WORC's Guide to Genetically Modified Alfalfa

Home , Center for Food Safety, Cleaning (forestry), Dow AgroSciences, Roundup Ready, Syngenta

A Guide to Genetically Modified Alfalfa

Western Organization of Resource Councils WORC WORC, the Western Organization of Resource Councils, is a regional network Contents of seven grassroots community organizations that include 9,500 members and 45 local chapters. WORC helps its member groups succeed by providing 5 Queen of Forages training and coordinating regional issue campaigns. 8 Problems with GM Alfalfa 11 Ten Things You Should Know About Roundup Ready Alfalfa WORC’s mission is to advance the vision of a democratic, sustainable, and just society through community action. WORC is committed to building 14 Jim Munsch - Coon Valley, Wisconsin sustainable environmental and economic communities that balance economic 16 The Case Against Roundup Ready Alfalfa: Geertson Seed Farms v. growth with the health of people and stewardship of their land, water, and air Johanns resources. 31 Blaine Schmaltz - Rugby, North Dakota WORC’s member groups are: Dakota Resource Council (North Dakota), 33 Glyphosate-Resistant Weeds Dakota Rural Action (South Dakota), Idaho Rural Council, Northern Plains 38 Contamination by GM Crops Resource Council (Montana), Oregon Rural Action, Powder River Basin 46 Genetic Contamination Across the United States Resource Council (Wyoming), and Western Colorado Congress. 48 Phillip Geertson - Adrian, Oregon 50 Roundup Ready Alfalfa: Is Conventional & Organic Alfalfa at Risk? 57 Eckenberg Farms - Mattawa, Washington 59 Five Things a Farmer Can Do about the Risks of Roundup Ready The Guide Alfalfa A Guide to Genetically Modified Alfalfa was written and compiled by Kristina 60 Five Things a Consumer Can Do about the Risks of Roundup Hubbard, Research Fellow, Western Organization of Resource Councils. Ready Alfalfa 61 Kathy Cox, Bloomfield Bees Honey - Sebastopol, California We appreciate the finanicial support of the John Merck Fund, Patagonia, the CornerStone Campaign, the Sierra Club and FarmAid, which made this 62 What if My Neighbor Planted Roundup Ready Alfalfa? research and publication possible. 64 Understanding Monsanto’s Technology Use Guide 66 Monsanto’s Technology Use Guide & Roundup Ready Alfalfa An online version of this guide is available for download at www.worc.org. 68 What’s next in the pipeline? Copyright 2008 70 Roundup Ready Sugar Beets to Debut in 2008 Western Organization of Resource Councils 71 George Siemon Organic Valley - LaFarge, Wisconsin 220 South 27th Street, Suite B 74 Reports Billings, Montana 59101 www.worc.org 79 Endnotes Introduction Photo Courtesy Agricultural Research Service, Courtesy Agricultural Research Photo USDA It is the fourth most widely fourth most is the It 1 grown behind crop corn, soybeans, and wheat, and But a new agriculture. valuable most to third the genetically modified (GM) alfalfa variety poses unique agricultural, environmental, and economic alfalfa with the varieties exist risks–risks didn’t that decades. grownfarmers for have announced Department its of Roundup approval (USDA) of Agriculture U.S. 2005, the In June Ready (RR) alfalfa. This variety is herbicide-tolerant, meaninggenetically it is engineeredto trademark survive Company’s main ingredient the of glyphosate, Monsanto in applications the produced RR alfalfa Monsanto herbicide, in Roundup. partnership alfalfa largest with the seed Genetics (a subsidiary Forage International of Land O’Lakes). company, Genetic engineering traditional technology) DNA (recombinant from tremendously differs breeding breeding other mechanisms. methods, Unlike engineering genetic the at operates and molecularcellular select between it possible a single level, to and transfer gene and makes – sometimes organisms between of two species.cells unrelated engineered RR are crops to applications derived a gene a soil bacterium, plants tolerate from allows these to which express genes jellyfishand tobacco include market) the on currently (not Other examples glyphosate. of plants, and a soybeaninserted tomato in into lettuce. gene Queenof Forages for a moment.Think Can you trace alfalfa—the dot America’s you see bales crop that inforage hay rural landscape—to your Alfalfa dinner plate? food is dairyfor lambs, and beef for pigs, cows and cattle, even honeybees. see it on our So, evenif we don’t a crucialdinner it plays foodplates, inthe we eat. role American of the a staple farming diet. It’s farmers value alfalfa U.S., the as an importantAcross feed livestock, for especially dairy cows, and grow U.S. the of it across 20 million acres than more Because of its pervasiveness in our landscapes, alfalfa is an important wildlife, including for more habitat species. 130 bird than Introduction U.S. agriculture. Monsanto controls market through 90percent about oftheGMseed global reduces andranchershave the control farmers andfurther over American varieties, seed affordtechnologies transnational companies the reduces ofaffordable,availability public toIn addition control environmentalandmarket the concerns, increasing that patented seed markets producers. for organic alfalfa even eliminate or reduce profits, costs, organic production with crops could increase alfalfa RR of systems,cross-pollination and organicfarming certified in biotechnology of agricultural TheUSDA alfalfa. notallow contaminationNationalthe use risk byRR Organic does Program organic andsome markets) export (such certified as andfeed GMmaterial seeds in outright, andhay that crop, seed shun, markets for orreject alfalfa isanopen-pollinated alfalfa Because alone. California could result in morethat alfalfa the ayear in application herbicides RR of200,000pounds expensive controls. chemical The National Center for and estimatesAgriculture Food Policy more toxic andrequiring operations, theofmanyto and bane farmers’ glyphosate, becoming resistance have developed tolerant weeds crops were and2004.Asaresult, several introduced) 1996(whenherbicide- between usebymore herbicide than pounds 138million increased the in U.S. planted crops 2006,89percent (in ofsoybeans werevariety) anherbicide-tolerant any, if minimal, with alfalfa USDA herbicides. indicates that data the rapid adoptionofRR nature, andrancherscurrently very produce butmany usebyits farmers encourages herbicide isconsiderablyvarieties. differentFor alfalfa from example,RR alfalfa non-GMalfalfa “Queen ofForages.” feed source cows.most important for dairy In agriculturalvernacular, itisthe honeybees. IntheU.S., itisgrown onmore than 20millionacres andisthe cows andbeefcattle, fuelfor dairy It isanimportant for lambs, pigs, and Alfalfa isthethird mosteconomically valuablecrop to U.S. agriculture. other livestock products. honey, slabs steaks, ofbutter to ofmilk, beef and andcheese, their glasses landscape American are to left make from field the connection to platefrom – those hay bales thatrural dot the the in U.S., are from notlabeled GMfeed, derived consumers andfood GMfood, Because athreat as to alfalfa to their right Many RR affordable consumers see organic orGM-free food. to make aliving. athreat to as their ability to–even practices alfalfa their choice ofRR introduction offarming the ranchers and see Otherfarmers in operations. their RR alfalfa growing to potential benefits isonestep from removed the alfalfa plate, growers see andmany because alfalfa minimal, Monsanto by consumers that to is opposition the technology andForagebelieve Genetics alfalfa. ofRR planting further andconsumers achanceranchers, to heard before be USDA whether to approve decides to choose buy,they andthe cost farmers, organic orGM-free Anditgives ofchoosing food. on the food RR alfalfa It of more consumersoperations. to time the gives about effects learn on their RR alfalfa widespread of planting of more to time the about effects learn farmers anddairy producers, livestockcourt’s growers, andhoney hay andseed alfalfa gives decision untilanEISisprepared.The at least alfalfa, ofRR planting any further barring injunction, contaminate InMaywill apermanent conventional issued 2007,the court andorganic alfalfa. onpage 16,found that discussed USDA todecision, address failed concerns that alfalfa RR Statement. Thisprecedent-setting EnvironmentalImpact afull andperform court alfalfa RR later,year andordered favor USDA in ofplaintiffs, ruled theapproval court to its of rescind It theinlawsuitenvironment. first response was be filed to the to approval ofaGM crop. A the department’s to andarisk athreat the livelihoods approvalalfalfa to ofRR farmers’ the Westernlawsuit a ofResource against USDA,calling filed Councils, Organization including organizations, producers farm andfamily of alfalfa 2006,acoalition In February system. production food ofour over alarge segment Monsanto’s increases products andallowsamonopoly andfarmers, farms onAmerican grip companies. ofpatentsownership andacquisition ofother seed that would comewith widespread adoption. alfalfa by offering evidence and actionstepstoavoid theproblems Guide poses toU.S. farmers, ranchers, andconsumers. WORC hopesthe environmental, agricultural, andeconomicrisksRoundup Readyalfalfa A GuidetoGenetciallyModified Alfalfa will aiddiscussionsandactivities surrounding RoundupReady isatoolkitfor avoiding the

Adding alfalfa to the line of RR to Adding ofRR the line alfalfa Introduction Evidence horse breeding, sprouting, and honey industries. industries. andhoney sprouting, horse breeding, the somein naturalGM-free including beef, markets, andother export markets, andalfalfa organic alfalfa other GM-freeruin fields. Contamination could to fieldscontaminate isnearly certain organic and from (GM)DNA (RR) Roundup Ready modified crop, sogenetically isacross-pollinating Alfalfa Genetic Contamination Agricultural Risks GM Alfalfa with Problems Photo Courtesy Agricultural Research Service, USDA Service, Research Agricultural Photo Courtesy damage caused by its product. byits damage caused to Monsanto let offeconomicthe hook for any against farmer, isto pit farmer agreements and mayproduct of cause. these Theeffect contamination orany other problems its shield Monsanto from for liability accidental have to Technology sign that Agreements will seeds alfalfa whopurchase RR farmers Monsanto GMseeds, Because patents its Unfair Liability contaminationpreventing oftheir crops. to GM-freewho want be are responsible for USDA says weeds. that or surrounding farmers crops neighbors’ to with avoid cross-pollination to create seeds refuge RR plant orbuffer areas who No law requires orregulation farmers cultivars are produced.” an where area GMO alfalfa in contaminated ifgrown a non-GMO notbe will that difficult“It is tocertify — William T.W. Woodward, Washington State University

Extension costly chemicals. have alongroadsides will andwhocontrolcrops, to alfalfa resortto andmore wild less friendly at life, stand orvolunteer whoexperience the endofits glyphosatealfalfa resistance weeds in Farmers for whouseglyphosate others to alreadyexist,ismounting. andevidence kill weeds glyphosate-resistant several weeds, alfalfa onsomeimportant Not onlyisglyphosate weak Glyphosate Resistance year. a ofherbicides 200,000 pounds the application ofanadditional could resultthat alfalfa in RR Agriculture Policy estimates National Center for Food and pounds. by138million increased has crops on herbicide-tolerant use Since 1996,herbicide Increased HerbicideUse Environmental Risks Photo Courtesy Sarah Stokes Sarah Photo Courtesy 4

3 In California alone, the InCalifornia Photo Courtesy USDAPhoto Courtesy alfalfa. Assessment before approving RR Environmental organisms its in andother beneficial insects, mammals, onbirds, impacts the possible notanalyze did species. endangered fieldseach year, alfalfa including More ofbirds visit than130 species Non-Target Organisms

