In its draft Environmental Impact Statement (EIS), issued on December 18, the U.S. Department of Agriculture (USDA) claims that there is no evidence that consumers care about genetically modified (GM) alfalfa.

Furthermore, USDA has completely dismissed the fact that GM contamination will threaten farmers domestic and export markets and organic dairy and meat products. USDA’s preliminary determination is to once again deregulate GM alfalfa without any limitations or protections for farmers, consumers or the environment.

It is time to tell USDA that it is wrong—farmers, ranchers and consumers do care about contamination of their crops, feedstuffs and food that is inevitable if USDA allows GM alfalfa to be grown in the United States.

What you can do
Send comments to USDA today.

Tell USDA You Will Reject GM Contaminated Alfalfa and Alfalfa-Derived Foods

USDA claims that consumers will not reject GM contamination of organic alfalfa if the contamination is unintentional or if the GM material is not transmitted to the end milk or meat product. Tell USDA that when you buy organic milk, you want to know it comes from cows that did not eat any GM alfalfa, does not contain any BGH, and was not exposed to any other genetically modified organism.

Tell USDA to Protect All Farmers Who Wish to Choose to Grow Non-GM Crops

Although USDA says it supports “coexistence” of all types of agriculture, the agency refuses to consider any future for alfalfa that would include protections from contamination for organic and conventional farmers and exporters.

Tell USDA That Protecting Farmers is Its Job and that Relying Solely on Monsanto’s Business as Usual “Best Practices” Ensures Widespread GM Contamination

USDA claims that Monsanto’s seed contracts require measures sufficient to prevent contamination, and that there is no evidence to the contrary. In the lawsuit requiring the EIS, the Court found that GM contamination had already occurred in the fields of several Western states with these same business-as-usual practices in place! The EIS itself acknowledges that GM contamination may happen. In general, where other GM crops were approved without restriction, contamination of organic and conventional seeds and crops is widespread and has been documented around the world.

Tell USDA That GM Alfalfa Would Significantly Increase Pesticide Use and Thereby Harm Human Health and the Environment

USDA admits, correctly, that introduction of Roundup Ready alfalfa will increase Roundup use. However, USDA’s claims that the increase is not significant and that Roundup will replace other, more toxic herbicides are flat-out wrong. The agency’s own studies acknowledge the great majority of alfalfa is currently grown without the use of any herbicides at all.

Roundup Ready alfalfa will increase Roundup use and exacerbate the resistant weed epidemic without displacing other herbicides on most alfalfa farms. Furthermore, the great majority of GM crops grown today are Roundup Ready, and its widespread introduction has vastly increased Roundup use. To kill Roundup-resistant weeds requires higher doses of Roundup, often in combination with other toxic herbicides. Over the past 13 years, Roundup Ready crops have significantly increased overall herbicide use on corn, soybeans and cotton - by 383 million pounds - and Roundup Ready alfalfa will only make matters worse.

Tell USDA That Harm to Small and Organic Farmers is Significant

USDA concludes that GM alfalfa will cause production to shift to larger farms that can afford built-in isolation distances and conventional growers who are not threatened by contamination, but that these economic shifts are not significant. Small, family farmers are the backbone and future of American agriculture and must be protected. Organic agriculture 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 GM contamination and subsequent environmental, consumer, and economic losses.

Tell USDA to Extend the Comment Period

USDA provided only a 60-day comment period for a 200-page document released over the holiday season. Then, USDA extended the deadline 15 days. Ask USDA to extend the comment period by 30 days.

How to Comment - Due March 3, 2010

To send written comments, mail two copies to

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

Please state that your comment refers to Docket No. APHIS-2007-0044.

Comments can also be filed online at USDA's website.

Sample Comments

You can use the sample consumer and grower comments to write your comments. You can also print the sample comment, sign it, and mail two copies of it to USDA by March 3.

• Sample consumer comments (WORD document)
• Sample grower comments (WORD document)

Consumer talking points from the Center for Food Safety

Grower talking points from the Center for Food Safety

Background

In 2006, WORC joined the Center for Food Safety (CFS) in suing the USDA for its illegal approval of Monsanto’s genetically modified Roundup Ready alfalfa. USDA failed to conduct an EIS before deregulating the crop. An EIS is a rigorous analysis of the potential significant impacts of a federal decision. The federal courts banned GM alfalfa until the USDA fully analyzed the impacts of the GM plant on the environment, farmers, and the public in an EIS.

According to the Animal Plant and Health Inspection Service (APHIS), which conducted the study, the draft evaluates the potential environmental effects of GM alfalfa to tolerate the herbicide glyphosate, known commercially as Roundup. GM alfalfa is commonly referred to as Roundup Ready (RR) alfalfa and is referred to as glyphosate-tolerant (GT) alfalfa in the EIS.

WORC and other groups representing conventional and organic alfalfa growers, dairy farmers, and consumers believe the draft EIS is grossly inadequate, and fails to take the hard look ordered by the courts at the affects of releasing Roundup Ready alfalfa.

Resources

• 10 Things You Should Know About Roundup Ready Alfalfa
• Center for Food Safety
• Glyphosate-Tolerant Alfalfa Events J101 and J163: Request for Nonregulated Status, Draft Environmental Impact Statement
• Impacts of Genetically Engineered Crops on Pesticide Use in the United States: The First Thirteen Years