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Coexistence and GE Alfalfa

by: Jill Richardson

Sun Jan 23, 2011 at 18:32:38 PM PST


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I haven't said much, if anything, yet about the USDA's new mantra of "coexistence" between GE, conventional, and organic farmers. But now, the Organic Trade Association (which I'm told is dominated by Organic Valley) and Whole Foods have come out in favor of this coexistence idea. I think it's time to say something about it. This post focuses on the immediate issue, GE alfalfa. However, I'd like to follow up with a second post about coexistence in a broader context of all U.S. agriculture.
Jill Richardson :: Coexistence and GE Alfalfa
Let's start with the excellent summary provided by the National Sustainable Agriculture Coalition:

USDA Secretary Vilsack, appearing before the Committee in the 112th Congress for the first time, was the primary witness at the Forum.  Last December, USDA released a Final Environmental Impact Statement for commercial use of GE alfalfa.  USDA has indicated that the agency is ready to approve the partial deregulation of GE alfalfa for commercial planting under a plan of "co-existence," a position restated by Secretary Vilsack at the House hearing.  The Secretary's view on co-existence is laid out in an open letter to opponents and proponents of GE crops.

As you can see, the idea of coexistence can apply to anything, but the USDA is specifically talking about GE alfalfa. The USDA is, as ever, pro-biotechnology, but after getting smacked by the courts a few times, they are now paying a bit of attention to the Environmental Impact Statement for GE alfalfa. Vilsack's open letter states:

As a regulatory agency, sound science and decisions based on this science are our priority, and science strongly supports the safety of GE alfalfa. But, agricultural issues are always complex and rarely lend themselves to simple solutions. Therefore, we have an obligation to carefully consider USDA's 2300 page EIS, which acknowledges the potential of cross-fertilization to non-GE alfalfa from GE alfalfa - a significant concern for farmers who produce for non-GE markets at home and abroad.

The rapid adoption of GE crops has clashed with the rapid expansion of demand for organic and other non-GE products. This clash led to litigation and uncertainty. Such litigation will potentially lead to the courts deciding who gets to farm their way and who will be prevented from doing so.

Vilsack would prefer that the USDA makes the decisions about biotechnology, not the courts. Thus, he's called for "coexistence." And for that, he's drawn criticism from both biotech interests and anti-biotech interests.

GE alfalfa is not the first GE crop to go through the regulatory process. However, it's open-pollinated, and that's driving a lot of controversy. From what I have gathered, it's difficult to hybridize alfalfa, and the first hybrid alfalfa was introduced to the market only in 2001 (compared to corn and other crops, which were successfully hybridized decades ago). The relevant difference between hybrids and open pollinated (OP) seeds is that farmers generally don't save seeds if they plant hybrids, but they can save seeds if they plant OP seeds.

For a genetically engineered crop, this means that in the past, when GE corn was put on the market and purchased by the majority of corn growers in the U.S., the genes for the GE traits could be passed via wind to non-GE or organic corn growing nearby... but then the vast majority of that corn was eaten, not planted. But when GE alfalfa pollen is taken by bees to non-GE or organic alfalfa plants, the result could be a next generation of seeds that will be saved and planted with the GE traits in their DNA.

For an organic farmer or a farmer who is paid a premium for planting and selling a non-GE crop, this is trouble for an obvious reason. They might plant a non-GE crop while their neighbor next door plants GE alfalfa... and with some cross-pollination, their non-GE alfalfa can produce GE seeds. Thus, they might lose the premium price they were expecting to get for their crops if testing reveals the GE contamination.

But there's another issue, which Joanne Rigutto brought up: alfalfa is a perennial. Farmers can get rid of their alfalfa by tilling or spraying herbicide - typically Roundup (glyphosate), perhaps mixed with 2,4-D. After Joanne brought it up, I checked in with some folks who know more about this than I do and they confirmed it. The benefits of Roundup (to a non-organic farmer) are that it is cheap and it doesn't stay in your soil and kill future plants you grow there. For a non-organic farmer who plans to grow non-GE alfalfa and then kill it with Roundup, it would be a BAD surprise to suddenly find out that their alfalfa is Roundup Ready! To kill a field of alfalfa, they would be forced to choose between tilling or using another (potentially more toxic) herbicide instead of Roundup.