TheUSDA Evidence 10 Evidence miles away. more than to 2.5 alfalfa trait non-RR alfalfa the transferred RR shows bees that honey Genetics from Astudy GMcrops. acquire transgenictraits will byForageproducers fear their honey honey Some conventional with andorganic varieties. alfalfa RR cross-pollinate andcan miles, (one-third pollen production). ofannual from alfalfa and most fields, isderived seed honey U.S. alfalfa pollinatorin are animportant bees Honey Honey Washington, andOregon. California, percent the in West, isproduced including 99 exported, the Of alfalfa alfalfa. RR and export companies continue to reject these demandGM-freein countries feed, Taiwan, Mexico, andCanada. Japan, andthe to rest Korea, South isshipped percentfive of go to exports alfalfa U.S. while5percent Seventy- isexported. feed, Most domestic U.S.animal as isused alfalfa Alfalfa Hay Exports producers whoare,beef want be, andorGM-free.to farmers to find dairy for expensive orimpossible increasingly sources be will non-GMfeed other feeds, commodity as contaminated as becomes Ifalfalfa contaminationrampant ofU.S.andcanola. soybeans, corn, ofthe because that transgenictraits notcontain itdoes aguarantee with to purchase grain their cattle are producersMany unable whofeed organic non-GMfeed andnatural beef Trader including ingredients, Joe’s, Wild Foods. andWhole Oats, stores retail ofGM to food free be demand. Some products alreadyrequire namebrand to organic fill andsomeproducersfeed this to have years, import started for several grain The demand for a organic chronic alfalfa. oforganic has milkand U.S. experienced shortage As the organic markets andnatural continue dairy, to andhoney expand, beef, the sodoes Organic andNaturalFoods Markets at Risk 9 6 Customers 7 products will be coming be will products over.” saying nogenetically modified documents tosign are us asking of our“Some Japanese hay customers –Jeff Plourd ofEl El Export, Toro 8 Honey bees can transfer pollen several several transfer pollen can bees Honey Centro, California to increase and be subject to shortages. subject andbe to increase products, milkandbeef especially from alfalfa, derived the oforganic prices expect products consumers adopted, iswidely can alfalfa contamination. that Inthe event RR alfalfa from RR organic andother non-GMalfalfa to protect the need cows increases and dairy cattle The demand beef for organic feed consumer ofalfalfa. isthe leading industry dairy The years. of organic milkfor several The a chronic has U.S. experienced shortage the costoforganicmilkandbeef Roundup Readyalfalfawillincrease transferfields from RR GMtraits to own. if their oftheirand theseed genetic purity aGMtrait. contained andmore samples, than50 percent 80percent samples, ofthe andsoybean ofthe corn canola tested samples ofconventionalScientists soy, (non-GM)corn, andfound that seed and canola For example, andsoybeans. corn in the spread rampant ofGMtraits the Union ofConcerned Currently, of have optionsbecause limited non-GMgrain producers to whowish feed beef options. (GM) feed modified non-genetically farmers’ decrease will alfalfa (RR) Roundup Ready genetically modifiedalfalfaseedandhay Roundup Readyalfalfawillcontaminateorganicandothernon- AlfalfaReady Roundup Know About Ten Things You Should 2 10 Certified organic alfalfa growersrisk premiums losing organicfor product alfalfa their Certified 1 year. a ofherbicides 200,000pounds an additional could result alfalfa the in applicationRR of Food andAgriculture Policy estimates that alone, the NationalCalifornia Center for 1996and2004.In between pounds million bymore thantolerant 138 crops increased Herbicide useonherbicide- on herbicides. producers currentlyMany donotrely alfalfa increase herbicideuse Roundup Readyalfalfawill

3 11 Evidence 12 Evidence abroad are eliminated. their markets if tostand loseeverything a much higherpercentage of their crop. They Northwest Pacific exported, producers export Although only5percent ofU.S. is alfalfa are Washington, andOregon. California, purchase GMhay. statesexport Theleading have told U.S. not will export companies they Japanese customers for import, alfalfa of RR Despite the Japanese government’s approval Japan isthe largest ofU.S. importer hay. alfalfa Northwest growers the hay market export for Pacific Roundup Readyalfalfawillruin andryegrass. ragweed, and giant (marestail), common (waterhemp), horseweed in the identified include pigweed weeds U.S. The most problematic glyphosate-resistant that kill. glyphosate cannot acres ofweeds have thousands optionsto with of few deal tools for controllingnew them, farmers outpaced has of glyphosate-resistant weeds the spread wouldreplace. Because technology were told farmers chemicals RR the very weeds, tochemicals control glyphosate-resistant must resortto andmore less costly friendly overtime. less effective herbicide Farmers resistance,are the developing popular making As more andmore weeds glyphosate isused, glyphosate-resistant weeds exacerbate theproblem of Roundup Readyalfalfawill 4 6 11

to test for GM traits. their products those whoexport—mayespecially forced be producers— honey products, honey in GMmaterial isdetectable Because pollen. the in U.S.produced from alfalfa isderived andalarge percentage ofhoney alfalfa, pollinatorsof are important bees Honey the honey industry Roundup Readyalfalfathreatens liability. Technology Agreement that shields itfrom Monsanto a enforces called contract astrict growers to buffer plant alfalfa areas. RR contamination. USDA notrequire does for their protecting fieldsfrom GM who don’t GMcrops plant are responsible patents are andliability reformed, farmers Unlesspatented laws traits. governing contaminated by seed and whoowns GMtraits byunwanted damages caused systems, whoshould pay including for andjudicial regulatory byour unanswered Many questions liability remain liability riskstofarmers transfer unfair Ready technology Monsanto’s patentsonRoundup 7 5 this new GMcrop.this new organisms beforeother non-target approving birds and onmigratory RR alfalfa of the effect notanalyze did Service Health Inspection ofAgriculture’sDepartment andPlant Animal on livestock andproductivity. health The U.S. crop)RR RR alfalfa (orany of potential effects researchNo independent exists onthe independent scientists wildlife have notbeenanalyzed by and productivity oflivestock and Ready alfalfafeed onthehealth The potentialeffects ofRoundup Photo Courtesy USDAPhoto Courtesy 8 RR alfalfa at the endofastand’s alfalfa RR life. to well as as kill glyphosate-resistant weeds, tochemicals control and alfalfa volunteer onadditional money spend will alfalfa RR whoadopt Farmers andother benefits. seeds glyphosate, order in on to receive warranties toof brands generic cheaper opposed as glyphosate (Roundup),trademark herbicide states to thatpurchase its growers need Monsanto’sseed. Technology Agreement onto istacked fee the ofGM price technology a because varieties, seed proprietary much other costsas twice as alfalfa RR farmers’ seedandchemicalcosts Roundup Readyalfalfawillincrease production system.production food ofour overalarge segment monopoly andallowsa andfarmers, farms American Monsanto’s increases products RR on grip to Adding of companies. the line alfalfa of patents and acquisition ofother seed market through GMseed ownership global Monsanto controls 90percent about ofthe public alfalfaseedvarieties reducesfurther theavailability of over American agriculture, and the level ofcorporatecontrol Roundup Readyalfalfaincreases 10

9 13 Evidence 14 Profiles varieties here the in U.S.varieties available from be other countries. will However,transportation. that there Munsch the out, same high-yielding is no guarantee, points seed frombecause of sources, foreign thefirst alfalfa behigh The iscost ofwhich find would to he’s believes impact. substantial financial with both two options, with faced In order Munsch to continue organic after with production the ofGMalfalfa, introduction (GM)alfalfa. modified contaminated bygenetically be will which haverole alarge natural ofbees, rangeofactivity, contribute to that the likelihood seeds the with producers coupled seed alfalfa area ofprime thesays. geographic compact He believes grown herein the seed U.S.,” tocontaminationofallalfalfa lead significant quickly Munsch will alfalfa that modified growersthe ofgenetically have introduction warned seed “Respected hay, andgrass alfalfa ofhispastures aquarter andabout include alfalfa. it isthe most cost-effective forage protein source cattle.for his ismixed winterAll ofhis feed forage because model, hisproduction in Munsch says that isakey organic alfalfa ofhisfarm. mile radius a150- within farms andbeef vegetable consultant to oforganic ahandful abusiness Munsch as alsoserves Agriculture program. (CSA) Supported that operates mostly aCommunity as by anarea organicfarm vegetable thesold under name“Grazier’s Organic” Valley, Wisconsin. is ofhisbeef Some Run Farm, Deer Coon in business, beef organicJim Munsch acertified runs Coon Valley, Wisconsin Jim Munsch - Photo Courtesy JimPhoto Munsch Courtesy

the “owner” Munsch position, of this genetic material amonopolistic in adds. and patent production, the allput of seed and geography the biology seed, modified genetically the patentallowing holderto demandpayment for the ‘use’ ofthe material.” The approval of the the patented containing genetic material regardlessover seed ofhowthe material got there, material,”this modified genetically “The holderofMunsch the patent hasclaim explains. contaminated with be eventually will thereareas, isanabsolute seed that certainty allalfalfa geographic limited very in isgrown America North in grown “Given seed that almost allalfalfa ofcontamination. instances in are of thepatenting protected property patent ofgenetic the material seeds means holder, even Munsch the ofU.S. about implications isconcerned the patent because law onfarmers, had residual glyphosate it.” in it forage knew to a if I hesays,feed cow are “Iwouldnever unknown ofGM still feed effects that and,given the andmultiple-generational organic grain, long-term studies. eats His family concerning ofdata onthe ofscience andadearth topic, questions regarding the legitimacy of such herbicides.” effects the long-term not know therebelieves areMunsch unanswered eatenforage cattle. by does modified the sprayed genetically there samein be Thepublic will Munsch explains. and “Therearegrain, ofglyphosatein residuals conventionallyraised the with useofRoundup herbicide,” grown food eating about concerned “I amalsovery experience,”previous Munsch adds. of anorganic system production for –anextremely three years onmy costly procedure, based undergoing itout land and the process wouldmean keeping of transition “Renting uncertified government payments. notreceive does hisorganic whereas farm bygovernment programs, who are subsidized Munsch producers says that against grain heiscompeting rentable isscarce land because butfound itunavailable at any the in past, price. his operation to rent sowewouldneed it.”used, land to Munschclose rentto tried certified organically has “An problem,” immediate heexplains, “is that ready to wedonothave own ofour be land fallow Munsch fears the thatstrain production. economic would out comeof alfalfa transitioning with cattle byapproximately 30to 40percent. his to feed forage theneeded like lowyielding amountofland cloverproducing wouldincrease for two years clover. compared to years to every seven six Furthermore,to replanted every be thetwice ofclover, yield annual better drought provides significantly resistance, andonlyneeds has alternativeThe second is Alfalfa as to switchfromsuchto anotherclovers. legume, alfalfa 15 Profiles 16 Evidence to pure stands; about a quarter is planted with grasses oranother companion crop. grasses with isplanted aquarter about to pure stands; of Themajority acreage isplanted applications grasses. the ofglyphosate alfalfa desired kill U.S. hay. mix analfalfa-grass their animals cattlefeed typically Many producers beef andhorseowners andgrasses. ofweeds free stands onpure alfalfa often depend they producers are because more likelyDairy to alfalfa, useRR Forages.” habitat for wildlife. it provides important cows. dairy highprotein its especially content, andlowfiber isa staple ofmostlivestock diets, andfourthmost planted. agriculture widely more than acres 2007. 21million in ( Alfalfa replanting. without U.S. forthe in planting widespread to plant commercialized perennial be engineered genetically microorganism, Agrobacterium,that confers resistance to glyphosate. Roundup.herbicide, To Monsanto dothis, from agene anative sequence soil incorporated to tolerate Monsanto’s isengineered in glyphosate, theingredient alfalfa active RR trademark producer, Like crops, O’Lakes). allRR ofLand ForageInternational (asubsidiary Genetics with seed largest the partnership sale.in alfalfa The MonsantoRR alfalfa Company produced across the United States. andcotton. corn, closelyfollowed crops acres are 100million bycanola, onnearly RR grown and crops enteredsoybeans (RR) Roundup with Ready the marketplace 1996,beginning in Geertson Seed FarmsRoundup v. Ready Johanns Alfalfa: The Case Against 14 Unlike RR soybeans and corn, RR alfalfa will be harvested for several consecutive years years consecutive for several harvested be will alfalfa RR andcorn, Unlike soybeans RR 17 Because of alfalfa’s pervasiveness, and because it is typically grown as a perennial crop, aperennial ofalfalfa’sas grown itistypically Because andbecause pervasiveness, Medicago sativa Medicago 19 L.) is the most important forage crop the isthe in U.S., most important on grown L.) andwas 12 Alfalfa isthe most crop recent to approved RR for Alfalfa be commercial 15 It isthecrop thirdto valuable U.S. most economically 20 RR alfalfa is not useful to mixed stand producers, as to isnotuseful as producers, stand mixed alfalfa RR 18 For all these reasons, it is dubbed the For “Queen of itisdubbed allthese reasons, 16 Alfalfa is an important animal feed because of because feed animal isanimportant Alfalfa 13 RR alfalfa isthe first alfalfa RR 21

granted on July 23, 2002, shortening the review time. onJulygranted 23,2002,shorteningthe review Monsanto which EPA ofthe status Risk” data, submitted for “Reduced for apetition review pursuantto Fungicide, the Federal Acton alfalfa andRodenticide Insecticide, (FIFRA). the to tolerance ofRoundup (or labeling increase level proposed other glyphosate) herbicide Environmental Protection (EPA). Agency Monsanto submitted glyphosate residue and data to the marketplace. alfalfa RR to thehoops bring with In 2002, the two companies began to regulatory jumpthrough several Monsanto andForagehad Genetics Petition for Deregulation notification. single dozen) are a often under listed states more (sometimes than a several states, because individual acreagein the amount offield trial 2005. the in U.S. 1998and trials between field glyphosate-tolerant alfalfa APHIS ofmore notified than 300 into the marketplace. Monsanto an“event” recombinant DNAusing methods untilthe is“deregulated” plant andallowed APHIScrops. considers a“regulated GMplant each inserted article” DNA andeach segment (GM) modified of ofand acknowledge testgenetically plantings (APHIS) mustnotified be The of Agriculture’sUnited StatesDepartment Service and Animal Plant Inspection Health many growers orconsumers. notsatisfy anddid Forage Genetics, Table 2005(see in hurdles serious alongthe few way for Monsanto 1onpage 20)posed and from in1998 trials fieldto approvalpathRR alfalfa The forplanting of commercialsaleand Approved Roundup Ready AlfalfaAPHIS, EPA, and FDA: How Regulators Field Trials 22 It determine to isdifficult Photo Courtesy USDAPhoto Courtesy 24

