East End Food Cooperative 7516 Meade Street Pittsburgh, PA 15208 www.eastendfood.coop www www Comments on Agricultural Coexistence I am writing on behalf of the East End Food Co-op, a natural and organic member-owned grocery store located in Pittsburgh, PA. We serve over 10,700 member-owners, and countless other non-member customers as well. I’d like to share our concerns about the dialogue taking place around the possibility for “coexistence” of GMO and non-GMO/organic farms. I will start by indicating that we stand with the National Organic Coalition, who argues that talking about coexistence without first committing to contamination prevention is perpetuating GMO contamination. This concerns our Co-op for a number of reasons. We are committed to carrying the cleanest, purest foods available. This is the primary reason we exist, the function we serve for our member-owners, and the reason that many shoppers will deliberately choose to walk in our door instead of a chain retailer or discount grocer. We are also committed to strengthening our local economy by working with as many suppliers in our region as possible. This doesn’t just mean we buy from local distributors, but rather we work directly with farmers and vendors to assure healthy, mutually beneficial relationships. We truly believe we’re all stronger together. We believe this posited notion for coexistence threatens both of these important cornerstones of our operation. Non-GMO/organics farmers are not the majority in Pennsylvania, yet they are our preferred suppliers. In the instance one of our farmers falls victim to contamination, we can’t continue to carry their goods while assuring our shoppers that we’re committed to carrying food on our shelves that is clean and free of genetic modification. That leaves us in a difficult position: we have to determine whether to no longer purchase from the contaminated farmer in order to meet the needs of our customers, or to continue working with that farmer while paying a lesser conventional rate in good faith that they’re still avoiding pesticide use and using other natural practices and will restore non-GMO/organic status as soon as they’re able. Neither solution is a happy one and both outcomes demonstrate the serious flaws in the assumption that non-GMO/organic farmers acquiring crop insurance will see their needs met in the instance of contamination. Perhaps it will help them through the first contaminated crop, but if natural food retailers who are looking to maintain stable supply lines begin to re-evaluate them as a reliable provider of non-GMO/organic foods, there’s no doubt it would have a negative impact on their business. In addition, contamination creates a fear in producers, retailers, and consumers alike that there may come a day when no crop from any well- intentioned farm can be assumed or guaranteed non-GMO, which is a scary prospect from every perspective. I’ll add that placing the onus of insurance on the non-GMO/organic farmer is profoundly backwards. If they don’t want this GMO crop in their field and have performed due diligence to prevent its presence and it arrives nonetheless, how is it that they’re the ones burdened with insuring themselves against such a trespass? Non-GMO/organic farmers face enough overhead with the certification process and more, that to pass this buck onto them puts further financial strain on the entire non-GMO industry of food production. Inevitably these costs will be passed on to consumers whose simple desire is to eat clean, healthy foods. It would make considerable more sense to instead place the responsibility for the prevention of contamination against the parties that would provide said contamination. That is to say, make the farmer using genetically modified seed lose acres of land to maintain buffer zones so their pollen drift and pesticide usage (hopefully) doesn’t reach non-GMO/organic fields. Even more judiciously, place the burden of compensation on the ever-profiting patent-holders who should be held responsible for segregation and traceability. Furthermore, we would argue that both parties should be charged with doing so under the watchful eye of the USDA, the organization put in place specifically to develop and execute federal government policy on farming and agriculture. There also needs to be some inherent compensation for instances when non-GMO crops do become contaminated to guarantee these farmers continued profitability. One area in which the East End Food Co-op member-owners and customers certainly agree with the USDA is that there is need for more education on topics related to prevention of crosscontamination, and we commend the USDA for their interest in this pursuit. The Co-op is fullheartedly in support of sharing education, information, and training, in fact it’s one of the Seven Principles shared by most cooperative organizations. However, education alone is not capable of contamination prevention and therefore is not a sufficient goal to pursue in this matter. The East End Food Co-op would like to confirm an interest in the resolutions that the National Organic Coalition are calling for: USDA-developed mandatory rules to prevent GMO contamination, because the voluntary solutions arising in their absence have proven insufficient. Full transparency throughout the supply chain is a must, which requires a standard labeling system for genetically engineered foods. Though we’d support a ban of all GMOs in our country, in particular, crops prone to drift and cross-pollination should not be approved for GMO production, including alfalfa, sugar beets, canola, and corn. More research should be conducted to ensure a non-GMO seed supply remains in case of the event of widespread contamination. More research should also be performed to closely study the impacts of genetically engineered products, and to monitor the contamination levels in the seed supply. Crop insurance should not be treated as a compensation mechanism in instances of contamination. The ability for farmers to continue planting GMOs should not ever preclude the growing or non-GMO/organic crops. To quote from the February 13th Write to Farm blog post by Bryan Snyder, Executive Director of the Pennsylvania Association for Sustainable Agriculture, On the face of it, the idea of “co-existence” is difficult to argue with…something we all would likely endorse with respect to disputes of all kinds, from the local to international levels. But in this case it’s a bit more ominous an idea, since the two sides are not equal in terms of the threat one poses to the other. We here at the Co-op couldn’t agree more, and feel that overlooking contamination prevention in favor of exploring methods for coexistence provides a grave threat to farmers, retailers, and consumers alike. In Cooperation, Heather Hackett Marketing & Member Services Manager