Going back to the NSAC synopsis:

USDA is scheduled to announce its final decision for the regulation of GE alfalfa on or very soon after January 24.  The plan for partial deregulation would rely on buffers, restricted planting areas and other methods in an attempt to prevent the contamination of non-GE alfalfa, including organically produced alfalfa, with genetic material from GE alfalfa.

The issue is especially critical for the growing organic dairy sector, in which many farmers rely on organic alfalfa for feed. There are numerous examples of contamination of non-GE crops by GE crop genetic material, including an entire line of a major rice variety.  USDA has yet to adequately demonstrate that there are effective methods for preventing such contamination.

This past week, as I've reported here, a few Republican Congresscritters sent a letter to Tom Vilsack expressing their views that the USDA should go ahead with allowing GE alfalfa to be planted everywhere, with no buffer zones or geographic restrictions. Also this week, the House Ag committee held a hearing, which it called a "Public Forum." The House Ag committee site is a mess these days, and I have yet to get all of the testimony, let alone a transcript or a recorded webcast of the hearing. But NSAC said of it:

An important point to note is that no one at the House Forum raised the issue of the proliferation of glyphosate-resistant weeds, especially in the South and Mid-West, where large amounts of glyphosate are applied every year to agricultural land growing Round-Up Ready GE crops.  Recent reports indicate that farmers are abandoning some fields, undoing years of work in conservation tillage to control weeds with heavy tillage, and turning to the use of more toxic herbicides.  Before the development of GE crops, glyphosate herbicide was used more judiciously because it could damage emerging crops.  With the development of GE crops, the agricultural landscape has been flooded with glyphosate using methods that include large-scale aerial spraying.

USDA has yet to adequately address the issue of herbicide resistance in its oversight of GE crops. USDA should turn its attention from promoting GE crops to provide at least equal time for a concerted effort to promote the use of cover crops, resource-conserving crop rotations, and other sustainable techniques that can help control weeds and provide additional benefits in improvements to soil quality and water quality.

Well, the latest news is that the Organic Trade Association has sent a letter to Vilsack, agreeing to the idea of coexistence. In their own words:

In response, OTA's Executive Director and CEO Christine Bushway sent a letter to Secretary Vilsack outlining OTA's willingness for dialog but also stressing OTA's belief that in order to have meaningful coexistence, policy decisions regarding GE regulation should shift the costs related to inadvertent contamination from the organic and non-GE sectors to the patent holders of the GE crops, protect organic seed crops, and assure implementation of requirements to avoid contamination in the first place

Whole Foods has also taken a stance favoring coexistence. And on the very other hand, Organic Consumers' Association (an organization I am proud to be affiliated with!) says "Hell no!" to coexistence.

I think all who support sustainable ag would obviously prefer GE alfalfa allowed with restrictions instead of having it allowed and unrestricted. And, in that case, I quite agree with the OTA request that the cost of any contamination of organic costs be shifted away from organic producers. But, given the general track record of GE crops in this country... the fact that they undergo very little (if any) independent testing and any scientist who publishes findings of anything negative about GMOs gets shouted down and the very well-established fact that GMOs cannot be contained... I think it would be better if GE alfalfa was not allowed for commercial planting at all. It seems that OTA and Whole Foods have given that option up as a lost cause (which it likely is) and that's why they've thrown their support to "coexistence."

There's certainly more to say on this, but I will save it for a future post.

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coexistence (4.00 / 1)
I agree with your essay. You covered the issues well, but I'd like to highlight your final sentence.

It seems that OTA and Whole Foods have given that option up as a lost cause (which it likely is) and that's why they've thrown their support to "coexistence."

Lucas et alia and Vilsack mention the safety of GE alfalfa. APHIS made the decision about safety years ago, before superweeds had emerged as a serious concern. APHIS actually decided to deregulate GE alfalfa (without restrictions) in 2005, but in 2007 a judge required the development of the Environmental Impact Statement. I doubt that any significant USDA voices ever seriously considered that development of the EIS would lead to a decision that GE alfalfa would not be deregulated, and in fact, simply stated, USDA is not considering this option. Hence the positions taken by Whole Foods and OTA.

Despite the linkage between OTA and Organic Valley, this is the position on Organic Valley's website today:

Organic Valley and Organic Prairie have always been actively involved in advocating for the elimination of GMOs. We support the position of many environmental, health, farmer and consumer organizations, and call for immediate mandatory labeling of all foods and food ingredients produced from GMOs.

