CAFA’s Board of Directors will soon meet to chart a course for 2010 and it already looks like it will be a busy year. Two issues surfaced in mid-December that already needed attention; an SOS to respond to pending restrictions for several insecticides, and the long-awaited, environmental impact statement (EIS) for Roundup Ready alfalfa. The draft EIS is still in the comment phase and there’s time to get involved.

When the USDA Animal Plant Health Inspection Service (APHIS) deregulated RR alfalfa without an EIS, it opened the door for a successful lawsuit in 2007 that halted planting. The draft EIS was originally slated for public comment the beginning of this year. Then in August it appeared the draft would finally be available for public comment in mid-September, and it was the topic for this column at that time.

You can make your voice heard during the comment period, which began Dec. 18, and will be open for 60 days.

A lot is at stake since environmentalists stated early on that they are determined to block deregulation once again. Alfalfa producers deserve the option to take advantage of the biotechnology that has greatly benefited corn, soybeans, cotton and other crops.

CAFA’s stance on the issue centers around two key subjects that are based on extensive research. During the past three years the gene flow issue has been scrutinized and it’s documented that methods are available to prevent significant contamination of organic or conventional alfalfa.

Information on the subject is posted on the National Alfalfa & Forage Alliance (NAFA) Web site (www.alfalfa.org) and includes a discussion on how to prevent gene flow for seed grown for markets sensitive to GE crops. The NAFA Web site also has coexistence documents on alfalfa at, http://www.alfalfa.org/biotechnology.html. UC Davis has a paper on how to prevent gene flow and enable coexistence. It’s available at: http://ucanr.org/freepubs/docs/8193.pdf.

The bottom line is there’s a lot of ammunition to support deregulation based on the work done on the gene flow issue. The other subjects that can be defended are weed resistance or weed shift concerns due to glyphosate use in RR alfalfa fields. Both conventional and GE crops are subject to resistance or weed shifts, but university scientists and growers have demonstrated that the problem can be avoided by rotating herbicides.

To view the draft EIS, visit the APHIS Web site. A fact sheet about RR alfalfa and the draft EIS process is also available on the site; http://www.aphis.usda.gov/newsroom/content/2009/12/alfalfa.shtml. To comment on the draft EIS for RR alfalfa, log onto: http://www.regulations.gov/search/Regs/home.html#docketDetail?R=APHIS-2007-0044.

Earlier we mentioned the SOS request to respond to a situation that could seriously impact usage of chlorypyrifos, plus malathion and diazinon over large areas of California, Washington, Oregon and Idaho. It stemmed from a National Marine Fisheries Service Biological Opinion (BiOp) on the insecticides and salmon. The BiOp prompted the EPA to make a precedent-setting decision to impose restrictions that will essentially prohibit their use over large areas.

The pending EPA restrictions were made without stakeholder input or a clear definition of waters that should be protected for actual salmon habitat. Restrictions were applied to areas miles from salmon habitat. Neither scientific nor federally-mandated analysis of the economic impact was considered. The plan involves expansion of no-use buffer zones to every ditch, drain, canal, and irrigation furrow that might eventually drain into a salmon habitat.

A BiOp was the trigger that choked off water deliveries to the San Joaquin Valley and it won’t be a surprise if we see more of the same in 2010.