Then 17 Evidence 18 Evidence alfalfa isnotmaterially differentfromalfalfa conventional alfalfa: onMonsanto’s isbased alfalfa onRR opinion safety its testing, determination that own RR orfeed food mandatory FDA norrequired tests, neither independent conducted Because Monsanto’sNote summarized safety assessment andnutritional documents. andfeed food The next month, Consultation FDA Note” a“Biotechnology issued RR alfalfa. regarding 2005. later extended 24,2005,butwas to set endonJanuary to 17, was February comment period available for comment. EnvironmentalAssessment was public (EA) preliminary Thenotice alsosaid that APHIS’ alfalfa. RR uncontrolled commercialof) saleandplanting Monsanto andForagehadsubmitted to deregulate their petition (that allow Genetics is, 24,2004,USDA November On anotice the in Federalthat published Register announcing Mexico, and Taiwan. Japan, Korea, Canada, including countries, approvals andproduction from several import through aFreedom ofInformation Actrequest. (FOIA) of thesubmitted data byMonsanto, isonlyavailable theitself toan overview data the public “events” for alfalfa RR 2003. October summary J101andJ163in Monsanto safety crops. assessment submitted andnutritional andfeed new afood voluntarily safety finding. to notrequire themake orfeed agency does afood products, andfeed ofGM food regulation The Drug and Administration’sFood (FDA) authority, statement on the policy in a laid out at 0.5ppm. seed alfalfa or tolerance for this protein. for Monsanto unnecessary andForageto acquire itwas anexemption Genetics commodities, for the ofthis production proteinand the genetic material necessary allraw in agricultural anexemptionestablished protein for EPSPS the (which CP4 confers tolerance to glyphosate) request to eliminate the hay. tolerances forage for andalfalfa alfalfa alfalfa. conventional engineered andgenetically forage andhay, which itsaidwere nolonger needed. gap.to fill this regulatory these tolerances EPA Monsanto notextend did Because seed, petitioned to alfalfa again forage, (ppm),and“in million fodder andhay, per orongrass 400 parts group” at 300ppm. atolerance group”established for residues ofglyphosatenongrass, “in feed, at oronanimal to establish tolerances for glyphosate residues onalfalfa. the Monsanto agency Federal andCosmeticAct Food, hadpetitioned Drug (FFDCA), AprilOn 17,2002,EPA anotice the in Federal published Register pursuantto that, the 37

32 Instead, FDA encourages voluntary submission Instead, ofsafety FDA information about encourages voluntary 35

27 Monsanto further proposed to Monsanto delete proposed the further tolerances for alfalfa 31 On February 16,2005,EPA February On atolerance set for glyphosate on 29 Three months Three later, EPA Monsanto’s denied 28 These weretolerances to apply both to 34 25 Monsanto for applied regulatory Pursuant to the FFDCA, EPA Pursuantto the FFDCA, 33 AlthoughFDA published 30 Because EPA Because previously 36 The public Thepublic 38 The 26

courses). lawns and for used golf grass popular turf a bentgrass, creeping RR for still aplant field in trials, prepared anEISfor any ofthe GMcrops onthe market (although oneiscurrently underway Statement anEnvironmentalImpact in a more (EIS). thorough review orother crops.” alfalfa in control andweeds pests ororganisms that and…should areto agriculture; not species beneficial the reduce ability to ordissemination,”introduction threatened notharm orendangered “will andthat the events J101andJ163“wouldnotpresent pest ofplant arisk which events that concluded alfalfa to moveinto the marketplace. (FONSI), Impact Finding its ofNoSignificant APHIS published May in the to 2005,paving way for deregulatealfalfa USDA decision the RR crop its announced Photo Courtesy Kristina Hubbard Kristina Photo Courtesy and event J163to complete.and event be and information, J101 the considers Agency this event consultation on alfalfa onMonsanto’sthis time,based data ofits andForagedescription Genetics’ marketed, At nowgrown, andconsumed. from parameter alfalfa relevant from them, are notmaterially differentin safety, oranycomposition, other derived andfoods J163,andthe feeds J101andevent event tolerant alfalfa Monsanto andForagehave that concluded their glyphosate- Genetics 39 40 The agency said it did not need to prepare did notneed saidit Theagency

APHIS has never never APHIS has 19 Evidence 20 Evidence September 27,2002 September November 24,2004 November 10,2004 November December 8,2004 December February 16,2005 February February 3,2005 February August 18,2004 August October 1,2003 October April 17,2002 June 27,2005 May 1,2005 May 2,1998 Approval ofRoundup Alfalfa Ready Regulatory Timeline forthe no longer considered regulated articles. no longerconsidered regulated J101andJ163are events determination that alfalfa glyphosate-tolerant USDA the notice publicofits publishes inFederal advising Register Impact. Significant USDA andFinding anEnvironmental Assessment issues ofNo at 0.5ppm. EPA seed onalfalfa atolerance for glyphosate level sets Eventtolerant Alfalfa J101andEvent J163.” Consultation Note regardingGlyphosate- FDA a“Biotechnology issues USDA extendsthrough 17,2005. February comment period 24, 2005). andapubliccomment (January deadline Environmental Assessment, inthe Federal alfalfa RR Register,deregulate the availability ofAPHIS’ USDA announces Monsanto &Forage Genetic’s to petition hay.forage andalfalfa EPA Monsanto’s denies to eliminate request the tolerances for alfalfa aresays nolongerneeded. they it hay forage, because andalfalfa eliminate the for tolerances alfalfa, set to Monsanto petitions also seed. onalfalfa ofglyphosate residues EPA totolerances establish forpetitioned pursuant to the FDCA EPA anotice inthe issues Federal that Monsanto Register had alfalfa). J101andJ163(RR for events summary safetyandnutritional assessment andfeed Monsanto afood submits andhay, forage, fodder grass, group; group.” nongrass feed, EPA “tolerances inoronanimal establishes ofglyphosate for residues related totolerances residues to establish for alfalfa. glyphosate (FDCA) EPApetitioned pursuant to the Federal Act andCosmetic Food, Drug EPA anotice inthe issues Federal that Monsanto Register had begin. field trials alfalfa (RR) Roundup Ready Table 1.

or threatened species andtheir habitats. or threatened species consultation U.S. with Fish andWildlife to endangered affect the about potentialfor alfalfa RR It EIS. afull for alsoasked andperform anEPA to deregulatealfalfa to decision RR rescind its asked USDA California, of District in theNorthern GM variety.court federal in filed The suit, the whenitderegulated alfalfa RR ofintroducing consider implications the potentialeconomic isinterrelated andthatthe potential environmentalharm harm, USDA economic with to failed Importantly, andthat damage export markets. itwill thatresistant the suit maintains weeds; that introduceproblems; more itwill into herbicides the environment andcreate glyphosate- creating marketing oforganic integrity products, the affect suit contends will that alfalfa RR thelawsuit against first USDA was be filed GM crop.to The particular for ofa thederegulation violationsUSDA of the including National Environmental onfive claims, (NEPA).Act Policy It consumer, producers farm, andfamily ofalfalfa a coalition andenvironmentalgroups sued After USDA gave Monsanto alfalfa, RR lightto andForageagreen commercialize Genetics Farmers Respond alfalfa. andconventional andorganic alfalfa RR between market acceptance andcross-pollination the petition. 137 supported private citizens. universityprofessionals, industries, consumer agriculture and groups, growers associations, producers, organicanimal producers, growers, growers andseed from alfalfa comments, astrong APHISBy hadreceived theresponse: endofthe comment 663 public period, Public Response 44 APHIS ignored or brushed aside these concerns. aside orbrushed APHIS ignored 42 The vast majority of respondents (520) opposed deregulating RR alfalfa; RR alfalfa; deregulating of majority (520)opposed vast respondents The 43 The main concerns of opponents werepotential problems with ofopponents Themain concerns

21 Evidence 22 Evidence “most time” optimal dueto weather andother factors outoftheir control. reads: Hisdecision capricious.” their fields to at always consider APHISthe harvest that cannot failed farmers extent “arbitrary oflikely and contaminationalfalfa ofconventional byRR andorganic alfalfa into a“buffer if the zone” APHIS’ isestablished. even called lackinquiry Judge of Breyer pollinators, fields by RR alfalfa off employ tocan protect their crops transported from pollen The judge method”organicfarmers noted asingle that EA nor “neither identify the FONSI the grow their chosen cannot crop.” they to the elimination ofallalfalfa; Thejudge said: gene istantamount the with engineered infected thethat possibility be their crops will alfalfa, went onruling The to note, “For who growfarmers choose those to engineered non-genetically anddonotdemonstrate environmentallaws. byfederal the “hard required look” convincing” conventional stating that are valid, USDA’s andorganic alfalfa were “not arguments opposing law. For example,will thecontaminate judge found that concerns RR alfalfa that plaintiffs’ found USDA’s to the and/or contrary basis, scientific without unconvincing, arguments the judge consistentlybefore regarding afuture ismade. deregulation Inhisruling, decision alfalfa. ofRR environmental impacts thatJudge USDA to ruled and Breyer the adequately potentialeconomic hadfailed evaluate for 13,2007, released commercial sale.February On was before alfalfa RR performed have been onwhether anEISshould 19,2007.HeJudge onJanuary focused heard Breyer the Charles case Growers Landmark Court Decision Protects Alfalfa conclusion isarbitrary. Without cannot. of gene whenthey transmission APHIS’s such data, into their the forage mature likelihood crop before seeds andno inquiry into are howoften actually farmers able to harvest APHIS madenoinquiry travelcan more than two miles. that bybees ispollinated that andthe fact alfalfa farms concentration ofseed the highgeographic given protect their crops from contamination, especially fact, in can, alfalfa to whodonotwant engineered grow genetically farmers into whether those on this though conclusion itmadenoinquiry even notoccur.contamination does It rested decision impact’ ‘no its significant it isthe organic andconventional responsibility to farmers’ ensure that such because ofgenethe such isnotsignificant transmission, likelihood impact orsprouts are GEfree.’seeds Instead,thatconcluded effect whatever itin thatinternal APHIS emailacknowledges ‘[i]tmay hard that be to guarantee an APHIS notconcludeindeed, did that gene would notoccur; transmission 46 He ordered USDA alfalfa EISonRR afull to perform production locations for disclosure. locations public production The illegal. JudgeRR alfalfa alsoordered deemed known Genetics to was supply all Forage growers through an Administrative Order. after soldorplanted March alfalfa 30,2007, RR which USDA conditions, ordered to certain andsoldunder was communicate toharvested could alreadyplanted be alfalfa APHISRR offuture plantings. and Forageto notify Genetics Monsanto requiring article, once aregulated again was andstated that alfalfa RR alfalfa, RR theof In May planting which 2007,Judge banned injunction, apermanent issued Breyer after this date.2007, andprohibited ofGMalfalfa allplanting to itbefore plant alfalfa March RR growers whohadalreadypurchased 30, allowed decision His Thismarked first-everthe seed. planting. moratoriumonplantingofaGM the seed alfalfa RR halting JudgeAbout amonth injunction after hisdecision, ordered Breyer apreliminary non-GM seed: physical environment.” of integrity the ofmaintaining Thejudge importance the explained result adirect of, are on the interrelatedthe effect decision deregulation and,indeed, with, Here, on the organic and of conventional effects thefarmers economic government’s are when they effects relevant ‘interrelated’with ‘natural orphysicalenvironmentaleffects’... by Monsanto’s GMvariety. Butthe judge found that USDA “overstates the law…Economic to organic andconventional risks crop contaminated couldeconomic be growers whosealfalfa technicality, onalegal USDA based that, nothave did theto argued agency address the andconsumers havefarmers higherstandards than government: the federal “whollyinadequate.” organic as as their products from labeling that He many acknowledged prohibitedJudge be alsofound Breyer APHIS’ not“necessarily” that will reasoning farmers

