I have been active in establishing organic legislation and regulations, advancing scientific organic research, and increasing awareness of organic methods and improving organic markets. I have worked through such organizations as the Organic Trade Association, the Organic Farming Research Foundation, the Maryland Organic Food and Farming Association, and Future Harvest-Chesapeake Alliance for Sustainable Agriculture. Currently, I serve on the National Organic Standards Board, a federal advisory committee mandated to advise the Secretary on materials and practices for organic agricultural and food production. My comments are solely personal and represent no organization.
I own and operate Nick’s Organic Farm in Frederick County Maryland. We have 150 acres under certified organic cultivation. We are or have conducted on-farm research in conjunction with USDA’s Beltsville Agricultural Research Center, University of Maryland and the Maryland Department of Agriculture.
We raise grass fed Angus beef, pastured chickens and turkeys, and free range eggs, vegetables, forages, corn, soybeans, barley, rye, and hairy vetch. Additionally, for the last three decades we have also produced organic seed, including open pollinated corn and food grade soybeans.
Prior Comments to the AC 21 Committee
I am particularly concerned about maintaining the purity of our farm’s organic seed and crops and coexistence with neighboring GMO crops. I presented written and verbal comments to this committee on March 7 and August 25, 2012.
I reiterate that I do not feel that organic farmers should bear the total responsibility, as is now the case, for maintaining the purity of their products from surrounding GMO production. Coexistence is a shared responsibility.
Context for My Comments
I do not support any coexistence policies that charge non-GMO growers insurance premiums to compensate for rejection of their products because of un-intended GMO content. As I stated in previous testimony, compensation is not the relief that I seek. I am seeking true coexistence that avoids or minimizes any need for compensation. My understanding is that the Committee is now seeking information on how to best achieve this coexistence, and it is toward that end that I am commenting. I also address some issues of pesticide drift.
My comments are organized around issues rather than the questions in the Federal Register notice.
Serious Exploration of Voluntary GMO Free Zones
I believe there probably are many ways to create voluntary GMO free zones. I will discuss just one approach that could be applied particularly to non-GMO seed production and other high value crops. A thoughtful study could produce much valuable information on a variety of approaches .
By chance, I farmed for over three decades on a 20 acre de facto GMO free zone. The publicly owned land is located in suburbia only 15 miles from the White House. It is miles away from any conventional commercial grain farms. Among other organic seed crops, I was able to raise certified organic open pollinated seed corn and food grade soybean seed. (This land is no longer leased for agricultural purposes.)
What are the elements of this “model” that could inform coexistence policy? The following questions could lead to an exploration of this and other models. These questions emphasize isolation distance as a key factor in coexistence, which is especially important for open pollinated corn, alfalfa and canola, but less essential for other non-GMO crops.
What state and local governments already have geographical information systems (GIS) to identify where private open space and/or public land is located on the urban fringes and not likely to be in conflict with GMO crop production? Do these states and municipalities that have specific land use policies regarding agriculture on the urban edges that lend themselves to non-GMO production? Is there any GIS information on the location of GMO crops? How would various isolation distances affect the possible choices of and amount of non-GMO free zones?
What factors affect the minimum economically feasible size of the land necessary to support viable non-GMO seed and high value crop production? Can seed production be integrated into other high value production methods, such as season extension (greenhouse/hoop house), aquaculture and hydroponics? How can smaller urban fringe producers fit into the non-GMO markets? (Much of this economic work may already be done.)
How would the policy of voluntary GMO free zones be constructed? What has been the experience of the non-GMO zones that have been created both domestically and internationally? Assuming contractual agreements are made, how would participants enter into and leave from a voluntary GMO free zone, and how does this affect the zone?
