OSA’s Comments on New GE Corn Trait

OSA’s letter to USDA on a petition to deregulate drought-tolerant, genetically engineered corn

Dear Secretary Vilsack:

We appreciate the opportunity to provide comments on the broad consequences of deregulating MON 87460 (Docket No. APHIS-2011-0023), a new corn trait genetically engineered (GE) for drought tolerance.

Because seed is the first and most vital resource in the production chain, the integrity of seed is paramount to the success of organic and non-GE farmers. Introducing yet another GE corn trait that is rejected by organic and non-GE farmers and the markets they serve – and, to date, has proven uncontainable – places even more undue burden on the organic and non-GE community. The Environmental Assessment does not take seriously the risks this new GE crop poses to this valuable and growing sector of agriculture. And we believe that any new GE crop under consideration requires a full Environmental Impact Statement that looks at any potential environmental, economic and social implications of introducing the new biotechnology trait.

Organic seed requires genetics free of transgenic material. Cross-pollination (and other routes of contamination) between GE and organic and other non-GE corn already increases production costs, eliminates markets for organic and non-GE producers, and harms the credibility of the organic label. Organic farmers and seed producers need seed that is free of transgenic material to meet USDA’s national organic standards, which require seed absent GE traits. In the event contamination occurs, organic and other non-GE seed producers need those who own, promote, and profit from GE seed technologies to be held responsible for the irreparable damage contamination causes.

Organic farmers and seed producers also need the organic label to remain credible, as consumers reasonably assume organic means GE-free. Many organic farmers and businesses know their customers well, and they know these customers expect their products to be free of GE traits. Any and all presence of such traits will cause their customers to lose confidence in their products.

Costs associated with contamination – testing for contamination, reimbursement for eradicating unwanted genetically engineered material from seed stock, lost premiums, and other costs – cannot continue to be borne by the organic and non-GE farming community. “Co-existence” has not been a reality with other GE corn varieties. Furthermore, any discussion involving the introduction of a new GE crop must be coupled with a contamination plan to protect non-GE seed and crops. At a minimum, there must be a contamination compensation fund of some kind that is paid by GE crop patent holders to provide immediate assistance to those who are contaminated.

When a product threatens to impact not just a single neighboring crop, but the integrity and viability of a farm and industry label, what recourse do those not choosing this technology have when seed genetics, markets, and reputation are harmed? Although both the organic and biotechnology industries acknowledge that GE material is moving into fields and markets where it is not allowed or wanted, little has been done to address the problem through regulatory processes and enforcement.

We urge you to take seriously contamination prevention strategies that adhere to principles of diversity, fairness, liability, precaution, sustainability, and transparency. Only then will we make progress toward protecting the integrity of organic and non-GE seed and feed sources.

Lastly, it is disconcerting that USDA continues to rely on data provided by the manufacturer petitioning for, and profiting from, the release of the product at hand. It is long past due that rigorous independent studies be initiated and considered by USDA in these decision making processes. This research must examine, for example, existing work on drought-tolerant corn bred and produced in organic and sustainable farming systems – research that does not rely on a technology that does not benefit, and indeed harms, farmers who rely on organic and sustainable farming systems, and marketplaces that do not tolerate the technology.

USDA also has the responsibility to bolster public programs involving classical plant breeding to meet the diverse needs of farmers without putting the integrity of a valuable and growing industry at risk. While both the biotechnology industry and USDA claim that GE crops are the solution to feeding our growing population, side-by-side comparisons show that genetic engineering does not have an advantage when it comes to producing better crops faster. Given this fact, the lack of attention and funding for classical plant breeding in the public sector is a critical issue that must be addressed through USDA’s research programs.

Thank you for your time and consideration of these comments.

Sincerely,

Kristina Hubbard

Director of Advocacy and Communications

Organic Seed Alliance

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4 Responses to OSA’s Comments on New GE Corn Trait

  1. “Organic seed requires genetics free of transgenic material.”