Organic Valley is a founding supporter of the Non-GMO Project, and our CEO George Siemon is member of their board of directors.

In partnership with Center for Food Safety, Organic Valley supported the fight against GMO Round-up Ready alfalfa seed.

Probably we can all understand the Whole Foods and OTA decisions, but the position of the Organic Consumers Association is important because there is a long line of GE crops that will be coming up for regulatory decisions. One dispiriting aspect of the regulatory environment has been the refusal to consider non-deregulation as a viable option. This needs to be changed.

An important point to note is that no one at the House Forum raised the issue of the proliferation of glyphosate-resistant weeds...

Another dispiriting aspect of the discussion, I must say. I wonder why not.

(Side question: was GE alfalfa planted between 2005 and 2007?)


superweeds (4.00 / 1)
Despite weed issue, Obama USDA committed to biotech

Sep 30, 2010
Philip Brasher

Ann Wright, a deputy undersecretary at the USDA, told a House oversight subcommittee today that the Obama administration is committed to protecting the continued use of genetically engineered seeds and lacks authority to restrict herbicide-tolerant crops even if it wanted to.

"This administration and USDA see biotechnology as being a very import{ant} tool for farmers to use in addressing some very important issues, globally and domestically," Wright said.  "All the options we look at have to be supportive of that." She said that limiting the use of herbicide-tolerant crops would force farmers to "return to older, often costly, and less environmentally friendly" ways of controlling weeds.

She  said the USDA can regulate herbicide-tolerant crops only to prevent them from becoming pests themselves, not to stop their use from leading to resistant weeds.

The department's stand didn't sit well with Rep. Dennis Kucinich, an Ohio Democrat and former presidential candidate who is chairing a series of hearings on the superweed issue. Kucinich told Wright that the department could impose restrictions on herbicide-tolerant crops under its authority to control noxious weeds.

Wright admitted that she wasn't familiar with the noxious-weed section of the law, prompting Kucinich to respond, "You're really not? If the regulatory agency is not fully aware of the full extent of its authority then that may be why we're having a problem here."

I suppose we won't get much of that kind of dialog for at least the next two years.


[ Parent ]
tilling (4.00 / 1)
Joanne actually referred to deep tilling. I'm not a farmer so I don't know the answer to these questions: do farmers ordinarily have equipment for deep tilling? Would the requirement for deep tilling imply further investments in expensive equipment?

I don't know about the other crops (4.00 / 2)
but at least with the sugar beet farmers I've heard about is that a lot of them don't have the equipment since they started using RR sugarbeets for weed control.

As far as removing alfalfa from an existing field, I think the reason for spraying (hence my concerns about glyphosate resistance in alfalfa), is to eliminate or reduce the need for deep tilling. You spray the plants, which in turn pull the chemical down into the roots and die. If I understand it right, the weather conditions have to be right to spray. Can't do it if it's blowing much, needs to be the right range of air temps (not too hot or too cold), and it has to be dry (preferably sunny) for a minimum number of hours (4-7?). We haven't had to use it out here in several years, and I don't use it except for specific plants. Harold used to spray the grass in the driveway, and for noxious weeds that were harmful to livestock.

One of the nice things about glyphosate containing products is that you can spot apply the stuff on things like tansey, and in a couple of days the animals can go back out onto the pasture. In addition to tansey (which causes liver damage in livestock) I've had St. John's Wort along the fences on the highway side of the paddocks. It causes photosensitivity in livestock. If the goats eat it, exposed skin on lips, around the nose, etc. blisters when exposed to the sun. The stuff self seeds and spreads by rhizome, it is a perenial and can be very invasive. So the option is digging every year, or spray the stuff.

For weed removal of row crops cultivation is used, which I think is deep tilling. I know there is one farm down in California who's blog I follow, that uses brush cultivating to reduce weed pressure on their crops. They grow vegetables, fruit and grains. I've seen video of the brush cultivator and it's pretty cool. The trick, as I understand it is to get the weed seeds to germinate before the crop does. Then you go along the surface with this big round brush (think like a street sweeper has) and the brush bristles disrupt the weed seedlings which lay on top of the soil and dessicate, dieing. Then you come in and plant your crop.

