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11 February 2010 @ 01:53 pm
Urgent! USDA to regulate GE alfalfa. Comment period ends 02/16/1010  

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February 11, 2010 01:46 PM

Docket No. APHIS-2007-0044

Subject: Docket No. APHIS-2007-0044

Docket No. APHIS-2007-0044 Regulatory Analysis and Development, PPD, APHIS, Station 3A-03.8 4700 River Road Unit 118 Riverdale, MD 20737-1238

In USDA's Environmental Impact Statement (Docket No. APHIS-2007-0044) on genetically engineered alfalfa, USDA claims that there is no evidence that consumers care about contamination to organic alfalfa and alfalfa-derived foods from Monsanto's GE Roundup Ready alfalfa. As an organic consumer, I can tell you that I DO care.

Prohibition of genetic engineering (GE) is a fundamental tenet of the Organic Standard. In fact, the organic rule's failure to exclude GE from its first version was one of the main reasons why 275,000 people like me filed public comments in 1997, at the time the largest outpouring of public participation in the history of U.S. administrative procedure. Consumers care deeply about organic integrity, and GE is fundamentally not organic. Polls show that more than 75% of consumers believe that they are purchasing products without GE ingredients when they buy organic.

USDA also claims that consumers will not reject GE contamination of organic alfalfa if the contamination is unintentional or if the transgenic material is not transmitted to the end milk or meat product. The Organic Standard requires that livestock feed for animals used for meat, milk, eggs, and other animal products is 100 percent organic. As the Court found in the lawsuit that required this EIS, to "farmers and consumers organic means not genetically engineered, even if the farmer did not intend for his crop to be so engineered." Whether or not the end product is impacted is not the issue. Farmers' fundamental right to sow the crop of their choice is eliminated when it is contaminated with transgenes, and so is the public's ability to support meaningful organic food and feed production. Consumers like me will reject GE contamination of organic by any means or at any stage of sustainable food production.

USDA claims that Monsanto's seed contracts require measures sufficient to prevent GE contamination, and that there is no evidence to the contrary. In the lawsuit requiring this document, the Court found that contamination had already occurred in the fields of several Western states with these same business-as-usual practices in place! In general, where other GE crops were approved without restriction, 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 EIS itself acknowledges that GE contamination may happen and includes studies that honey bees can cross-pollinate at distances over 6 miles, and Alkali bees at 4-5 miles, much further than any distances under Monsanto's "best practices."

As a consumer, I care about the contamination of organic foods and crops, and I expect USDA to do everything the agency can to protect organic farmers and consumers. The organic industry provides many benefits to society: healthy foods for consumers, economic opportunities for family farmers and urban and rural communities, and a farming system that improves the quality of the environment. However, the continued vitality of this sector is imperiled by the complete absence of measures to protect organic production systems from contamination and subsequent environmental, consumer, and economic losses. USDA must reject the deregulation of GE alfalfa and protect the integrity of organic.

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