Comments on
“Enhancing Agricultural Coexistence”
submitted to the
USDA Advisory Committee
on
st
Biotechnology and 21 Century Agriculture (AC21)
by Nick Maravell
Nick’s Organic Farm, Potomac MD
March 4, 2014
transmitted electronically to
Docket No. APHIS-2013-0047
Personal Background
I am organic farmer for the past 35 years.
I have been active in establishing organic legislation and regulations, advancing scientific
organic research, and increasing awareness of organic methods and improving organic
markets. I have worked through such organizations as the Organic Trade Association, the
Organic Farming Research Foundation, the Maryland Organic Food and Farming
Association, and Future Harvest-Chesapeake Alliance for Sustainable Agriculture.
Currently, I serve on the National Organic Standards Board, a federal advisory committee
mandated to advise the Secretary on materials and practices for organic agricultural and
food production. My comments are solely personal and represent no organization.
I own and operate Nick’s Organic Farm in Frederick County Maryland. We have 150
acres under certified organic cultivation. We are or have conducted on-farm research in
conjunction with USDA’s Beltsville Agricultural Research Center, University of
Maryland and the Maryland Department of Agriculture.
We raise grass fed Angus beef, pastured chickens and turkeys, and free range eggs,
vegetables, forages, corn, soybeans, barley, rye, and hairy vetch. Additionally, for the
last three decades we have also produced organic seed, including open pollinated corn
and food grade soybeans.
Prior Comments to the AC 21 Committee
I am particularly concerned about maintaining the purity of our farm’s organic seed and
crops and coexistence with neighboring GMO crops. I presented written and verbal
comments to this committee on March 7 and August 25, 2012.
I reiterate that I do not feel that organic farmers should bear the total responsibility, as is
now the case, for maintaining the purity of their products from surrounding GMO
production. Coexistence is a shared responsibility.
Context for My Comments
I do not support any coexistence policies that charge non-GMO growers insurance
premiums to compensate for rejection of their products because of un-intended GMO
content. As I stated in previous testimony, compensation is not the relief that I seek. I
am seeking true coexistence that avoids or minimizes any need for compensation. My
understanding is that the Committee is now seeking information on how to best achieve
this coexistence, and it is toward that end that I am commenting. I also address some
issues of pesticide drift.
My comments are organized around issues rather than the questions in the Federal
Register notice.
Serious Exploration of Voluntary GMO Free Zones
I believe there probably are many ways to create voluntary GMO free zones. I will
discuss just one approach that could be applied particularly to non-GMO seed production
and other high value crops. A thoughtful study could produce much valuable information
on a variety of approaches .
By chance, I farmed for over three decades on a 20 acre de facto GMO free zone. The
publicly owned land is located in suburbia only 15 miles from the White House. It is
miles away from any conventional commercial grain farms. Among other organic seed
crops, I was able to raise certified organic open pollinated seed corn and food grade
soybean seed. (This land is no longer leased for agricultural purposes.)
What are the elements of this “model” that could inform coexistence policy? The
following questions could lead to an exploration of this and other models. These
questions emphasize isolation distance as a key factor in coexistence, which is especially
important for open pollinated corn, alfalfa and canola, but less essential for other nonGMO crops.
What state and local governments already have geographical information systems (GIS)
to identify where private open space and/or public land is located on the urban fringes
and not likely to be in conflict with GMO crop production? Do these states and
municipalities that have specific land use policies regarding agriculture on the urban
edges that lend themselves to non-GMO production? Is there any GIS information on the
location of GMO crops? How would various isolation distances affect the possible
choices of and amount of non-GMO free zones?
What factors affect the minimum economically feasible size of the land necessary to
support viable non-GMO seed and high value crop production? Can seed production be
integrated into other high value production methods, such as season extension
(greenhouse/hoop house), aquaculture and hydroponics? How can smaller urban fringe
producers fit into the non-GMO markets? (Much of this economic work may already be
done.)
How would the policy of voluntary GMO free zones be constructed? What has been the
experience of the non-GMO zones that have been created both domestically and
internationally? Assuming contractual agreements are made, how would participants
enter into and leave from a voluntary GMO free zone, and how does this affect the zone?