I probably sound like a heretic speaking about glyphosate containing products, but I do think it's a useful product as long as it's not sprayed willy nilly all over everything. That's the big problem I have with RR crops (well that and the patent issues).

Normal people scare me.... But not as much as I scare them.


[ Parent ]
I agree that Round-Up is useful... (4.00 / 2)
if it is used occasionally and not heavily. I've used it to clear land to establish prairie gardens and for spot uses along fence lines. I'll use ant spray to get rid of ants infesting the chicken coop. But the key is to use the chemicals on a spot basis as needed, not on a continuing, will-nilly basis. I used to spray my potatoes the first couple years I grew them (though with an organic spray for potato beetles); now I find it's actually easier (and certainly less costly) for me to run a daily beetle check, knocking them off the potato plants or squishing them.  

[ Parent ]
Yup (4.00 / 2)
that's how I'll use it if anything comes up that I have to kill quickly and surely. Otherwise I hand weed and/or harvest for sale.

The same goes for other chemicals. I have used copper spray one year here, in two applications. It was a couple years ago when I had blight show up on the tomato plants. I used it when I saw the blight start up. Went out and culled the most heavily affected plants, then sprayed twice over a 2 week period. That's how things like these should be used.  

Normal people scare me.... But not as much as I scare them.


[ Parent ]
AgSense confusion (4.00 / 1)
AgSense: Roundup Ready Alfalfa should be available in 2011

Jan 3 2011
Leonard Lauriault, NMSU forage agronomist

The development of Roundup Ready Alfalfa represents a significant innovation allowing for more effective weed control and lower overall herbicide use with lower toxicity to applicators, as well as reduced use of environmentally-damaging herbicides.
...

The second option places restrictions on where RRA seed can be grown...That is: RRA forage fields cannot be harvested for seed; RRA forage grown within 165 feet of an alfalfa seed field must be harvested when or before it reaches 10 percent bloom; and RRA seed fields have to be identified by GPS coordinates and be at least five miles from any non-RRA seed field.

If a forage agronomist is that misinformed, who can expect politicians and bureaucrats to be less confused? The point of RR crops is to enable more herbicide use.


field abandonment (4.00 / 1)
The NSAC article contains a link that supposedly goes to a report about farmers abandoning fields. The linked article reports no such thing, but the article is nevertheless very interesting.

Growing Roundup-resistant weed problem must be dealt with, expert says

September 14, 2010

"During the period since the introduction of glyphosate-resistant crops, the number of weedy plant species that have evolved resistance to glyphosate has increased dramatically, from zero in 1995 to 19 in June of 2010," Mortensen said.

This list includes many of the most problematic weed species, such as common ragweed, horseweed, johnsongrass and several of the most common pigweeds -- many of which are geographically widespread.

"In practice, the problem of glyphosate resistance goes far beyond a species count," Mortensen said. "More important, perhaps, is the increase in acreage infested with glyphosate-resistant weeds. The reported extent of infestation in the United States has increased dramatically since just November of 2007, when glyphosate-resistant populations of eight weed species were reported on no more than 3,251 sites covering up to 2.4 million acres."

In the summer of 2009, glyphosate-resistant weeds were reported on as many as 14,262 sites on up to 5.4 million acres, and the most recent summary indicates 30,000 sites infested on up to 11.4 million acres, according to Mortensen. In a period of three years, the number of reported sites infested by glyphosate-resistant weeds has increased nine fold, while the maximum infested acreage increased nearly fivefold.

"There is reason to believe this trend will continue into the future," he said. "The cost of forestalling and controlling herbicide-resistant weeds is estimated to cost farmers almost $1 billion each year, at an additional cost of $10-20 per acre."

Mortensen expressed concern about herbicide- and germplasm-development companies responding to the glyphosate-resistance problem by developing a new generation of genetically engineered crops in which glyphosate-resistant cultivars are being engineered to have additional resistance traits introduced into the crop's genome.

"These additional gene inserts will confer resistance to other herbicide active ingredients, including 2,4-D and dicamba," he said. "For a variety of reasons, it is quite likely that such crops will be widely adopted. Disturbingly, that would result in a significant increase of older, higher use-rate herbicides in soybean and cotton production.

