OSA Delivers Comments to USDA on Organic Seed

OSA provided the following comments at a USDA listening session today focused on the agency’s priorities  and activities related to organic production and markets. Our comments focused on the need to adequately fund public plant breeding programs, with an emphasis on organic seed system projects, and the importance of implementing contamination prevention measures in conjunction with a compensation plan to mitigate risks associated with genetically engineered crops.

You can submit your own comments by October 1, 2011, to 2011OrganicListening@ams.usda.gov. The agency is looking for feedback on these topics.

Comments from Kristina Hubbard, Director of Advocacy, Organic Seed Alliance

U.S. Department of Agriculture | Organic Working Group | National Organic Program

Listening Session on USDA Priorities and Activities Related to Organic Production and Markets

September 20, 2011

Good afternoon. Thank you for hosting today’s listening session on such an important subject. My name is Kristina Hubbard and I’m the director of advocacy for Organic Seed Alliance, a national organization that advances the ethical development and stewardship of the genetic resources of agricultural seed. Our research and education programs engage farmers and other seed professionals in developing regional and decentralized seed systems that provide biologically diverse seed options appropriate for organic farming systems. And we aim to influence policy decisions that impact the integrity of the seed systems we help create.

Earlier this year, OSA released its State of Organic Seed report, the first comprehensive analysis of the opportunities and challenges in building the organic seed sector. Our data shows that while farmers report increased attempts to source organic seed, the lack of organically bred and produced seed remains a major barrier to the growth and ongoing success of organic farming. Organic producers are underserved in genetics specifically adapted to their cropping systems, regions, and market niches.

We conducted a survey of certified organic farmers in 45 states and found that more than 80% of respondents believe that varieties bred for organic systems are important to the overall success of organic agriculture. Yet investments in organic seed projects lag behind the enormous growth of the organic sector, now valued at $29 billion in 2010 alone. Investments in organic seed projects total $9 million, but that’s over the course of 14 years.

Here’s one way the department can intensify its support for organic agriculture. OSA has been facilitating an Organic Plant Breeding Working Group, made up of about a dozen public plant breeders across the U.S., and they relay that they need USDA to increase support for long-term organic plant breeding projects. Our research shows that many past organic breeding projects did not produce finished varieties, in part because most grants only cover 1 – 4 years of work. Breeding projects often take 4 – 12 years to reach a final product ready for release.

So, we need longer term funding and more funding for important research programs such as the Organic Research and Education Initiative.

Funding is also needed to support field trial networks that assess germplasm in organic production systems. When optimum genetics are identified, funding is needed to help educate breeders and farmers producing seed on how to commercialize a new variety.

Finally, funding farmers’ involvement in participatory breeding projects is a golden opportunity to support family farmers while creating infrastructure for developing more choice in the marketplace in the face of a highly consolidated seed industry dominated by non-organic interests.

Rebuilding public plant breeding programs is therefore essential to expanding choice to meet the diverse needs of organic farmers and support the public interest. The National Institute for Food and

Agriculture must honor a clear mandate from Congress to provide meaningful funding for the development of public plant varieties. We also support creating an Institute for Seeds and Breeds for the 21st Century, a distinct sub-agency within USDA’s National Institute for Food and Agriculture to address this urgent need to adequately fund classical plant breeding.

It is especially important that USDA-funded research remain in the public domain to ensure public access to germplasm and prevent the further consolidation of our nation’s plant genetic resource base.

The 2010 competition workshops that USDA hosted in partnership with the Department of Justice ignited hope in farming communities, including the organic community. They were hopeful that agencies were confronting the abuse of market power, especially the abuse of utility patents on plant genetics. Yet neither USDA nor DOJ seem inclined to even publish a report in response to the thousands of public comments personally delivered at the 2010 workshops. We urge USDA to continue working with DOJ and to release a report, and, ideally, a plan of action.

We know that research and development has largely narrowed to focus on other industry interests, in particular biotechnology, which brings me to my last point.

USDA can better support growth in the organic sector by confronting the challenges of contamination by unwanted genetically engineered material, and implementing policies that ensure a shared responsibility for contamination prevention. USDA should implement mandatory contamination prevention measures for those who adopt the technology, since the burden of prevention currently resides solely with non-adopters of the technology.

Such measures must be coupled with a compensation plan – paid for by patent holders promoting and profiting from the products – to cover costs for those immediately harmed by contamination as well as costs associated with contamination prevention. Seed companies selling at-risk organic field crops relay that contamination happens and they incur financial losses on account of it, with no recourse for recouping these losses.

This is why it is especially disconcerting that USDA is signaling a move to limit its regulatory authority instead of strengthening oversight in the face of contamination events and recommendations by independent government offices, including the Government Accountability Office and the agency’s own Inspector General.

For example, USDA is exploring options that would advance an already largely self-regulating system. One of these options would allow manufacturers of regulated products to perform their own environmental assessments, a necessary step for deregulation. This proposal presents an indisputable conflict of interest. Studies that are scientifically rigorous and conducted by independent third parties have never been more important for reviewing the performance and safety of genetically engineered products. USDA must use its regulatory authority under existing law.

Thank you for the opportunity to provide comments.

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