individual choice.’individual of diversityandvariety anenvironment possible, wherever which supports another consequence: NEPA isanundesirable food, goal isto ‘maintain, oraconsumer’s crops, engineered choice to engineered eat non-genetically that action eliminatesA federal afarmer’s choice to grow non-genetically marketed. regardless be can ofhowsuchalfalfa, alfalfa to to donotwant their livestock grow engineered orfeed genetically farmers most importantly,engineered… APHIS’s comment simplyignores that these …to andconsumers notgenetically organic these means farmers 23 Evidence 24 Evidence crop: isanunapproved GM alfalfa RR longas as Order.) the and replaced OrderJuly 2007 clarified 2007supplemental Administrative December June 14,2005andMarchbetween 30,2007.(A foralfalfa measures RR growers whoplanted production mandatory Order requiring In July 2007,USDA anAdministrative issued wagons, choppers, combines, and seed conditioning equipment. conditioning andseed combines, choppers, wagons, balers, including equipment, of pieces 1 The Orderfor specific instructions Administrative cleaning outlines less than 8.5x11inches andmarked Alfalfa.” “Roundup Ready no only. measuring purposes hayasign with mustclearlyfeed alfalfa labeled be RR and that the hay RR alfalfa, if hayfor beused purchasemust contains they notified ispresent the in hay. seed cover viable if asecured covered with Buyersmust be hay to must alfalfa haul used be RR trucks Flatbed alfalfa. ofnon-RR transport to for astorage used alfalfa before site being after clean mustswept unloading be Transportation: fields. alfalfa non-RR prior field in touse RR alfalfa in whileitis the fields be mustcleaned alfalfa RR andnon- for RR both Equipment used alfalfa.” RR onlywith used shall be equipment “This stating, orlabel a sign mustmarked with be hay orseed alfalfa exclusively for the ofRR production Equipment: hay production. grown fields for to alfalfa introduced RR Pollinators: 47 These requirements remain in effect in effect These remain requirements Pollinators be cannot Equipment used Equipmentused Any trucks, wagons, or other transporters used to moveRR used orother transporters wagons, Any trucks, “Roundup Ready Alfalfa.”“Roundup Ready Storage mustlabeled containers be seed. alfalfa from segregated non-RR be must seed alfalfa ofRR Bags seed. alfalfa non-RR with prevent physical mixing Seed: wire. Alfalfa”“Roundup Ready or attached securely to twine the tags binding bybale as mustidentified produced be where the itwas farm leaving alfalfa ofRR Bales hay. from segregated non-RR be Storage: noless thansign 8.5x11inches andmarked Alfalfa.” “Roundup Ready Vehicles transportation. hay must during alfalfa display alfalfa a RR transporting and/or mustcommingled accompany documentation RR alfalfa The following Documentation and Lot Identification Alfalfa”Ready orwire. attached securely to twine the tags binding by bale as “Roundup hay mustidentified alfalfa be and/orcommingled alfalfa ofRR Bales TagsBale methods: following orleaves produced are-seller’swas byoneofthe mustclearly labeled location be hay that alfalfa leaves onwhich and/orcommingled it the farm alfalfa RR All andfor feed. animal hay and/orbyend-users, isproduced Hay: Commingling of RR and non-RR haywhere for andnon-RR the useonfarms isallowed ofRR Commingling All RR alfalfa seed must be harvested, handled, transported, andstored to transported, handled, mustharvested, be seed alfalfa RR All All RR hay may be transported to contained areas for areas to storage, hay contained RR All may butmust transported be

9. Shipment date andticket number 8. Scale 7. Weight 6. Unit ofbales) count (number number 5. Lot 4. Name andaddress ofhauler 3. Name, signature, andaddress ofseller 2. Name, signature, andaddress ofbuyer designation alfalfa 1. RR

25 Evidence 26 Evidence and longitude coordinates address orthe mailing ofthe farm. grown –eitherlatitude be will orfield isor thewith exactwhere oftheir farm alfalfa location must callers provide the to USDAplans conventional plant Second, ororganic operator alfalfa). requires conventional current that growers be (oragency callers or organic alfalfa a grower who USDA August this in for hotline established callers. ofcriteria aset 2007with potentialevaluate fields, the to takefor contamination and steps to protect alfalfa. their non-GM their near growing is RR alfalfa if out find can establish sofarmers a toll-free hotline for and a timeline planted, disclosure stateswas ofthe counties eastern in where alfalfa RR ordered USDA to set planted, disclose the counties 17western in stateswas where alfalfa RR Judge the samecounty within growers wholive or adjacent farms. Breyer county to alfalfa RR Two months to later onlyto require that amended this alfalfa order provided notice be was Positioning acreage. production System alfalfa ofallRR locations (GPS) alsoorderedinjunction Monsanto andForage to provide USDA Genetics Global with that ask but did Monsanto andUSDA ofthese disclose the Asa fields. location the result, planted,already ask didnot theto alfalfa court ofGM The plaintiffs order thedestruction 2008. the acreageexpected to jumpto 2007,andthen 570,000in to more than acres onemillion in Monsanto alfalfa, ofRR planting further halted Before decision theacres court for seed. were theIn 2007,more in U.S. planted than alfalfa 200,000acres ofRR for forage, and20,000 Ready Alfalfa Court Sets Rules to Stop Spread of Roundup 48

before March 30, A listofcountieswhere RoundupReadyalfalfawasplanted near theirfieldsby callingUSDA’s hotline, Alfalfa growers canfindoutifRoundupReadyalfalfaisgrowing http://www.aphis.usda.gov/biotechnology/alfalfa_locations.shtml. Is RoundupReady Alfalfa Growing Near You? 3007, ispostedonUSDA’s website,

(866) 724-6408 at

49 .

First, the

the environment. negatively well as as impact and food, reduce the supply will ofnon-GMfeed fears that alfalfa RR that anddesire eat organic alsoregularly foods foods areCFS’ ofGMmaterial. members CFS free andsell for non-GMproducts. their livestock, feed useitas grow alfalfa, ofthese members Some state across every the nation. in almost with members organization membership non-profit systemsproduction welfare, isanational animal onhumanhealth, CFS andthe environment. Safety Center forFood company’s costs. ofTrask the may purity thefarmers raise demandtesting which will to certify Family Seeds, conventional Both andorganic alfalfa. the ofRR with introduction supply isinevitable seed its the nationwide,contamination to of including organic andbelieves producers, seed high quality Trask Commons. Dakota South as commonly provides known Family varieties public Seeds andhay from old, businessfor seed family four generations.Trask alfalfa harvests Family Seeds Trask Family Seeds glyphosate. with ability to andferal alfalfa control weeds domestic Weed market. its well as Farms’ as seed, resistance to Geertson hinder glyphosate will its ability will affect to export RR alfalfa by seeds Farms’ Geertson records. The contamination of are universitytested varieties andhave Farms’ proven seed yield international Geertson markets. domestic both and in seed ofalfalfa Farms varieties sells six 1939.Geertson in by hisfamily 80acres homesteaded that the was original still farms since 1942.Phillip Geertson seed alfalfa Farms Seed Geertson against USDAcase the filed andEPA: andorganizations Nine individuals Plaintiffs remains effect. in alfalfa RR against planting the injunction appeal, the During granted. It appeal. to partially theits ask court expedite did which the was appeal, andMonsanto. Forage dealers, Monsanto Genetics, during the toseed injunction notseek did lift restrictions andcosts ongrowers, unnecessary salesimposes seed alfalfa against RR injunction USDA’s to the Ninth approvalalfalfa ofAppeals. ofRR Circuit Monsanto Court that the asserts JulyOn 23,2007,Monsanto Judge andForageappealed Breyer’s to Genetics vacate decision Roundup Ready Alfalfa Monsanto Appeals Court Order Banning ranches on the edge of the Black Hills of South Dakota and has been a been andhas Dakota ofthe ranchesonthe Black HillsofSouth edge

is a family-owned seed farm near Adrian, Oregon near that produced farm has seed isafamily-owned

(CFS) seeks to address the impacts of industrial farming and food andfood farming to ofindustrial address seeks the impacts (CFS) 27 Evidence 28 Evidence and publicly transparent assessment of the impacts is conducted. and publicly transparent isconducted. assessment ofthe impacts independent, untilathorough, objective, andcommercialized deregulated GM crops be new which demandsthat no Engineering, who haveonGenetic the Farmer endorsed Declaration groups issues. Farmer andrural to biotechnology Farmer of34farm iscomprised agricultural 1999to in provide anational voice on for farmers Engineering onGenetic Farmer Campaign the coordinated Farmer andsponsored to organizations member andits NFFC GM crops. of impacts health environmental,andpublic to into call question economic, the agronomic, groupsin the nation amongthefarm first 1986,andwas in founded system. was farm NFFC healthy, just, asustainable, togroups working economically secure and safe, food andsecure The National Family Farm Coalition material. that anddesire eat organic andwhoregularly foods foods are ofGM ofGMcrops; free free whodesire their farms to maintain whogrow andusenon-GM alfalfa; farmers include alfalfa anddisclosure ofresearch DRC’sby their products; sponsorship onGMproducts. members for damages caused corporations onbiotechnology liability placing engineered; genetically economy. Amongthe interests ofDRC are is consumers’ to right whether their food know 1978to in Dakota’s protect North formed air, land, water, andagricultural communities, rural other with offices inBismarck Dickinson in andwas headquartered Fargo, Dakota. DRC North Council Resource Dakota The ofGM crops. free as tothat wish maintain they organicfarms certified andwhoown whogrow andusenon-GM alfalfa farmers include alfalfa Its Cornucopia Institute members methods. oforganic farming the isprotecting credibility andthrough marketplace politically both Amongthe interestsfarmers initiatives. ofThe Through research,Cornucopia’s advocacy,economic development, and is goal to empower The CornucopiaInstitute Pesticides’ members. Beyond thesecontinue treadmillthat crops the will pesticide threatens because pesticides the of health Pesticides to aim reduce members the to proliferation andits tolerate ofGMcrops designed away atransition and the environment from byencouraging the useoftoxic Beyond pesticides. Pesticides Beyond promotes safe air, water, to andworks health protect public andfood land, is a non-profit organization based in Cornucopia, in Cornucopia, based Wisconsin. organization isanon-profit (DRC) is a North Dakota non-profit organization that is organization non-profit Dakota isaNorth (DRC) (NFFC) is a coalition representing family farm and rural representing andrural isacoalition farm family (NFFC) the interests ofconsumers GM-free whowant foods. cattle; toandprotecting livestock alfalfa ordairy uncontaminated orfeed grow GM-free alfalfa protecting interestswantranchersthe andwho to farmers of foods; modified of genetically toWORC the ensure andaccurate clear wants labeling consumers’ to right byrequiring know through sustainable andjust society community action. ofademocratic, theadvance vision chapters. and50local WORC’s 9,500members with community organizations mission isto The bythefrom release ofnovel the threats GMorganisms. posed reformand advocates for to regulatory protect the natural environment andhumanhealth Club’s agriculture. TheSierra industrial educatesCommittee the public Engineering Genetic and habitat genetic engineering, protection, pollution, encompass species, endangered Club’s TheSierra San in California. Francisco, headquartered non-profit a California concerns Club is TheSierra placesofthe theearth. andprotecting wild to enjoying, exploring, dedicated Club The Sierra and otherfactorsdictate whenhay canbe harvested. that cross-pollination between hay fieldsisnotathreat, even though weather wasdelayedHarvesting duetorain. MonsantoandForage Geneticsassert Alfalfa hay fieldsinfullbloomsouthof Billings, Montana, August2005. Western Councils ofResource Organization is a national non-profit organization of approximately isanational organization non-profit 750,000members