"If they are adopted in the way I expect they will be, herbicide use in soybean production would increase by an average of 70 percent in a relatively short time after the release of these new genetically engineered, herbicide-resistant cultivars."



toxic weeds (4.00 / 1)
Alfalfa is a forage crop, duh, so it seems to me that glyphosphate tolerance and glyphosphate resistance among weeds that are toxic to animals should be a top concern. Frank Lucas is unconcerned, which particularly puzzles me because he claims to be or to have been a rancher.

I've been trying to find an up-to-date list of weeds that already are GT or GR, but have not been successful. One problem is that when Mortensen talks about 19 resistant weed species, I think he referred to the incidence globally, not just in the U.S. Also, I don't know if he strictly meant resistant, or his 19 includes tolerant species.

I did find an interesting article written in early 2009.

Loss of Glyphosate Efficacy: A Changing Weed Spectrum in Georgia Cotton

Weed Science
2010
58:73-79

It focused on Benghal dayflower and Palmer amaranth but the 10 most troublesome weeds in Georgia cotton fields in 2005 were

Benghal dayflower
Palmer amaranth
Morningglories (Ipomoea spp.)
FL pusley
Nutsedges
Asiatic dayflower
Smallflower morningglory
Texas millet
Wild poinsettia
Bermudagrass

There is a difference between herbicide resistance and herbicide tolerance. Who knew?

The Weed Science Society of America defines herbicide tolerance as ''the inherent ability of a species to survive and reproduce after herbicide treatment. This implies that there was no selection or genetic manipulation to make the plant tolerant'' (Anonymous 1998). Benghal dayflower is tolerant to glyphosate and many of the herbicides used in agronomic crops. It was first reported in agronomic fields of south Georgia in 1999, soon after the adoption of GTC (Culpepper et al.2004).

The Weed Science Society of America defines herbicide resistance as the ''inherited ability of a plant to survive and reproduce following exposure to a dose of herbicide normally lethal to the wild type. In a plant, resistance may be naturally occurring or induced by such techniques as genetic engineering or selection of variants produced by tissue culture or mutagenesis'' (Anonymous 1998). Herbicides do not cause the mutations that lead to herbicide resistance, but instead impose selection pressure such that adaptive, naturally occurring mutations become established and increase in frequency in a plant population. Palmer amaranth has developed resistance to many classes of herbicides including glyphosate, dinitroani- lines, triazines, and acetolactate synthase (ALS) inhibitors (Culpepper et al. 2006; Gossett et al. 1992; Heap 2008; Horak and Peterson 1995; Sprague et al. 1997; Vencill et al. 2008; Wise et al. 2009). In Georgia cotton, Palmer amaranth resistance to glyphosate and ALS-inhibiting herbicides is a significant weed management issue.

So at least Benghal dayflower already is glyphosphate tolerant, and at least Palmer amaranth already is glyphosphate resistant, and Palmer amaranth is toxic to livestock because of high nitrate accumulation. Benghal dayflower also is known as tropical spiderwort, and has been on the Federal Noxious Weed List since 1983.

Weed species with a known tolerance to glyphosate include dayflowers (Commelina spp.), smartweeds (Polygonum spp.), and morningglories. Genetically diverse weed species, such as crabgrasses (Digitaria spp.), foxtails (Setaria spp.), Sorghum species, velvetleaf (Abutilon theophrasti Medik.), pigweeds (Amaranthus spp.), common lambsquarters (Chenopodium album L.), kochia [Kochia scoparia (L.) Schrad.], and common cocklebur, are at risk for developing glyphosate resistance where glyphosate is applied continually over time and space (Powles 2008a).

Farmers Cope With Roundup-Resistant Weeds

WILLIAM NEUMAN and ANDREW POLLACK
May 3, 2010

Bayer is already selling cotton and soybeans resistant to glufosinate, another weedkiller. Monsanto's newest corn is tolerant of both glyphosate and glufosinate, and the company is developing crops resistant to dicamba, an older pesticide. Syngenta is developing soybeans tolerant of its Callisto product. And Dow Chemical is developing corn and soybeans resistant to 2,4-D, a component of Agent Orange, the defoliant used in the Vietnam War.



Apparently the Vatican (!!!) supports GMO... (4.00 / 2)
I thought the voiceover (4.00 / 1)
in those Monsanto commercials sounded suspiciously pontifical.

[ Parent ]
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