Docket No. APHIS-2007-0044
Regulatory Analysis and Development
PPD, APHIS, Station 3A-03.8
4700 River Road Unit 118
Riverdale, MD 20737-1238
USDA’s basic mission is “protecting American agriculture.” Yet in the draft EIS (APHIS-2007-0044) 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. USDA analyzed only two options in the EIS: 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 should protect all farmers, not just those growing Monsanto’s patented crops.
Additionally, USDA acknowledges that GE alfalfa may contaminate organic and conventional alfalfa, but claims that Monsanto’s seed contracts require measures sufficient to prevent such contamination, and that there is no evidence to the contrary. But 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. In fact, contamination of organic and conventional seeds and crops is widespread and has been documented around the world. A recent report documented 39 cases in 2007 and more than 200 in the last decade. The harms incurred by 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. Looking to Monsanto to protect farmers from contamination by their own product is a complete abdication of USDA’s duties, akin to leaving the fox to guard the hen house.
Finally, USDA concludes that GE alfalfa will cause production to shift to larger farms but that these economic shifts are “not significant.” Small, family farmers are the backbone and future of American agriculture and must be protected. According to Farm Aid, thousands of small, family farmers are under extreme economic pressure and are pushed off their land each year. The very existence of the family farm is at risk and a shift in production from small farms to larger farms in the nation’s fourth-largest crop substantially increases that risk.
Please protect farmers’ and consumers’ right to choose organic and non-GE crops and foods by rejecting the deregulation of Monsanto’s GE alfalfa.