is a regional network of seven grassroots grassroots networkis aregional ofseven 29 Evidence 30 Evidence September 18,2007 September February 13,2007 February 16,2006 February March 23,2007 March 12,2007 August 1,2007 Timeline ofLawsuit Filed Against USDA forits June 27,2005 July 23,2007 July 23,2007 May 3,2007 Approval ofRoundup Alfalfa Ready APHIS appeals the Court’s appeals APHIS decision. to theirclose fields. growing is RR alfalfa andfindoutif tohotline call for farmers USDA notice publishes in Federal a toll-free announcing Register Monsanto the Court’s and Forage appeal Genetics decision. judgment. Judge amended publishes alfalfa. on RR Judge EIS injunction until orders afull permanent USDA does the EIS. completion ofafull onlyafter issued be will alfalfa ofRR regarding the deregulation andthat article, afuturedecision once aregulated is again alfalfa notice publishes that inFederal announcing RR APHIS Register planting. and sales seed Judge injunction, haltingRR orders preliminary alfalfa. of RR commercial release Environmental Statement Impact approving before the (EIS) USDA finds lawviolated the failing Court to by an conduct alfalfa. (RR) Ready USDA’slawsuit challenging ofRoundup commercial release Center for Food Safety, other file plaintiffs andseven WORC, articles. longer consideredregulated J101andJ163are no events that alfalfa glyphosate-tolerant USDA the notice public publishes inFederal advising Register Table 2. is contaminated, he would be forcedis contaminated, hewouldbe to discontinue forage production. the On other this hand,if isorganic. testing thatcustomers reveals hisfeed that feed the alfalfa testing onehand,hemay additional On costs to incur assure his ofGMalfalfa. introduction test to theensure ofGMmaterial, feed itislikely itisfree such testing follow will the donotpresently the forage dairies While to provides organicSchmaltz alfalfa organic dairies. for such aliability.” company to Ihave saiditisimpossible issue has contacted coverage butevery such anevent, explains. “IhaveSchmaltz attempted toinsurer of an find case whowould cover in liability my zero amongmy tolerance customers for whodemandorganic products,” contaminated seed that are“There threatenedorganic may alfalfa alfalfa is hisfields. with byRR come contact in Schmaltz’s and sprouting alfalfa, seed to salesof concernsDue liability regarding alfalfa both meto continue allowed my in has livelihood,”farming says. Schmaltz “Organicconventional farming. in used andfertilizers chemicals by systemicimpacted exposure to negatively after was hishealth organically farming He began livestock. for organic dairy forageconsumption andalfalfa forsprouting human alfalfa he produces production, seed to Inaddition ten organic years. businessfor in more thanbeen that farm has an organic seed operates Blaine’s Seeds, Best and owns Schmaltz Blaine Rugby, North Dakota Schmaltz - Blaine

Blaine’s Seeds Best 31 Profiles 32 Profiles agricultural fields during hunting season. season. hunting fields during agricultural “abundant,”as to addition in people’s such hunters as whofrequent clothing andboots, from field-to-fieldwildlife, which Schmaltzdescribes by transported alsobe can Seeds due to persistent wind,” says. Schmaltz orhigher. hour in this per be enormous region would pollen andseed travelingdistance of “The explains of10to that heencounters 15miles week each four ormore speed days awind with thatHe landscape farms. he greatereven prairie fieldswindswept due is his own to the open, and GM alfalfa between that ofcross-pollination isalsoconcerned theSchmaltz likelihood alfalfa.” nearby, the with GM cropcontaminated bycross-pollination mymight be organic alfalfa will venture if and there Bees out fieldstwo miles, wereabout fields. GMalfalfa pollinate our “My We that andIeat organic family foods. bees honey own byour produced alsoeat honey Igrow.” consuming the in alfalfa risks andto health my metoensure own preserve thatallowed my customers donotface unknown to risk consumer health,”unknown has anorganic farmer explains. “Becoming Schmaltz ofcrops isthe producer regarding afood concern the as genetic engineering “My primary RR corn steadily corn increased). RR more where thancorn, from seven-fold 2002to acreage glyphosate of useincreased 2005(as from 4percent toincreased 74percent oftotal U.S. cotton acreage.pattern The samein isseen For example, glyphosate useoncotton 753 percent cotton from 1997to RR increased 2003 as tons less in than adecade. bymore than 60,000 shows cropsdata that increased useonherbicide-tolerant herbicide the dramatically. usein U.S. herbicide crops, Since the ofRR introduction increased has USDA How Did We Get Here? higherinputcosts andmore environment use, our andfood. meaning in chemicals herbicide to glyphosate. To their anddiversify must increase farmers contend resistant with weeds, resistance even more weed will encourage perennial, grown widely a field especially rotations, fields in wherecropconsistentlydevelop farmers RR into another introducing crops, growRR acres ofU.S. farmland. Already, infest andpigweed. glyphosate-resistant more than weeds two million horseweed the in press, glyphosate-resistant were including glyphosate-resistant reported weeds entered of the alfalfa marketplace cases (RR) Roundup Ready at whenseveral atime the containment efforts. road,down complicating farmers’ for the opportunity the remainleaving germination years in soilfor can dormant years, seeds These per plant. of thousands ofseeds capablehundreds dispersing producers, of prolific seed are also relatives. ofthe weeds most genes challenging Some toherbicide-tolerant weedy andthe outcrossing of the chemical, spread seeds, ofnaturally resistanta particular weed Weeds it. would have exposure frequent killed resistance to reasons: develop for several application doseofachemical that anormal previously that survives aweed “superweed:” with (GM) Those who thecrops follow familiar term the debateare modified on genetically A Growing Threat to American Farmers Weeds Glyphosate-Resistant 50 Because leading weed scientists agree that many of these weeds that agree many scientists ofthese weeds weed leading Because 51 Glyphosate use alone has increased bymore than 700percent. increased Glyphosate usealone has 53

33 Evidence 34 Evidence Arkansas farmers as much as $500 million in inputs. in much $500million as as farmers Arkansas ( In 2005,glyphosate-resistant horseweed Glyphosate-Resistant Horseweed forced to doubletheircosts chemical to control resistant weeds. wouldreplace. Farmers technology are RR often companies claimed biotechnology chemicals must resorttofarmers more toxic andcostly very to chemicals control resistant weeds—the suggested rates ofglyphosate use, largely attributed to resistance the weeds. growing in with a50 percentin to 200 increase coupled been crops RR rapid has The adoptionof Combating Resistance Is Costly after years. useofglyphosate develops aloneforthat several glyphosate-resistant horseweed that conventional in commonly develop fields. such ryegrass, as crops nowinfest RR in moreglyphosate-resistant acres than prominent weeds resistant weeds, conventional in crop occur too. course, production, Of glyphosate-resistantStill, weeds substantially.the ofresistant development weeds extent the in U.S. crop plantings ofRR –more increased than acres 2006–has 100million in to resist the in world. glyphosate, engineered herbicide The genetically the most used widely andcottonto crops–are soybeans, –corn, most grown 2,4-D),someofour widely now somecrops areWhile naturally(for herbicides resistant example, to particular isresistant corn Conyza canadensis Conyza 58 An Arkansas extension AnArkansas agent reported: ), ormarestail, may have cost “If you’re Delta, the in Arkansas a resistant weed. One Arkansas Arkansas One a resistant weed. suggested rate often to fails kill eightthe times horseweed, asusceptible kill glyphosate will 2003. in up acres since itfirst showed infested has ahalf-million weed and adjust to it.” WeDelta. have to it with live spread overthe entire Arkansas Itspread ofthis will weed. will...Wesoon can’t stop the problem now,horseweed you and youdon’t have aresistant 54 57 At onestudy least confirms

60 Though a normal rate Thoughanormal of 59 The resistant 56 Now 55

of herbicides per year in California alone. California in year per of herbicides Policy estimates could result that alfalfa the in application 200,000pounds RR ofanadditional the National Center Infact, production. for alfalfa in Food andAgriculture used of chemicals islikely the to amount overalfalfa increase directly theProviding herbicides option ofspraying notrelying stand, onherbicides. ahealthy alfalfa to maintaining still appears be weeds, acreage. that were to herbicides reported applied less than 17percent ofU.S.specialist hay alfalfa In1998,aUniversity any producers if herbicides. usefew of WisconsinMany alfalfa weed Roundup Ready Alfalfa and Weed Resistance waterhemp,in glory, morning velvetleaf, cocklebur, ivyleaf, isgrowing. andlambsquarter ratethe normal ofglyphosate Missouri. in 10times survived which has andcommon ragweed, alreadyaproblem California, in ryegrass, resistance developing to are glyphosate. onlytwo include ofmany Others weeds pigweed and ifnot impossible, toeliminate once established. Horseweed difficult, resistance isvery year,Each more as that contenditisclear andmore farmers glyphosate-resistant with weeds, The ListKeeps Growing an extra $40ormore acre. per control before resistance even surfaced. “catastrophic,” glyphosate-resistant calls pigweed specialist to difficult was the weed because ofresistance highlevels toreported glyphosate (8to the 12times suggested rate). weed One have Carolina andNorth all Carolina, South Missouri, rate. Georgia, in Since 2005,scientists adosage ofglyphosate almost 10times the recommended survived 2005.Theweeds in Georgia in discovered was resistant pigweed The world’s population ofglyphosate-first than horseweed. farmers to American palmeri resistant Palmer amaranth ( glyphosate- believe scientists weed Some Glyphosate-Resistant Pigweed states,spreading rapidly, fourteen most in recently Nebraska. in documented been andhas infestations. dueto acreageoneyear glyphosate-resistant in no-till horseweed its more than andlost 50 percent, more than inputcosts. $35,000in saw by infestation reduced producer asevere hisyields with ofglyphosate-resistant horseweed ), or pigweed, isagreater threat ), orpigweed, 67 Thoughmore best figures recent are not approachavailable, farmers’ tomanaging Amaranthus 65 64 On average, resistant pigweed costs cotton average, On producers resistant pigweed 68 66

And the list keeps growing. Evidence for resistance Andthegrowing. list keeps “We can’t weed.” ofthis stopthespread —Arkansas Extension Agent—Arkansas 61 Tennessee lost 50percent of 62 The weed is Theweed

63 35 Evidence 36 Evidence nettle, henbit, cheeseweed, marestail, hairy fleabane, andfilaree. fleabane, marestail, hairy nettle, cheeseweed, henbit, malva, including weeds, alfalfa onsomeofthe glyphosate most isweak important because or not, rely surface whether glyphosate-resistant will herbicides onadditional alfalfa weeds RR resistance, andbarnyardgrass. developing too,lambsquarter including controlrates alfalfa. for RR in weed labeled at grass the proposed evidence thatThere glyphosateBermuda may isalso kill not year.”each nettleend ofthe field…Nowcansee allalong the field. you We’re moreseeing andmore nettle this study, westarted “When three years: there were nettle on four orfive plants stinging [one] for grown hadbeen where alfalfa nettles plots RR experimental ofstinging in thein prevalence ashift observed approved specialist for commercial sale. AUniversity weed ofCalifornia-Davis was beforeyears variety trials field the RRalfalfa in resistance Weed weed identified specialists alfalfa). in (notably,glyphosate to weeds control are alsoimportant someimportant someofthese weeds crops too.RR Inthe West, to conventional risks poses wheat producers whorely alfalfa on RR where don’t cropsrisks other are RR The produced. cropRR only butnon- concern rotations, throughout isgrown the U.S.,Alfalfa relatively well regions in as as crop cultivation, ofRR free will add to confidentthe for rotation selection RR alfalfa that resistant weeds. are scientists weed Leading rotate cropanother. with oneRR somegrowers will – mean soybeans with corn corn, with Common crop rotations –alfalfa glyphosate-resistant weeds. unidentified, well as as existing, exacerbate the problem ofalready to ofcrops iscertain line RR acreage crop, itto soadding the varieties. the U.S. were herbicide-tolerant and 52percent in planted ofcorn In 2007,91percent ofsoybeans 69 70 71 Alfalfa isamajor Alfalfa