How could the USDA best show leadership, in conjunction with other Federal, state and
local agencies, universities, private companies and individuals and not-for-profit
organizations, to provide market and policy incentives for the creation of GMO free
zones? Is this task within the scope and resources of the current AC 21 committee? How
could interested stakeholders best organize themselves into a group that could make
recommendations? Would commissioning a study from the National Academy of
Sciences (NAS) be a viable approach? (Any NAS or other study would need initial
support from Congressional, Executive Branch, and state and local policy makers, as well
as established GMO and non-GMO agricultural interests.)
Many Barriers to Coexistence with GMO Production
Limitations of Land Patterns, Isolation Distances, and Other Avoidance Practices
Land patterns--Our 165 acre farm is on the East Coast. There are many farm parcels this
size and smaller in our area. We grow open pollinated and hybrid grain corn and
soybeans, and open pollinated corn seed stock and food grade soybean seed stock. GMO
crops, including corn and soybeans, surround our farm.
Our farm is roughly a square configuration, with sides of 2700 feet. Standing dead center
on our farm we can never be more than 1350 feet from our borders. Under these
circumstances, for open pollinated crops, isolation distance alone ceases to be an
effective control measure for open pollinated seed corn production.
Varying Maturity and Planting Dates--Planting maturities timed to pollinate outside the
prevailing window of the surrounding crops, while helpful, is not always a failsafe
measure. We have no control over the vagaries of weather affecting planting or
pollination, or our neighbor’s decisions of when to plant or to re-plant when faced with
adverse conditions.
In addition, because we plant open pollinated seed varieties, our pollination “window” is
not as uniform or as short as with a hybrid corn variety. This factor makes delayed
planting less of a certain avoidance measure.
Barriers and Buffers--We also employ barrier crops, such as tall sorghum, to shield our
corn from foreign pollen. Depending on field specific conditions, we also do not harvest
the outside four to eight rows of corn for seed. In addition, we have grassed, forested or
paved buffers around our entire farm to comply with organic regulations. While these
crop barriers and buffers are helpful, they provide virtually no protection against
undesired insect borne pollination into crops such as corn and alfalfa.
Adverse Financial Impact
Our avoidance practices represent lost opportunity costs. For example, any corn not
harvested as seed as a sacrifice barrier, or any corn rejected as seed, represents a
reduction in value. That reduction in value can make the non-seed corn worth between
one tenth to one fortieth of the value of seed corn when compared to the value of organic
feed grain. (Note: Open pollinated food corn varieties are lower yielding than our organic
field corn hybrids and that lower yield affects the price of the seed.)
Our un-harvested buffer zones and lower value barrier crops, our delayed planting dates
which reduce our yield potential, and our sacrificed outside rows of corn are estimated to
cost in an average year $20-40,000 in “forfeited” income for both grain and seed
production. Because our land is rotated through small grains, hay, and pastures, we have
only 20% in row crops each year. If we were to increase our row crops or only grow seed
corn and seed soybeans, our forfeited income would be considerably higher.
To date we have not had any of our seed or grain rejected due to the unintended presence
of GMOs. Our seed customers require “no detectable level” of GMO in a seed sample of
at least 3,000 seed, and sometimes 10,000 seed. Currently we send samples to our seed
customers, and they have the GMO testing done at their expense. So the cost of testing
several lots of seed are not in the above estimates of forfeited income.
Lack of Labeling for Agricultural Inputs
Non-GMO farmers need to know if their agricultural inputs contain GMO content. Seed,
vaccines, inoculants, hormones, biologics, antibiotics, enzymes, etc. should be labeled as
either free of GMO content or, alternatively, as containing GMO content. One way or the
other, this labeling of agricultural inputs seems a common sense approach to helping all
to maintain coexistence.
Unfortunately, the average farmer cannot tell by current labeling which products contain
GMOs. My understanding is that GMOs are registered with various Federal agencies,
many are registered within APHIS, and so this information is know and could be required
to appear on product labels.