    No it does not – while the NOP excludes GE crops, it does not require that organic seeds or crops are free of transgenes, nor does it require testing to enforce any such absence. This sentence in an official statement by the Organic Seed Alliance is false, and should be retracted.

    “Organic farmers and seed producers also need the organic label to remain credible, as consumers reasonably assume organic means GE-free. Many organic farmers and businesses know their customers well, and they know these customers expect their products to be free of GE traits. Any and all presence of such traits will cause their customers to lose confidence in their products.”

    This is an interesting paragraph, because it demonstrates the complexity of the situation. It is stated that organic consumers demand 100% freedom of transgenes, which is not actually true, by the way. (see here: http://www.biofortified.org/2010/03/organic-consumers-not-very-concerned-about-ge/) And in response to that perceived demand, it is assumed that the organic agricultural community must meet that standard. Note that absolute absence of synthetic pesticide residues is neither demanded, nor met by organic consumers and the industry, respectively. But prohibitions on their use in organics is strict, much stricter than the presence of transgenes. What could cause such an imbalance in perceived demand, and response to that demand?

    I think part of the problem here is that certain members of the organic community and advocates are trying to both convince consumers that absolute purity with 0% transgenes is necessary, and then turn around and say that their hands are tied by the demands of their consumers. One former employee of the OSA has described (using war analogies) this demand for 0% transgenes thus:
    “This is not a scenario I would have suggested a year ago, as I always have maintained that although organic standards are not test-based, our organic food should be free of all GE traits — or not certified organic at all. I now believe that stance will lead to an unwinnable war. ”
    http://www.pccnaturalmarkets.com/sc/0909/sc0909-organic-integrity.html

    The ironic part in all of this is that the Organic Seed Alliance is penning opinions opposing a trait that will not only be useful in helping adapt crops to drought and the effects of climate change, it is precisely the kind of trait that could be grown in an organic agricultural system and provide benefits to that system. Is the Organic Seed Alliance interested in forging alliances beyond the previously-drawn nation-boundaries that we have all inherited?

    In this letter, Kristina Hubbard said that “This research must examine, for example, existing work on drought-tolerant corn bred and produced in organic and sustainable farming systems.” Does the Organic Seed Alliance support testing GE drought-tolerance traits also in organic agricultural systems to see what benefits that combination might yield?

  2. Pingback: Seed Digest (July 8 – 22, 2011) | Seed Broadcast

  3. Matthew says:

    “This is not a scenario I would have suggested a year ago, as I always have maintained that although organic standards are not test-based, our organic food should be free of all GE traits — or not certified organic at all. I now believe that stance will lead to an unwinnable war. ”
    - Karl, you use this quote but fail to share the context – which was a call for a system of accountability in contamination of organic and non-GE crops by their GE counterparts. The article clearly makes a case for accepting LLP, but ONLY under a regulatory system that collects fees from GE sector to pay for contamination above a set acceptable limit. Until that occurs, then we are forced to fight what I do believe to be an un-winnable war, but a necessary one to protect choices to eat food free of unacceptable levels of GE presence.

    As to this drought corn, I believe Pioneer already has a conventionally bred drought tolerant corn that is performing as well or better than Monsanto’s trangenic, with perhaps a 1 or 2% difference in extreme years (and a potential yield drag in normal years). We have little need for this in organic (nor do I think it will be widely used in conventional, given likely cost of biotech trait over conventional) as we don’t grow much corn in submarginal areas like eastern Colorado or western Kansas – and if a farmer did, they could buy the Pioneer varieties that are not transgenic. To suggest that growing corn in drought-prone western Kansas is beneficial and will mitigate climate change is a joke. This area should be used for wheat, but false commodity markets and inflated corn-biofuel prices farmers push farmers to sometimes opt for corn….we’d better serve hunger, climate, and other enviro issues by stopping the corn subsidies, paying those farmers higher prices to grow food, and not grow corn in substandard areas with 8 inches of annual rainfall. It’s absurd, and to promote a drought tolerant biotech trait without looking at the entire system in which it is being promoted is to not see the forest for the trees.