72 Additional weeds found in alfalfa stands appear to appear be stands found alfalfa in Additional weeds 74 73 Farmers whoadopt outside cultivated fields. fields. cultivated outside outcrosses ortakes root feral alfalfa with RR alfalfa if and may effectiveness loseits alongroadsides ditches, andin feral alfalfa relatives. to Glyphosate control isalsoused weedy andits alfalfa volunteer managing have will trouble farmers andsoybeans, corn RR as landscape the in American pervasive as becomes alfalfa such IfRR crops, corn. as whenrotated other with RR itself, especially aproblematic could become weed alfalfa RR of the year. times at someregions in certain are (phenoxyherbicides banned such Dicamba) as herbicides, almost that twice ofglyphosate. of anEIQ approximately has thatDicamba on the environment, rates effect pesticides’ 28, Dicamba. are stands often more alfalfa toxic outRR taking such than 2,4-Dand glyphosate as herbicides, crop orderglyphosate with rotations. in to to remaining plants kill proceed At stand’s the endofanalfalfa life from (anywhere three to use twelve many years), farmers Volunteer RoundupReady Alfalfa alfalfa, even within specially designated areas.” within speciallydesignated alfalfa, even ofRR aftertherelease achieved be can threshold fortransgenic or plants seeds ofnature make tolerance’the forces itimpossible thata‘zero toguarantee “Human error, sub-standard and stewardship random practices, events, 76 78 According to Cornell University’s asystem (EIQ), Quotient EnvironmentalImpact —Allison Snow,—Allison Ph.D., flowatOhio Stateexpert Gene University 77 This is expected to pose problems in California where certain where pose problemsCalifornia certain in Thisis to expected Photo USDA Courtest

Alternatives for 37 Evidence 38 Evidence crops onmore from a13percent than acres, 2005(or 250million increase acres). 30million were GM. the in U.S. planted by2007,91percentIn 2000,54percent ofsoybeans were GMvarieties; certainty.”destination isa“virtual University ofManitoba their intended that concluded the movement of transgenesbeyond itis impossible. Some argue than difficult. and conventional separate throughout products proven supply the chain has food more co-exist can the growers ofeither,and conventional harming without seed transgenic keeping differentiationin the marketplace. argue companies that GMseed Although biotechnology Such contamination isproblematic andseed. pollen not onlyecologically, terms of but alsoin contribute both factors andhumanerror can to thespread unwanted Biological oftransgenic to andstand muchconcerns, notmore loseas –if –than organic producers somesituations. in course, Of conventional share farmers many cross-pollination. inadvertent ofthe same entered those the if traits crop crops through that even own their patented contain traits, companies effectively andseed biotechnology patented isofgreat concern, as genetic traits with associated Theissueliability of that to through took years develop breeding. seeds careful premium afforded prices risk of bynon-GMmarkets. integrity losing the also genetic Farmers losing including to organic farmers, to organic many crops problems poses crops (GM) from modified genetically transfer The fields. of genes neighboring –“genetic drift a new –from drift” organic producers are experiencing acrossborders, field transported Now,products. to addition in chemicals their area show their organic upin residues in applied ofchemicals where drift, pesticide with concerned haveOrganic farmers longbeen Crops Contamination by GM 81 More placeabroad, are too. GM planted GMplantings taking In2006, 22countries 80 79 Scientists from Santa Clara University andthe Clara from Santa Scientists certification service in North Dakota in North service certification —Farm organic VerifiedOrganic, it.” from free tosource America North seed in notpossible forfarmers itis believe we nowsopervasive, is commodities pollutionGM of American “The 82 GM food. are completely believe and,consequently, ofGMcrops, farmers free markets that in don’t want percentage oftransgenicmaterial. Asaresult, GMcrops continue to fields turnupin that from company each tested forfound ofnon-GM seeds positive that asmall allthe varieties and companies seed testedfromIowa, different varieties five four major seed conventional in Fairfield, organismbased (GMO) ID,facility testing Genetic areputable modified genetically companies have But done seed little to slow customers. contamination or educate their farming protection for future andmarket research demands. needs of ofGMcontamination—is need in level nodetectable with for breeding—seeds used varieties cropgreatly to contributed notes oftraditional contamination. The that report seed foundation andother crop), forms that ofhumanerror proving have mixing inadvertent open-pollinated (a mostly crop) were self-pollinated contaminated at to rates (an similar corn andlevels from GMvarieties. derived ofDNA sequences low levels contaminated with are that andconcluded pervasively the varieties andcanola, soybeans, corn, conditions under of to ensure strict (i.e., produced conventionalvarieties purity) of certified Scientists tested samples The Union of Concerned from the beginning. contaminated harvest whilenotaGMvariety, that, a seeds plant GMmaterial contain –ensuring unknowingly at often any stagefarmers ofproduction, non-GMseeds with mix GMseeds Not onlycan to the cause ofcontamination most appears be in ofthem. investigated, cross-pollination are Althoughmany ofthese notfully 2006thanrecorded cases in any (24events). other year cropsfive since GM continents werein 1996. introduced More were incidents contamination of GMcrops. Register, to aninitiative of contamination record byintentional incidents releases oraccidental aGMContamination launched In 2005,two international organizations non-governmental GM Contamination on the Rise organic for intended products. including cropsturn upin non-GMmarkets, andfood Still, GMmaterial continues to that alternativesas GMingredients. to products contain food organic systems, consumers certified in rely on organic products andfeed the useof GMseed industry.a $14billion country. ofthe such organic dairy, as by60percent sectors, someparts in growing someindividual with Agriculture (USDA) estimates the organic marketby20percent ormore isgrowing year, each industry. food ofthe American of the sectors The of fastest growing United StatesDepartment At one the organic market become the that sametime has increased, adoptionofGMcrops has 83 In just decades, the organic food industry grew from a grassroots movement into from agrassroots grew the industry organic food Injust decades, 85 The Register currently lists 142 cases of GM contamination in 43 countries on ofGM in 43 contamination countries cases The currently 142 Registerlists 84 Because the USDA notallow Because Nationaldoes (NOP) Organic Program 86

87 Interestingly, samples the soybean

39 Evidence 40 Evidence fined for sending the seeds without correct documentation. without correct the seeds for sending fined was the seeds, the company obtained from which originally UC-Davis scientists Seed, Seminis from genetic engineering. genes derived were contained Davis scientists unaware the seeds researchers 14countries. in researchers at twelve institutions the in U.S. andto mistakenlyscientists sent GMtomato to seeds Similarly, 2003,University in ofCalifornia-Davis breeding. in mistakenly used that was the variety unapproved GMcorn believes in Spain. Syngenta field in trials and used U.S., inadvertently to exported other countries, tonsthe in hundred were anddistributed grown approval.have Asaresult, several regulatory that not did variety aGM corn Syngenta anddistributed inadvertentlyfour produced years, to U.S.resources. breeding GMcorn anerror in In2004,Syngenta For reported authorities. the onlyroutes ofcontamination. At it’s times, mismanagement the companies’ own ofgenetic barges ocean companies—aren’t and to food trucks, and transport fieldselevators grain farm to Yet sources, travel—from andthe convoluted path contaminated seed seeds cross-pollination, shed. was seed after the years original germinate several from plants volunteer the shed crop the in andremainingsoil.Some dormant being of seed as a grown result cropwas show fields ormore upin –can ayear aftercultivation the original –crops that deliberate plants andvolunteer without persist andstorage equipment; harvesting getthrough mixed can transgenicand conventionalshared seed (i.e. bees); insects pollinating largely attributed or Transgenic to wind wind. via farm travel can from pollen aneighboring enterGM material can afarmer’s which is field drift, pesticide throughunlikeroutes, several 90 89 Apparently, the UC-

thebills.”now Ihavetopay can’tthat they manage and technology introduced “They’ve 88 Organic Farmer inNebraska 91 —David Vetter,—David been getting testedbeen ultimately have aroute to supply.” the food saidthe situation Scientists’ offersConcerned evidence…that“more allof these thatthings have aresultgoing outofbusinessas ofthe contamination. reach orexceed $1billion. more thaninvolving producers. 450rice lawsuitBayer against a filed including CropScience,class-action lawsuits havehundred been aresult 2006as in lost $2billion ofthe nearly contamination. the industry rice According to Greg Yielding, executive Growers Rice ofthe Association, director Arkansas research abandoned (Bayer 2001.) onLL601in CropScience ofGermany plots. experimental in variety after growing the made fiveyears the manufacturer was stopped this discovery from the exports U.S. rice long-grain receiving Shockingly, 29countries andin is grown, wayfound into its riceSouthern states the commercial supply five where rice in long-grain consumption, (which LL601rice tolerates glufosinate nameLiberty) trademark herbicides, supply,rice ofwhich half isexported. notapproved for the upin U.S. commercial variety In 2006,aGMrice saleshowed long-grain GM Rice Field Trials Devastate U.S. Exports to take years removewill from supply. the StarLink humanfood handlers. processors, andgrain more food than to $500million farmers, Harl,Neil E. aprofessor at Iowa State ofeconomics University, estimated that Aventis paid market for butwereby the declining StarLink U.S. hurt bythe contamination. caused corn 2003, Aventis to pay to $110million agreed settle from notgrow growers claims corn whodid the nation’s still pervaded from the contaminated market, grain and pulled supply. corn to eradicate Starlink. trying $1 billion makers processors, andfood spentmoreAfter than this farmers, discovery,companies, seed registered for positive the GMvariety. lessplanted than 0.4percent to oftheir corn StarLink. onlyapproved for livestock variety supply—a consumption. human food In1999,Iowa farmers more attentionreceived public ofAventis’ than the 2000discovery the in corn GMStarLink around thehas world, documented noevent have numerousWhile contaminationbeen events The StarLink Fiasco Lives On 102 The losses ruined many farmers’ enterprises, and some reported andsome reported enterprises, manyfarmers’ ruined Thelosses 99 94 93 Approved for butnot human field experimental trials Three years after StarLink was found in the food in supply the was found food after years Three StarLink 101 Total damages for may compensatory the plaintiffs 103 92 By harvest time, half the harvests the time,half harvests By harvest Margaret Mellon ofthe Union of 104 98

97 Experts agree that agree it Experts 100 Almost 200 Almost 95 In

41 Evidence 42 Evidence for GMmaterial organic in products. abroad, where have somecountries especially hismarket, zerocontamination tolerance limits andsaysClarkson’s technology” a“leaky President GMcrops as grain. Lynn describes Clarkson Despite GMmaterial these still precautions, contaminates 6percent varieties. about corn of crops through to areits scanner sort non-GM,anduses anoptical organic blueandwhite to measures Company ensure identity Grain takes strict preservation Clarkson Illinois-based $4,000. worth ofcorn load GM-free.as percent These 25 add tests about to Vetter’s bill. He $1,500 spent to seed corn test a Farmers musttest shoulder thetheir crops cost their seeds. to want oftesting guarantee they if fields. won’t dealers seed refuse because to purity—some their Vetterguarantee hisseeds tests Vetterplanting, attributes neighbors’ in GMcorn with the contamination to cross-pollination before ofhisseeds the purity heconfirmed Because contamination harvest. ofhis2000corn grower David VetterNebraska since 1997.He regularly GM discovered tested has hisseeds Contamination Across the United States, pages 44and45.) acrossGenetic the country. haverevealed events been (See contamination several this finding, tested shells taco corn organizations for ofnon-governmental coalition GMmaterial. For products. supply the after example, andfood in discovered food a was StarLink seeds environmental groups have investigated the extent ofGMcontamination conventional in andconsumer many and testing, farmers required thenever government has Because purity. to away far from ensure as China as seed seeds import Some their ability to producers now GM-free byhindering food find organicfarmers seed. U.S. burden onorganic contamination placesanunfair standards andconsumer demand.Seed organic onaccess to depend meet toOrganic GM-freevarieties farmers conventional seed unrealistic for that consumers are allorganicofGMmaterial. to aguarantee foods free expect andmakes it products, oforganic the food integrity isreducing varieties conventional seed However, organic. crops as to certify not required the inability to GMmaterial outof keep contaminationinadvertent sotesting ofcrops and food, for genetic material unwanted is The USDA’s butnot standards production standards, for NationalOrganic sets Program Organic Food Products Tests Reveal Widespread Contamination in 106 107