How could the USDA best show leadership, in conjunction with other Federal, state and local agencies, universities, private companies and individuals and not-for-profit organizations, to provide market and policy incentives for the creation of GMO free zones? Is this task within the scope and resources of the current AC 21 committee? How could interested stakeholders best organize themselves into a group that could make recommendations? Would commissioning a study from the National Academy of Sciences (NAS) be a viable approach? (Any NAS or other study would need initial support from Congressional, Executive Branch, and state and local policy makers, as well as established GMO and non-GMO agricultural interests.)
Many Barriers to Coexistence with GMO Production
Limitations of Land Patterns, Isolation Distances, and Other Avoidance Practices
Land patterns--Our 165 acre farm is on the East Coast. There are many farm parcels this size and smaller in our area. We grow open pollinated and hybrid grain corn and soybeans, and open pollinated corn seed stock and food grade soybean seed stock. GMO crops, including corn and soybeans, surround our farm.
Our farm is roughly a square configuration, with sides of 2700 feet. Standing dead center on our farm we can never be more than 1350 feet from our borders. Under these circumstances, for open pollinated crops, isolation distance alone ceases to be an effective control measure for open pollinated seed corn production.
Varying Maturity and Planting Dates--Planting maturities timed to pollinate outside the prevailing window of the surrounding crops, while helpful, is not always a failsafe measure. We have no control over the vagaries of weather affecting planting or pollination, or our neighbor’s decisions of when to plant or to re-plant when faced with adverse conditions.
In addition, because we plant open pollinated seed varieties, our pollination “window” is not as uniform or as short as with a hybrid corn variety. This factor makes delayed planting less of a certain avoidance measure.
Barriers and Buffers--We also employ barrier crops, such as tall sorghum, to shield our corn from foreign pollen. Depending on field specific conditions, we also do not harvest the outside four to eight rows of corn for seed. In addition, we have grassed, forested or paved buffers around our entire farm to comply with organic regulations. While these crop barriers and buffers are helpful, they provide virtually no protection against undesired insect borne pollination into crops such as corn and alfalfa.
Adverse Financial Impact
Our avoidance practices represent lost opportunity costs. For example, any corn not harvested as seed as a sacrifice barrier, or any corn rejected as seed, represents a reduction in value. That reduction in value can make the non-seed corn worth between one tenth to one fortieth of the value of seed corn when compared to the value of organic feed grain. (Note: Open pollinated food corn varieties are lower yielding than our organic field corn hybrids and that lower yield affects the price of the seed.)
Our un-harvested buffer zones and lower value barrier crops, our delayed planting dates which reduce our yield potential, and our sacrificed outside rows of corn are estimated to cost in an average year $20-40,000 in “forfeited” income for both grain and seed production. Because our land is rotated through small grains, hay, and pastures, we have only 20% in row crops each year. If we were to increase our row crops or only grow seed corn and seed soybeans, our forfeited income would be considerably higher.
To date we have not had any of our seed or grain rejected due to the unintended presence of GMOs. Our seed customers require “no detectable level” of GMO in a seed sample of at least 3,000 seed, and sometimes 10,000 seed. Currently we send samples to our seed customers, and they have the GMO testing done at their expense. So the cost of testing several lots of seed are not in the above estimates of forfeited income.
Lack of Labeling for Agricultural Inputs
Non-GMO farmers need to know if their agricultural inputs contain GMO content. Seed, vaccines, inoculants, hormones, biologics, antibiotics, enzymes, etc. should be labeled as either free of GMO content or, alternatively, as containing GMO content. One way or the other, this labeling of agricultural inputs seems a common sense approach to helping all to maintain coexistence.
Unfortunately, the average farmer cannot tell by current labeling which products contain GMOs. My understanding is that GMOs are registered with various Federal agencies, many are registered within APHIS, and so this information is know and could be required to appear on product labels.
