Six farm groups wrote the director of the White House Office of Science and Technology last week to express their deep concerns about how USDA's process to deregulate Roundup Ready alfalfa could threatened to undermine the U.S. government's science-based regulatory system.
The letter emphasized that proposed restrictions for just one crop could negatively impact all producers of biotech crops for decades to come, and that non-scientific biotechnology regulations should not be created as part of USDA's environmental review process.
USDA's authority to regulate and deregulate biotechnology-derived crops comes from the Plant Protection Act (PPA), which requires the Secretary to base regulatory decisions on sound science.
The review in question is known as an Environmental Impact Statement (EIS), which USDA was compelled to conduct as part of an ongoing lawsuit concerning its original deregulation of the alfalfa in 2005 based on a separate environmental review.
The Department issued the EIS, which took 47 months to complete, in late December. At that time, USDA said it preferred to either deregulate the crop completely or deregulate it with unprecedented restrictions, which could include isolation distances, geographic planting restrictions, limitations on harvest periods and equipment usage, seed bag labeling, seed coloration and the listing of seed production field locations on a national database.
The EIS is now available for public review, and a decision on the path forward could be announced as early as the end of this month.
The EIS for GM alfalfa includes a conclusion from USDA's Animal and Plant Health Inspection Service (APHIS) that it does not pose a plant pest risk.
The groups writing argued that without that risk, it is inconsistent for USDA to impose conditions on this crop and doing so would, in fact, undermine the U.S. government's science-based regulatory process.
The groups told the White House that these conditions, combined with broader policy statements in the EIS, would set a dangerous precedent for the continued safe development, availability and marketability of new varieties of crops utilizing the latest technology.
They also described the effects such conditions would have on the integrity of American trade agreements, which have long been negotiated and litigated based on the science-based philosophy of the U.S. regulatory system.
"Our organizations will continue to engage with USDA in a comprehensive discussion of 'coexistence' policy, but new and precedent-setting agricultural biotechnology policy, that impacts all American agriculture, should not be included as part of a specific product deregulation," they said.
The alfalfa industry has worked extensively with USDA, grower groups, academics and state seed certifying officials to implement voluntary stewardship measures that will allow conventional, organic and biotech alfalfa growers to manage their multiple cropping systems. Most major agriculture groups believe this process should be allowed to continue without interference.
There is no commercialized biotech wheat anywhere in the world, but the wheat industry works on biotechnology issues because its leaders believe biotechnology's introduction into the wheat crop is necessary to increase productivity, attract acres back to the crop and feed a growing global population sustainably.
NAWG staff continues to work with coalition partners to impress upon USDA and other parts of the Obama Administration the importance of appropriate access to technology and modern production practices.
A copy of the full EIS is available at http://www.aphis.usda.gov/biotechnology/downloads/alfalfa/gt_alfalfa%20_feis.pdf.
The agriculture coalition letter sent to the White House is at www.wheatworld.org/biotech.