Featured Speakers

RAYNE PEGG OF USDA
SPEAKS MONDAY MORNING AT
DEL MAR MARRIOT
10 AM- 10:45 AM

The Small Farm Conference is pleased to announce Rayne Pegg*, Russ Parsons, Josh Viertel, and A.G. Kawamura as keynote speakers at the 2010 California Small Farm Conference.

Rayne Pegg became Administrator of the Agricultural Marketing Service (AMS) on July 6, 2009. In her position, she has the responsibility of overseeing AMS policies and programs.

USDA's Agricultural Marketing Service administers programs that facilitate the efficient, fair marketing of U.S. agricultural products. AmRAYong those programs are the National Organic Program, international marketing services, and farmers' market and local food marketing programs – including the Farmers' Market Promotion Program.

Pegg most recently was Deputy Secretary of Legislation and Policy for the California Department of Food and Agriculture (CDFA). Pegg represented the CDFA before the California legislature, regulating bodies and interested parties on issues that had the potential to affect the Department's programs. In June 2004, Pegg joined the California Farm Bureau Federation's National Affairs and Research Division as director of international trade and plant health. She continued the Farm Bureau's strong emphasis on trade issues facing the nation's top farm exporting state and was also responsible for plant health/agricultural chemical matters and horticultural crops.

Prior to joining the Farm Bureau, Pegg worked for three years with the Agricultural Council of California where she served as director of governmental relations. In her tenure with the council, which represents agricultural cooperatives, she handled a variety of issues including labor, taxation and environmental issues before the California legislature. Prior to joining the Council, she worked on communications and business development with an Oregon firm.
Pegg is a graduate of the College of Notre Dame of Maryland.


REGARDING

DEREGULATION OF GE ALFALFA

Docket No. APHIS-2007-0044

POINT OF VIEW OF KARIN ZIRK
A DO NOT DEREGULATE POSITION HOLDER

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.


POINT OF VIEW OF GEN

http://www.genengnews.com/blog/item.aspx?id=598



What’s the most sustainable way to grow the food we eat? If you think the answer is always local and organic, you may be surprised by a new study from England’s most prestigious scientific body, the Royal Society. This highly anticipated report says there’s much we can learn from organic practices, but it embraces the use of science and technology for producing more food on less land.

Importantly, the Royal Society says that protecting the environment in the 21st century will require the adoption of sophisticated agricultural technologies including biotechnology and genetically modified crops. That’s welcome news for America’s farmers and consumers. For most of the last two decades the U.S. has been the undisputed leader in the development and adoption of biotech crops.

Ironically, as an increasing number of farmers in Europe, Asia, Africa, and South America take up these innovative varieties, burdensome regulations here at home have raised development and approval costs and kept many potentially important products from reaching the market.

Opponents have even turned to courts to slow down the introduction of new varieties. Two years ago a group of activists and farmers sued the U.S. Department of Agriculture, claiming the department’s scientists didn’t follow, to the letter, a law called the National Environmental Policy Act (NEPA) when they approved a biotech crop called Roundup Ready alfalfa.


POINT OF VIEW
OF CENTER FOR FOOD SAFETY


http://ga3.org/campaign/alfalfaEIS/we7g5369zje6deb8?



CFS has begun analyzing the EIS and it is clear that the USDA has not taken the concerns of non-GE alfalfa farmers, organic dairies, or consumers seriously. USDA’s preliminary determination is to once again deregulate GE alfalfa without any limitations or protections for farmers or the environment. Instead USDA has completely dismissed the fact that contamination will threaten export and domestic markets and organic meat and dairy products. And, incredibly, USDA is claiming that there is no evidence that consumers care about such GE contamination of organic!
247 pages of comments can be read here


Regulatory Status of Alfalfa Genetically Engineered for Tolerance to the Herbicide Glyphosate