Lack of Knowledge Base to Achieve Coexistence
Lack of Knowledge of the Degree/Extent to Which Unintended GMO Presence Exists in non-GMO Seed Stock and Foundation Seed
To the extent that foundation and breeding seed stock are not free of GMO content, then there is a baseline to improve upon in achieving coexistence. To the extent that non-GMO foundation and breeding seed are free of GMO content, then some common sense strategies for ensuring and safeguarding the continued purity of the seed should be implemented. USDA should collect baseline data on the current state of the commercial and research seed supply, including the USDA germplasm collections, in order to guide realistic policy and to periodically evaluate progress on achieving coexistence. USDA should work with the National Genetic Resources Advisory Council monitor the purity and adequacy of our nation’s seed supply.
Lack of Knowledge About Strategies/Technologies to Achieve Coexistence in Seed Production
GA1s Gametophytic Incompatibility—Breeding corn to include the GA1s gametophytic incompatibility gene holds some promise, has some drawbacks, and is not failsafe. This genetic trait favors self-pollination and tends to “reject” pollen from “foreign” corn varieties.
Supporting more research into this area could inform seed producers as to how this breeding technique, which has been used for decades in popcorn production, might be useful in helping to achieve coexistence in corn production.
Breeding technologies most likely to achieve coexistence––Can hybrid breeding techniques or other established technologies help maintain seed purity, especially with open pollinated crops such as corn? What is the added cost of such techniques?
Lack of Knowledge of How to Breed GMO Out of non-GMO Foundation Seed
Theoretically, it is to breed GMO genetic material out of a variety. Under USDA leadership, and with the cooperation of the biotechnology industry and the non-GMO seed and crop industry, research should be conducted to demonstrate how this breeding process could be done practically and, hopefully, affordably. Such research might also discover what technology or testing would make this endeavor most practical and economically viable. Being able to reverse unintended GMO presence in the seed supply would greatly relieve some of the tension surrounding the coexistence issue.
Pesticides and Coexistence
The use of GMO crop technology is closely tied to the use of pesticides, and these pesticides are having unintended impacts on the environment and on organic crops. In addition, the use of pesticides seems to be increasing despite the promise of GMO technology to reduce overall pesticide use.
Unfortunately, these pesticides are no longer controlling weeds and pests. If GMO seeds linked to pesticides were a “silver bullet,” we would all know it by now.
The blanket use of pesticides matched to GMO crop seed for weed control has produced the expected result of “superweeds” that are resistant to chemical pesticides. Mare’s tail, the first weed resistant to Roundup (glyphosate), developed it defense in nature only four years after Roundup Ready soybeans were released. Which not only proves again that it does not take biotechnology to develop the trait, but that certain undesirable outcomes of current GMO technology are foreseeable. Now approximately 24 weeds have developed resistance to Roundup.
USDA approvals are pending to link GMO seeds to the herbicide 2,4-D. In the near future, we can expect other chemical pesticides such as dicamba and atrazine will also be linked to GMO crop seeds. New formulations encompassing various combinations of Roundup, dicamba, 2,4-D, and atrazine are already on the market, despite the fact that there is little information about the effects of the interactions of these chemical components on the environment or human health. All of these developments will most likely lead to ever increasing loading of pesticides on the environment.
In addition, pest resistance to Bt has occurred since the introduction of GMO crops containing the Bt gene. This resistance can lessened the effectiveness of Bt formulations sometimes used by organic farmers for pest control, thereby rendering useless a once judiciously used tool.
The environment impacts of glyphosate, 2,4-D, dicamba, and atrazine are documented and, to some extent, disputed. But with the passage of time the scientific evidence is mounting that serious undesired consequence to the environment and human health have occurred. Most recently, atrazine has been implicated in producing ill effects in wildlife and humans. In addition, the potential of drift damage from 2,4-D are well known.
Neonicotinoids, which are not now linked to GMO technology, have raised serious concerns about adverse impact on our bee populations—necessary pollinator of many crops.
To achieve meaningful coexistence, both USDA and EPA must change their environmental and health evaluation procedures to at least accommodate what we have already learned, if not to accommodate what we can reasonably expect.
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