Lack of Knowledge Base to Achieve Coexistence
Lack of Knowledge of the Degree/Extent to Which Unintended GMO Presence
Exists in non-GMO Seed Stock and Foundation Seed
To the extent that foundation and breeding seed stock are not free of GMO content, then
there is a baseline to improve upon in achieving coexistence. To the extent that nonGMO foundation and breeding seed are free of GMO content, then some common sense
strategies for ensuring and safeguarding the continued purity of the seed should be
implemented. USDA should collect baseline data on the current state of the commercial
and research seed supply, including the USDA germplasm collections, in order to guide
realistic policy and to periodically evaluate progress on achieving coexistence. USDA
should work with the National Genetic Resources Advisory Council monitor the purity
and adequacy of our nation’s seed supply.
Lack of Knowledge About Strategies/Technologies to Achieve Coexistence in
Seed Production
GA1s Gametophytic Incompatibility—Breeding corn to include the GA1s gametophytic
incompatibility gene holds some promise, has some drawbacks, and is not failsafe. This
genetic trait favors self-pollination and tends to “reject” pollen from “foreign” corn
varieties.
Supporting more research into this area could inform seed producers as to how this
breeding technique, which has been used for decades in popcorn production, might be
useful in helping to achieve coexistence in corn production.
Breeding technologies most likely to achieve coexistence––Can hybrid breeding
techniques or other established technologies help maintain seed purity, especially with
open pollinated crops such as corn? What is the added cost of such techniques?
Lack of Knowledge of How to Breed GMO Out of non-GMO Foundation Seed
Theoretically, it is to breed GMO genetic material out of a variety. Under USDA
leadership, and with the cooperation of the biotechnology industry and the non-GMO
seed and crop industry, research should be conducted to demonstrate how this breeding
process could be done practically and, hopefully, affordably. Such research might also
discover what technology or testing would make this endeavor most practical and
economically viable. Being able to reverse unintended GMO presence in the seed supply
would greatly relieve some of the tension surrounding the coexistence issue.
Pesticides and Coexistence
The use of GMO crop technology is closely tied to the use of pesticides, and these
pesticides are having unintended impacts on the environment and on organic crops. In
addition, the use of pesticides seems to be increasing despite the promise of GMO
technology to reduce overall pesticide use.
Unfortunately, these pesticides are no longer controlling weeds and pests. If GMO seeds
linked to pesticides were a “silver bullet,” we would all know it by now.
The blanket use of pesticides matched to GMO crop seed for weed control has produced
the expected result of “superweeds” that are resistant to chemical pesticides. Mare’s tail,
the first weed resistant to Roundup (glyphosate), developed it defense in nature only four
years after Roundup Ready soybeans were released. Which not only proves again that it
does not take biotechnology to develop the trait, but that certain undesirable outcomes of
current GMO technology are foreseeable. Now approximately 24 weeds have developed
resistance to Roundup.
USDA approvals are pending to link GMO seeds to the herbicide 2,4-D. In the near
future, we can expect other chemical pesticides such as dicamba and atrazine will also be
linked to GMO crop seeds. New formulations encompassing various combinations of
Roundup, dicamba, 2,4-D, and atrazine are already on the market, despite the fact that
there is little information about the effects of the interactions of these chemical
components on the environment or human health. All of these developments will most
likely lead to ever increasing loading of pesticides on the environment.
In addition, pest resistance to Bt has occurred since the introduction of GMO crops
containing the Bt gene. This resistance can lessened the effectiveness of Bt formulations
sometimes used by organic farmers for pest control, thereby rendering useless a once
judiciously used tool.
The environment impacts of glyphosate, 2,4-D, dicamba, and atrazine are documented
and, to some extent, disputed. But with the passage of time the scientific evidence is
mounting that serious undesired consequence to the environment and human health have
occurred. Most recently, atrazine has been implicated in producing ill effects in wildlife
and humans. In addition, the potential of drift damage from 2,4-D are well known.
Neonicotinoids, which are not now linked to GMO technology, have raised serious
concerns about adverse impact on our bee populations—necessary pollinator of many
crops.
To achieve meaningful coexistence, both USDA and EPA must change their
environmental and health evaluation procedures to at least accommodate what we have
already learned, if not to accommodate what we can reasonably expect.