Comment period on Roundup Ready alfalfa begins December 18

This is a guest blog by Dan Putnum
Forage Extension Agronomist and Agricultural Program Leader
Department of Plant Sciences, the University of California

The long-awaited decision on the deregulation of glyphosate-tolerant (GT) alfalfa (Roundup Ready or RR alfalfa) has been made.USDA-APHIS, which regulates biotechnology traits, has completed a Draft Environmental impact Statement (EIS) and posted this on its website. This was required by a legal decision in March of 2007 due to a lawsuit brought by Center for Food Safety.

Their decision:
“ APHIS has made a preliminary determination that action should be taken, and that action will be to grant nonregulated status to GT alfalfa lines J101 and J163, in whole. The introduction of these GT alfalfa lines has no significant impact on the environment. These GT alfalfa plants, lines J101 and J163, are not plant pests and are unlikely to pose plant pest risks.”

It is time for you to weigh in and provide comments to APHIS on their preliminary decision – should they be supported in this decision to allow commercialization of this trait (nonregulation), or should it continue to be regulated (not allow commercialization)? Have they addressed the important issues associated with this technology?

There are a range of issues associated with this, but primarily it comes down to:
• The claim that this trait causes excessive gene-flow to organic or conventional alfalfa fields which will prevent organic or conventional growers from farming as they wish and lead to eventual contamination of all alfalfa fields.
• The claim that the introduction of this trait causes much larger development of Roundup-resistant weeds which will have an impact on the environment.

These were the two most critical issues in the lawsuit and the important issues that APHIS needed to address, along with market impacts.

Those who disagree with these claims argue that:
• Gene flow is primarily an issue with seed production (<1% of the acreage), and can be (and is) managed with isolation requirements in seed production. In hay crops, gene flow is largely prevented, since hay is mostly harvested before significant bloom. Techniques such as managing feral alfalfa and testing products using a simple test strip can assure customers of the non-GE status of hay or seed.
• Weed resistance to herbicides is an old problem with agriculture and not unique to RR alfalfa and can be managed through diverse weed management strategies that have been developed over many years by weed scientists. If it occurs, it will primarily have an impact on the effectiveness of Roundup, not the environment.

UC (University of California) and other universities have detailed publications on both of these issues, on gene flow and on weed resistance; see link below.

APHIS has extensive documentation of their study of these issues, plus related market issues in the EIS statement. Please see their website below. The EIS alone is 1,476 pages long, with documentation, but the critical issues can be easily found.

We should keep in mind that this decision will impact the use of all genetically engineered crops in general, for alfalfa in the future (not just RR alfalfa), and perhaps for other crops, as well.

Time to make your voice heard.

You may review the APHIS documents by starting here:
http://www.aphis.usda.gov/biotechnology/alfalfa.shtml

Several University of California Documents related to biotechnology, coexistence of alfalfa types, and weed resistance can be seen at:
http://alfalfa.ucdavis.edu/+producing/index.aspx?cat=Biotechnology%20and%20Roundup%20Ready%20Alfalfa

The National Alfalfa & Forage Alliance documents on coexistence and seed stewardship, which came out of workshops over the past three years are at: http://www.alfalfa.org/CSCoexistenceDocs.html

To SUBMIT COMMENTS TO USDA-APHIS, SEE
http://www.regulations.gov/search/Regs/home.html#submitComment?R=0900006480a6b7a1

To see a longer listing of previous comments (2008), which includes the recent entries, see:
http://www.regulations.gov/search/Regs/home.html#docketDetail?R=APHIS-2007-0044