dispersed in the wind, but must be carried by pollinating insects. Even then, the biotech and non-biotech fields would have to flower at the same time for viable pollen to be spread and for fertilization to occur.

• There Is No Threat To Organics: Perhaps most importantly, U.S. and international organic rules make clear that unintentional cross-pollination with a biotech plant does not cause an organic one to lose its organic status. So, arguments that widespread planting of RR alfalfa could jeopardize organic crops are totally groundless. As long as an organic grower does not intentionally plant biotech varieties, the accidental presence of a few biotech plants does not jeopardize the organic certification in any way.

• RR Alfalfa Is Already Being Grown Successfully: Because the court order only prevented the sale of new seed, roughly 5,500 farmers in 48 states have already planted more than a quarter million acres of Roundup Ready alfalfa, with no reported cases of cross-pollination.

• Biotech Crops Are Safe: Biotech crops with the Roundup Ready herbicide-tolerance trait, including RR alfalfa, are among the most thoroughly studied agricultural products in history. Countless scientific bodies, including the U.S. National Academy of Sciences, American Medical Association, the UN’s Food and Agriculture Organization, and many others have studied biotechnology and concluded that this plant breeding method is at least as safe, and often safer, than most non-biotech breeding methods because the breeder actually knows what gene and protein the new varieties will produce, and can test them more robustly for safety.

• Biotech Crops Are an Important Tool for Farmers: Biotech varieties with herbicide resistance and other traits are now grown on over 300 million acres by more than 13 million farmers in 25 countries. They have raised yields, reduced the spraying of insecticides, and stimulated a shift to more environmentally benign herbicides and conservation tillage practices. It is clear that crop biotechnology holds substantial promise for improving the foods we eat and lightening agriculture’s environmental footprint.

Again, readers wishing to submit their own comments can do so no later than March 3, 2010, by following this link: http://www.regulations.gov/search/Regs/home.html#submitComment?R=0900006480a7ba3f.

Additional information about the USDA’s regulatory docket on RR alfalfa can be found here: http://www.regulations.gov/search/Regs/home.html#docketDetail?R=APHIS-2007-0044; and the EIS can be viewed here: http://www.aphis.usda.gov/biotechnology/alfalfa_documents.shtml.

Background information on RR alfalfa can be found on the University of California, Davis website here: http://ucce.ucdavis.edu/files/filelibrary/5283/17270.pdf; and here: http://alfalfa.ucdavis.edu.

Thank you to all who are willing to help.



C.S. Prakash and Gregory Conko