Background

In 2006, the Center for Food Safety (CFS) sued the USDA for its illegal approval of Monsanto’s genetically engineered (GE) Roundup Ready (RR) alfalfa because the Agency failed to conduct the NEPA-mandated Environmental Impact Statement (EIS) before deregulating the crop.  The federal courts sided with CFS and banned GE alfalfa, mandating that USDA fully analyze the impacts of the GE alfalfa on the environment, farmers, and the public.   

USDA released its draft EIS on December 14, 2009 which fails to protect organic agriculture from GE contamination.  A 60-day comment period is open until February 16, 2010, so we must act now to organize our constituencies and to ensure the protection organic integrity now and in the future.

This is the first time that USDA has prepared an EIS for any GE crop and, therefore, the final, approved EIS will have broad implications for all GE crops.  The failure to address the environmental and related economic impacts of GE alfalfa will have far-reaching consequences for organic and U.S. agriculture as a whole, and that is why it is so important for the organic community to rally together and demand protections.

Review Draft EIS here: http://www.aphis.usda.gov/biotechnology/downloads/alfalfa/gealfalfa_deis.pdf

Review Supplemental documents here: http://www.aphis.usda.gov/biotechnology/alfalfa_documents.shtml.

Initial Concerns about the Draft EIS & Information Needed for the Record:

CFS has begun analyzing the EIS and it is evident that the USDA has not taken the concerns of non-GE alfalfa farmers or organic dairy farmers into consideration whatsoever.  It has completely dismissed the fact that contamination will threaten organic domestic and export markets.

• •  The EIS dismisses the significance of widespread contamination of organic and non-GE alfalfa. 

  Info Needed:  Opinions, experiences, studies (published or unpublished), anecdotal stories, and testing data that explains how contamination will occur or demonstrates  that contamination has occurred.  Attach actual data and studies to make your comments stronger.

• •  The EIS dismisses the significant adverse economic effects that GE contamination will have on organic and non-GE conventional alfalfa seed or hay growers (e.g. export markets), and organic and conventional dairy producers that rely upon organic and non-GE alfalfa hay for forage. 

  Info Needed:  Any studies (published or unpublished), anecdotal stories and economic analysis showing why contamination will harm you or your company, farm or dairy.  Supply any information, (personal as well as articles, and studies) indicating that markets you sell to are GE-sensitive or reject GE outright.  Attach actual economic data or studies, and proof that sensitive markets will reject contaminated product about markets makes to your comments stronger.

• •  The EIS’s economic analysis admits that RR alfalfa will hurt the organic industry and small farmers but it fails to analyze or suggest any possible protections for organic.
• •  The EIS says that there is no evidence that organic consumers care about GE contamination.

WE NEED TO PROVE THEM WRONG!

We must all participate in this widespread call to action to all of those who:

• care about the environmental and economic consequences of uncontrolled nation-wide growth of GE alfalfa;  
• believe in the public’s right to choose to eat non-GE food;
• want to protect farmers’ right to sow the crops of their choice; and
• want to prevent increased pesticide use and the enhancement of invasive weeds and the associated adverse impacts on biodiversity and endangered species.

Submit Your Comments to the USDA/APHIS — by February 16, 2010
http://www.regulations.gov/search/Regs/home.html#submitComment?R=0900006480a6b7a1