Docket ID: APHIS-2007-0044

Agency: APHIS

Hide Info about this Docket
Title
Regulatory Status of Alfalfa Genetically Engineered for Tolerance to the Herbicide Glyphosate
Type
Nonrulemaking
Category
Genetically Modified Organisms and Products
Program
Biotechnology Regulatory Services


247 PAGES OF COMMENTS
CAN BE READ HERE

http://www.regulations.gov/search/Regs/home.html#docketDetail?R=APHIS-2007-0044


Comments on Department of Agriculture, APHIS
Docket No. APHIS-2007-0044-0003

The review of Glyphosate tolerant alfalfa will examine many aspects relative to the current concerns and the pending EIS. However, the question relative to seed production of this product can be boiled down to the concept of monitoring the seed you produce and do not ship any seed to a market that does not want it or will find fault with it. Further, we must balance the economics against the need for sufficient segregation. The question facing the industry is how can this be done? The seed industry is currently involved in stewardship programs to monitor seed production that have proven to be very effective at meeting goals for genetic purity of the seed crop.

Currently, the alfalfa seed industry had chosen to produce seed in several production areas in order to find adequate isolation.

Any attempt at regulation needs to consider several areas, Education, Communication, Cooperation, Compromise and Respect for opposing viewpoints.


Education – The seed industry needs to continue to produce science based programs that educate seed growers and hay growers in the best management practices to achieve the goal. This is the stewardship side of the equation and is already in place. Non-GMO producers need to adopt stewardship programs also. Use of the seed certification system and third party audits will allow for better communication and education.

Current research needs to be implemented into standards such as has been done in some state seed certification programs. The industry could also benefit from working with the new AOSCA plan for expanded services.

Seed production schemes are well run and due to buyer seller arrangements in the trade seed production can be monitored to fit the market you intend to sell into.

Communication - Notification of planting and location of fields has always been a “secret.” However, ask any grower who has GMO alfalfa and they will give you directions to the fields. Better disclosure of field location may assist in production of crops to meet export demand. Also, timely sharing of planting plans and experiences will facilitate the process.

The small number of production companies makes for effective communication in the seed industry.

Cooperation – Pinning protocols are in place to monitor GMO corn and alfalfa and these plans are quite effective in the cooperative effort to produce GMO and non-GMO crops.



The major question facing the alfalfa industry regarding seed export is, “Will a threshold for LLP of GMO ever be established and agreed to by all parties concerned?”

Working with seed certification agencies will allow better cooperation between conditioners and growers. This is an area that organic growers need to be aware of. Utilizing seed certification for organic seed production can help. This will assist in planting decisions.

Cooperative efforts need to extend to other countries that produce seed that is imported into the US for conditioning and then exported. (Australia)

Allowing for farmers to choose the type of production they will have is also an important part of cooperation.

Compromise - It may be time for the non-GMO portion of the industry to develop their own set of best management practices as the GMO sector has done.

Recently the industry agreed, within the confines of seed certification, that the current isolation standards were not sufficient to reach desired levels of genetic purity. The compromise position was to develop boiler plate language to allow a seed company to request added services to produce a product that was to meet a higher purity standard. This has always been an option in seed cert. but is now formalized.

The realistic approach in seed production is to realize that zero is not attainable. This is the area of compromise. Sophisticated tests are in place and are being utilized. Buyers can attain the product they want and can avoid those they do not want.


Respect for opposing viewpoints – This will be a key to being able to sit down with the entire industry in order to achieve the points listed above.

The industry can avoid the use of GMO in areas of production where the product ends up in a sensitive market. This is a management practice and not a regulatory problem.

Parting Questions: If GMO had world wide acceptance and all growers had access to GMO contracts what would be the level of concern in the industry? Therefore, the major focus for the industry may be market acceptance. A goal they have not been able to achieve yet but will come with time and work in the areas mentioned above.


Greg Lowry, Executive Vice President
Idaho Crop Improvement Association, Inc.
55 SW Fifth Ave, Suite 150
Meridian, Idaho 83642


 

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