105 Since they arethey often to inadequate stop the For movement ofpollen. example, State Louisiana the submitted. requested information be require that butitcannot information request APHIS additional from can applicants, alfalfa. nature generalin andmayvery notappropriately RR including GMplant, address new each are enforceable. butthe notlegally guidelines measures, The arerecommendations also for including in fieldplants containment trials, recommendations APHIS provides growing permits. not were notifications, under regulated trials 97percent fieldabout in ofthe GMplants and may cover ofstates. any In2004, number amountofacreage include anunlimited can One notification begins. before afield trial anEnvironmentalAssessment not perform the APHIS notification). does of receiving days 30 for (within field conducting trials 1993. process forin apermit morereplaced than 85percentbeginning ofthe crops field in trials Most areunder APHIS’ field trials conducted system, notification process a that streamlined byAPHIS. regulation to allowtheir commercial further release without their varieties, areAfter field manufacturers crops trials conducted, ofGM may APHISpetition to deregulate oversight byUSDA’sThese plots require (APHIS). Service and Animal Plant Inspection Health before plots itis in commercialized. offieldexperimental A GMcrop years trials undergoes Government Oversight of Field Trials 108 Under the system, notification an APHIS simplyacknowledges applicant’s notification 109 110 Even APHIS’ if recommendations are followed, say they could never be kept.” be could never say they weren’t mightthey and you kept, and containment and segregation, weremadeabout “Promises

— Philip Regal, Biologist, Biologist, — Philip Regal,

University of Minnesota University ofMinnesota 43 Evidence 44 Evidence test.” where ofthem at andhowthewhat the crops grown, becomes endofthe are field being information the about field test sites it approves including andis responsible for monitoring, process The basic ofGMcrop andmonitoring fieldstudy trials. that concluded “lacks APHIS an on published In 2005,the General APHIS’ USDAReport Audit approval Office ofInspector contaminate their cropstheir knowledge. without don’tAnd farmers have accessunapprovedcrops socan GM to offield the trials, location no access to community. that information experiments about their own in may happening be “Confidential informationwithhold as BusinessInformation.” has the public cases, In these involvetrials offieldThe majority genes considered manufacturersproprietary, allowing to 47,000 testinvolved trials sitesThe field more spanning acres. than480,000 only3.6percent APHIS foroffieldapplications. trial rejecting 1987 and2004,criticized Interest Research fieldbetween more Group thanreleases 18,000authorized documented In2005, APHIS’the muchcriticism. oversight has ofthesereceived field Public trials U.S. crop,rice damages. potentiallycosting in billions prevent contamination. confinement recommendation considerably,implemented and other measures segregation to APHIS’ University exceeded they fieldclaim LL601(GMrice) whoconducted trials scientists     114

APHIS does not review notification applicants’ containment protocols, which describe protocols,containment which notification applicants’ describe notreview APHIS does Specifically, notes the that: report APHIS does not require permit holders to report on the final disposition ofGM disposition onthe holdersto final report notrequire permit APHIS does andnotification permit notwith APHISall does follow up field trials, After authorizing inThe planted the ofallGMfieldtrails locations exact U.S. known. are notalways test sites for overayear, APHIS’ orapproval. without knowledge storage in crops remained at ofGMpharmaceutical found field that two large harvests mayGeneral athreat pose to supply unintentionally TheInspector the if food released. and purposes for nonfood which crops, are and industrial modified pharmaceutical to proceed. trials field andallowing notifications before the in environment, acknowledging persisting tofrom plan the andprevent theit contain GMcrophow applicants field within trial atplanted all. holders to out find been exactly where ifplanted or they have been the fields have 111 Yet to led thecontamination of fieldthe entire trials long-grain U.S. 112 113

Roundup Ready Alfalfa: reimburse the USDA for the itcostto $3million thedestroy agency the co forto humanconsumption. headed Prodigeneandagreed a $250,000fine paid soybeans contaminating among grew the soybeans, field,from harvest andsomeof the corn the previous were later the in same planted Soybeans onlyto corn experimental after plowitunder itfailed. Prodigene, pigvaccine. experimental aTexas-based company, biotechnology the planted to that producebushels werean ofsoybeans engineered mistakenly corn with mixed Evidence for the problem alreadyexists. In2002,USDA ordered of500,000 the destruction contaminate will chemicals” supply. the humanfood [and]industrial enzymes to produce that pharmaceuticals, engineered “plants highprobability” thereto experts, isa“very create a catastrophic situation to, similar Accordingbut more than, serious the incident. StarLink way into andcould chain. Many the environments, food ofthese crops are open-air in produced such isathreatcrops, corn, as tosubstances find shouldtheir humanhealth pharmaceutical food in chemicals orother industrial ofdrugs production onmore thantrials 1,600acres 2007alone. in crop field andindustrial pharmaceutical authorized USDA chemicals. orindustrial drugs pharmaceutical to produce engineered crops—plants pharmaceutical forcrops unintended supply, the humanfood such as the in face ofexperimental alarming isespecially public informationlackThe trial offieldavailable to the Crops Pharmaceutical The Public Health Risk of USDA authorized pharmaceutical and industrial cropfield and pharmaceutical industrial authorized USDA trials on more than 1,600 acres in onmorethan2007. 1,600acres trials 115 The taminated soybeans. taminated 116

117 45 Evidence 46 Evidence Genetic Contamination without correct documentation. documentation. correct without the seeds for sending fined was the seeds, obtained which originally UC-Davis scientists the company from Seed, Seminis engineering. from genetic genes derived contained seeds the were UC-Davis scientists unaware the and to researchers Apparently, 14countries. in to researchers at twelve institutions the in U.S. mistakenlyscientists sent GMtomato seeds In 2003,University ofCalifornia-Davis California relatives.glyphosate onto weedy resistance its to orpass wanted spread towill where areas itisnot the grass Forest worry Service, the U.S. including (EIS). Critics, StatementEnvironmental Impact is thecrop first GM undergoto an byUSDA, and undergoing review isstill bentgrass 2007. GMcreeping the environment November in in from persisting bentgrass RR a $500,000fine failing to prevent for Scottsordered TheCompany payto Jefferson County,Oregon. USDA in traveled 13milesfrom field trials CompanyScotts andMonsanto, byThe developed GM turfgrass a bentgrass, creeping (RR) Ready from Roundup In 2004,pollen Oregon at 900feet. these were distances segregation tests, set from the nearestfield. RR At of the time two planted miles was foundation seed The stock. ituselessto seed as deem enoughtransgenicmaterial contained which Idaho, foundation including seed, Wyoming, Montana, in and seed alfalfa were found conventional traits in alfalfa that RR reported Association Clover Seed and 2006,the Idaho Alfalfa In December Idaho, Montana, Wyoming gene flow was percent was found geneat 83 flowsites. of the collection fields. seed hayof active RR alfalfa within fieldsTransgenictwo milesof Mesain County,edges and fields, abandoned alongroadsides, Colorado StateColorado University at Extension 23sites testedplants feral alfalfa Colorado of 50percent. contamination levels gardens trees—showed backyard orwild percent the from balance from organic farms, papaya seeds—80 ofcontamination. the 20,000 On BigIsland,nearly levels soldbythe University ofHawaiiNon-GM seeds alsoshowed Oahu,the BigIsland,andKauai. on three Hawaiian islands: contaminated conventionalhas andorganic papaya trees Virus-resistant the firstbe GM tree papaya, commercialized, to Hawaii event costevent Terra $200,000. Prima material the The in chips. contamination transgenic distributors revealed and UK chipsorganic tortilla after European destroyed more of than 87,000bags In 1998,Terra and recalled Prima Texas Agriculture SustainablePlains In 2002,the Northern DakotaNorth conventional farmers. conventional farmers. who sell to organic and seed registered certified todistributed growers of was contaminated seed variety. oftheseed Some foundation soybean StateDakota University contamination of a North discovered Society

Across the United States billion in damages. in billion lost $2 nearly riceindustry The to 30countries. nearly supply, andfood contaminated the seed exports including pervasively variety ricein 2001,yet the ofLL601 field trials states. Bayer producing rice CropScience abandoned grain commercial supply, rice long- Southern allfive including In 2006,thein U.S. the variety riceunapproved an identified and Texas Louisiana, Arkansas, Missouri, Mississippi, refuse to test their seeds. the purity—some guarantee won’t dealers seed because seeds fields. neighbors’ Vetter his tests in GMcorn with pollination the contamination to cross- Vetterplanting, attributes before ofhisseeds the purity he confirmed Because harvest. contamination ofhis2000corn since Bt 1997,anddiscovered regularly testedhas hisseeds grower DavidVetterNebraska Nebraska contamination. market for U.S. bythe caused corn bythe declining growerscorn hurt pay to $110million settle from claims supply.food In2003,Aventis to agreed to from the eradicate StarLink trying marketers spentmore than $1billion processors, andfood farmers, companies, Seed Iowa harvest. corn – contaminated 50percent ofthe not approved for humanconsumption –aGMvariety corn In 1999,StarLink Iowa instead of destroying them. theto pigs released alivestock dealer,Champaign The Universityat ofIllinois piglets. in Urbana/ more milkandaprotein that improves digestion to produce engineered were ofGMpigs offspring to the U.S. Administration, Food andDrug the pigs maypigs have entered supply. the food According In 2003,the Illinois contaminated seed. isresponsible for thedrift presence rather than ofthe trait, ofcontamination the indicates lowlevel that pollen report, transgenic material oneofthe According in samples. to the Vermont in 12 farms for genetic contamination anddiscovered The Interest Public Vermont Research Group fromtested corn Vermont New YorkNew Times similar to diabetic blindness. tosimilar diabetic disorder a to develop were Thepigs engineered funeral. at into a sausage, turned lab technician, andthen served wereGM pigs stolen from the University bya ofFlorida Florida

reported that 365GM reported 47 Evidence 48 Profiles and begin growing again. “It’s again. growing forand begin mechanism the species.” asurvival could germinate isbrought hard thehard back to RR seed seed through the surface plowing, into couldthat and,if remain the for the ground, dormant deep hard years, isplowed seed seed for remainexplaining germinating IfRR the without can in ground that many years. hard seed ishard seed,” –upto seed high percentage 50percent says, ofhard ofalfalfa seed Geertson crop aperennial that grows“Not onlyisalfalfa for a upto has ormore, eight years alfalfa gone forever.” explains. “AlfalfaGeertson be itwill weknow as it’senvironment, there—it everything,” get in will “Once the isin alfalfa] [Roundup Ready non-GM crop. forimpossible conventional to grow farmers a will make it variety (GM) modified genetically andfears the years, for several alfalfa (RR) Ready the ofRoundup about development concerned across forage the farmers U.S.alfalfa He been has ofGeertson’s Aspart to 20 years. hetalks work, for program more than breeding aplant with growers for worked more andhas than 30years, forage to directly alfalfa Farms soldseed has Seed the that Geertson land homesteaded. hisfamily 1939andhisbrother in still farms beginning seed international alfalfa Hisfather markets. grew for domestic both and seed ofalfalfa varieties six Farms, anOregon businessthat produces Seed andoperates Geertson owns Phillip Geertson Adrian, Oregon Phillip Geertson -