  4. I’m glad I checked back – I had thought that Kristen would be responding to my comment as per her email, but there’s some good meat in Matthew’s words to chew on. My response is below:
    “Karl, you use this quote but fail to share the context – which was a call for a system of accountability in contamination of organic and non-GE crops by their GE counterparts. The article clearly makes a case for accepting LLP, but ONLY under a regulatory system that collects fees from GE sector to pay for contamination above a set acceptable limit.”
    It was not my intention to obscure discussion of the compensation fund idea, but to focus on how you said that the GE-free-or-not-certified stance is untenable. You did not say in the article that this stance only applies if the compensation fund is generated. So that I understand your position clearly, you believe that until such a fund is set up – organic farms should be decertified if any GE plants show up?
    This aspect of my comment has essentially gone unanswered so far. Is absolute purity of seed a de facto requirement of organic agriculture? I am all in favor of finding out what exactly is an unacceptable level – and the only information I can find are opinions from thought-leaders (and not the consumers) or poorly designed studies from the Consumer’s Union which were designed to get a response that they didn’t get and tried to cover up. (above)

    Your compensation fund idea is interesting in several ways, in fact I have been mentioning it to a lot of people. From the organic side, however, the views are far more negative than from the GE side. I think there are more details that need to be considered, and I have asked you a couple questions about it that have gone unanswered. Hopefully we might be able to discuss it in more detail in the future, but this digresses from the reason why I commented.

    “As to this drought corn, I believe Pioneer already has a conventionally bred drought tolerant corn that is performing as well or better than Monsanto’s trangenic…” Pioneer has been breeding drought-tolerant GE corn conventionally, in fact I met the guy running that project. They are also working on biotech traits for the same, which I imagine would be combined in the future. Also, the current drought-tolerant Pioneer corn is being combined with other GE traits, perhaps there are some available varieties without any GE traits, but probably not at the diversity available for the GE ones:
    http://deltafarmpress.com/corn/agribusiness-pioneer-releases-drought-tolerant-corn-hybrids
    But I think you are missing the point here. To a farmer, 2% is still substantial, but news reports are pegging the Pioneer corn with 5% in drought years, and Monsanto says its GE variety pushes above 6%. Now I’m not going to say before seeing more detailed information how fantastic either of these will really be, because it is still early, but I was thinking more along the lines of an open-minded approach to determining whether or not it would be beneficial. Matthew, you have dismissed such an approach out of hand, without suggesting that maybe there is some interesting discovery to be made that our simple human philosophies didn’t consider. Could the drought benefits of a soil-building organic regime and of crops bred – and engineered – to use water better not only combine well, but combine in such a way that the result is greater than the sum of its parts? I guess what I’m looking for is a more holistic approach to figuring out a trait’s overall usefulness, and not devolving the discussion into complaints about how much corn there is. Finally, I would like to note the contradiction in that you are arguing against the GE drought-tolerant corn because it is not needed or would be bad for Kansas and beyond, yet, you also say that drought-tolerant non-GE corn would be fine to buy. Apart from cost, I think deciding whether or not the trait would be beneficial to farmers is independent of how it is derived.

    “To suggest that growing corn in drought-prone western Kansas is beneficial and will mitigate climate change is a joke.”
    The joke’s not mine – because I did not suggest any such thing. I came back to this page because I read the news about drought hitting a lot of farms and affecting the crops this summer. You do not need to go to submarginal lands to find a benefit from drought tolerance.

    “It’s absurd, and to promote a drought tolerant biotech trait without looking at the entire system in which it is being promoted is to not see the forest for the trees.”

    There’s more than one ‘system’ to consider. I don’t expect someone who has been very clear that they are not interested in any GE crops whatsoever to be willing to entertain the idea that maybe the systems we have erected in our heads need adjusting just as much as the systems we’ve erected on farms.
    Looking forward to further discussion.

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