grievous in my in opinion.”grievous explains. “They’re putting out something there thatcan’t you Geertson and that’s recall, “I’m notagainst the technology, butyouhave to to contained,” –ithas useitcarefully be that zero has tolerancecountry for GMseed,” hesays. to contamination“Idon’t concerns. from the U.S. seed alfalfa to feel comfortable sending a customers this year, Zealand to hisNew notto seed sell due alfalfa decided Geertson In fact, gene,”RR explains. Geertson the contaminated with notaccept alfalfa will “Most growers. seed foreign buyersofalfalfa seed the in U.S.He fears alfalfa that destroy RR planting market will the for foreign American seed grown.” impossible,” nearly be will “It make says, will itsoit’s adding, Geertson plant the onlyalfalfa in the seed U.S. that of free alfalfa contamination is Raising fields. to seed conventional alfalfa “If the gene Roundup Ready spreads transfer the eventually alongroads, to gene will feral alfalfa difficult. Andthemore nature perennial makes even the GMtrait. GMtrait containing ofalfalfa spread produce will they the seeds (even just oneplant), plants alfalfa are the in hedgerow. Ifthese are RR miss orthatare farmers always plants thereand third He cuttings. believes though hard to second find—with there someseed— always be will butthat noseed, has cutting ofalfalfa explains that the first Geertson years.” short a few just in contaminate alfalfa allnon-RR will am confident RR alfalfa that grower for more I than 20years, onmy experience analfalfa as “Based 49 Profiles 50 Evidence (GM) seed and feed in certified organic farming systems, cross-pollination of RR alfalfa with RR alfalfa of systems,cross-pollination organicfarming certified in andfeed (GM) seed notallow the modified the useof genetically National does (NOP) Organic Program Because breeding. organic in seed andconventionalused alfalfa loss ofconsumer confidence and loss andhigherprices of genetic for consumers; resources potential andloss costlyof markets; efforts eradication consequences: producers serious risk makes way into organic market, its alfalfa alfalfa the organic (RR) If Roundup alfalfa Ready miles ormore. pollinator,wild a common bees, andbumble fields, agricultural in areto travel five reported pollinatorscontribute commercial well. andwild to Both as gene flow transported sometimes from transferonecrop pollen to the next, bees genetic When material is alfalfa. in setting seed plant fromto thethe flowersofanother,pollen flowersofonealfalfa for necessary a process for andtransfer pollen food collect whenbees occurs Cross-pollination plants. their alfalfa to pollinate leafcutter bees, producers rely andhoney especially onpollinators, seed Alfalfa 4percent. byabout isonlygrowing feed, 20percent year, each growing whileU.S. andother corn oforganic including production crops, ofthe Organic Trade member board Clarkson, the demandforis Association, organic feed for hay. more organic aneed alfalfa with this coupled demand isimplicitly organic market. ofthe the U.S. oneofthe segments fastest growing oforganic milk, ashortage experienced barley, andalfalfa. oforganic soybeans, production corn, toDakota peas, increase to North andislooking markets, demandfor rapidlyorganic growing livestockits andpoultry to meet America andSouth from China organic feed currently imports California growing. 1997and2003. percent between by572 increased lambs, cattle, and beef sheep pigs, including organiclivestock, of certified in 2001.Thenumber organic animals total more ofcertified than ofthe half total number isanessential componentthe in organic livestock industry.Alfalfa cows accounted Milk for Organic Alfalfa at Risk?Is Conventional & 120 While the shortage is attributed primarily to a lack of certified organic cows, to isattributedalack ofcertified the shortage While primarily 118 And the demand for alfalfa-derived organic products is organic products Andthe demand for alfalfa-derived 122 121 According to Lynn 119 In2005, Crop-to-Crop Gene Flow recent to past grow completely conventional uncontaminated alfalfa.” crop in itis“simplythe as aseed grown Shock, to unfeasible useafieldRR alfalfa that had has 43 to content. 71percent hard seed trials field averaged RR alfalfa some field.fact, In analfalfa in produced ofthe total seed portion fields andalfalfa. for flow alfalfa feral pollen to surrounding are potentialsources for complicating control the reintroduction measures oftransgenictraits, later,populationsyears alfalfa Thesevolunteer plants. to alfalfa volunteer unwanted leading germination. to start entering the seed coat that water keeps from seed content. are buthave “Hard viable seed” animpervious seeds” stand. analfalfa ofcrops yields succeeding limiting Volunteer including plants, may alfalfa present unwanted alfalfa problems managing serious in fields. vehicles forinto alsobecome pollen trait gene flowby conventional nearby spreading ororganic outcrosseswith RR alfalfa alfalfa. feral if ineffective thatCounty crews useglyphosate to find the herbicide control these will in areas feral alfalfa ditches.in and along offields, onthe edges established roads, to plants trait these feral alfalfa throughother human care, crops that such Pollinators corn. onlysurvive as transfer the can RR unlike aweed, often as the times humancultivation, in environment outside persists Alfalfa Crop-to-Wild GeneFlow Monsanto). this (in case, GM traits orontheGM crops, patent of owners whoplant notonneighbors GM crops, fields isentirely onproducers ofnon- organic and conventional certified transgenicmaterial outof of keeping the burden So, crops. neighbors’ with buffer areas to cross-pollination avoid to create seeds RR whoplant farmers producers. hay compared to conventional 10 to 50percent premium for their markets affordalfalfa producers a Organic profits farmers. for non-GM costs andreduce production increase conventional andorganic crops could 123 USDA notrequire does 128 According to Oregon State University scientist Clinton 126 Hard seeds may Hard germinate seeds oreven late the in season 125 124 All alfalfa has a certain percentage of “hard acertain has alfalfa All Feral alfalfa plants that Feral plants acquire the RR alfalfa 127 Hard seed makes up a significant makes Hard up asignificant seed

129 51 Evidence 52 Evidence haypollen. afterviable is cut flowershave alreadyproduced insist that most production. RR alfalfa alfalfa of grown fields for seed opponents Furthermore, hay time,orto to at ensure harvest acertain farmers that their fields arefrom isolated alfalfa there requirement practices, for is nolegal growing recommended acknowledging a contract control schedule. signs cannot farmer if a Even weather harvest their orother factors affecting smallpercentagethey bloom, orat avery blooms before alfalfa harvest producers typically production.”from flow hay potential pollen seed minimize to common alfalfa “at hay harvested simply recommends that be alfalfa orbefore RR 10percent to bloom TUG strategies to to the The transfertrait limit oftheconventional RR andorganic alfalfa. notrequire growers to butdoes contribute implement containment to cross-pollination, Monsanto’sand containment measures. Technology factors that outlines Use (TUG) Guide restrictions planting bythe concerns absence are alfalfa Cross-pollination compounded ofRR produced. are cultivars anarea in where grown contaminated GMalfalfa if wouldnotbe a non-GMplant miles. more trait the than transferred RR 2.5 byForagefoundconducted bees that honey Genetics or hayunlikelybe currentpractices. fields production production wouldusing seed andfound that alfalfa complete within drift pollen containment oftransgenictraits alfalfa before forageyears the hitthe Researchers new market. atState Kansas University studied field in andconventional trials alfalfa alfalfa RR between recorded cross-pollination Scientists destroyed market the has organic Canada. canola in GM canola Committeeby the Standing onAgriculture andForestry Canada. in 1995),according in to GMcanola areport growing began (Canada toopposition GMproducts zero” 1994,but is now“virtually in $425million ofthe EU’s was because canola Canadian year. each isexported canola 75percent nearly as ofCanadian genetic marketsengineering, thatnegatively impacted reject makes extremely controlling traits canola volunteer of transgeniccanola has also It difficult. canola. of three different with varieties GM andassociated companies, are bydifferent resistant seasons subsequent to glyphosate), owned three herbicides(including in volunteering plants growers nowfind thatcanola Canadian canola, herbicide-tolerant of Afterthree different be. planting cropsvarieties can extensive between cross-pollination Canada’s crop) shows how (another insect-pollinated experience transgeniccanola with overlooked. be cannot conventional alfalfa to the organic livestockimportance andorganic industry, and RR contamination between alfalfa’s Considering alfalfa. contamination risk byRR andfeed GMmaterial seeds outright in andhay that seed shun markets fororreject alfalfa isinsect-pollinated, alfalfa Because 135 AndaWashington that State University to difficult agronomist certify saiditwouldbe 136

131 For example, the European export market Union for (EU) 138 So, while cross-pollination whilecross-pollination So, 133 132 Many farmers argue that argue Many farmers 130 This rampant This spread 137 134 While hay While Field trials states. Pollen drift may have occurred (and may still occur) during RR alfalfa field trials, and field trials, states. alfalfa Pollen RR may (and may during have still drift occur) occurred currently is among 35 the inleast planted at Alfalfa top cropsnotification. ten trials, in field Monsanto asingle states under acreage the forbecause total combined proposed lists several 435 acres. The was wereacreagenotifications ordenied.) withdrawn average trials either of these field (According to the Information ofthese Systems onlyseven database, for Biotechnology 1998and2005. between Monsantotrials field APHIS ofmoreRR alfalfa notified than 300 less than oneyear. sources overtime. seed infiltrate non-RR it’s precautions, andvoluntary stewardship guidelines would likely trait that alfalfa the RR distance. Dr.with Snow, Allison anexpert ongene flow, clear with very even thatconcluded andcontaminationdistances levels. correspondence demonstrate data between andCSU apoor thecontamination. IASCA Both thatshown distances has isolation donotprevent RR alfalfa The commercial of release sites. collection fields. seed alfalfa was two percent milesofRR foundwithin Transgenic at83 gene flow of the Mesain County,edges hay ofactive and fields, fields Colorado, abandoned alongroadsides, The sameyear,Extension StateColorado at 23sites plants tested University alfalfa (CSU) feral from 0.2percent toranging 0.4percent to at of900feet distances 1.5miles. sites, Of contamination ten eleven showed plantings. mandated RR alfalfa for specifically field. RR distancesAt ofwere segregation distancethe time these –a set at 900 tests, Idaho feet from planted two miles was the nearest The seed foundation stock. ituselessto seed as deem enoughtransgenicmaterial Wyoming, which contained andIdaho, foundation including seed, Montana, in found seed conventional in was alfalfa trait that alfalfa the reported RR (IASCA) Association Clover andSeed 2006,the Idahocommercially Alfalfa available. InDecember was variety contaminated the conventionalthe GM first year alfalfa alfalfa RR In fact, entirely.” prevented be cannot field the borders ofanindividual isolation andcontrol beyond movement ofpollen pollination, extension “standards andnotes growing agent if that agrees, even to modify are revised thatpractices may not allowadequateisolation distances.” production ofseed the “most because expert, likely seed purchased contamination in could be have production already inadequate. proved According seed alfalfa Isolation in distances to one producers toconcern forwhowant avoid alfalfa alfalfa. RR itis fields, production stillaserious seed hay alfalfa fieldsriskbetween islessbetween ofa than 144 It determineacreagelocationstrials, of the to these isdifficult and total field 141

140 142 That is, contamination levels did not always decline did notalways decline Thatcontamination levels is, 143 As the data above indicates, this indicates, “infiltration” Astheabove data took

139

AUniversity ofCalifornia 53 Evidence 54 Evidence products. cross-pollinate does not bode well for an industry that depends on foreign customers wary of GM controversial, because both alfalfa farmers and export businesses know that alfalfa’s ability to GM-free product. Growing RR alfalfa in areas where alfalfa is largely produced for export is very GM crops and food are just as concerned as organic farmers about their ability to provide a and harvests that are free of transgenic material. Farmers who export to countries that shun Both organic farmers and conventional farmers who export to sensitive markets rely on seeds Industry Export test for presence.” its ontheor sprout market be andthat market GMOwill might that have they knows analfalfa to Accordingtransgenic material their products). in “it to oneexpert, isquestionable the if health aware of costs sprouts be GM-free providing andadded as(such ofthe difficulty testing for off their As shelves. these markets continue GM ingredients grow,to sproutgrowers should Trader including chains, retail Joe’s, Wild Foods, are andWhole committed Oats, to keeping market orare marketing considering theirorganic sprouts orGM-free. as Many large food for producers alarming who This isespecially adopted. widely be sources alfalfa should RR towho wish stayimpossible,seed itlocate find GM-free ifnot extremely will to pure difficult, environment andmarketplace sources. Sprout GM-free producers could limit seed eventually into the alfalfa RR tointroducing marketed directly sprout being without because growers, for the However, ofsprouts. production couldthe affect sproutingindustry seed alfalfa RR benefits. stores sprouts item oftheir many are food health nutritional in apopular Alfalfa because Sprout Industry fiveofwhich pending. fieldare trials, alfalfa RR new APHIS of25 In2007, notified Genetics farmers. Forage to affected fieldsunbeknownst alfalfa entered organic orother conventional likely alfalfa RR their communities, in trials field of areexperimental notnotified farmers cover thousands ofacres). Because (morefield trials potentiallythan 40,which alfalfa hay most the well RR second as ,as organicmost alfalfa acreage for certified Forconducted. example, the Idaho boasts onwhere were the field depending trials this time, fieldsconventional during alfalfa could havecertainly entered organic and 146 Monsanto’s 2007Technology planted be cannot Use says seed Guide that alfalfa RR 147

—Chep Gauntt, —Chep WashingtonPresident, market.”export thechancestand oflosing all ofour acceptit...We will Japanese customer possibleis no way thatthe “There 145 State Hay Growers Association import approval from some important export markets. approval from someimportant import Monsanto the final andForage removed domestic after userequirements receiving Genetics forgrown domestic useonly, approval. 2006, international InFebruary regulatory pending to addition to (in the Technology sign be could Agreement). said The RR alfalfa thatcontract Launch,” Domestic implemented a“Limited growers had that contract alfalfa anadditional RR Monsanto approved hadnot yet exportthe countries GMforage for important import. first someof themostapproved was for commercial saleandplanting, alfalfa RR When place. in framework regulatory current Mostglobe. ofthese have countries azero alsoindicated tolerance for GMmaterial orhave no year,Each to $40 million worth more than theacross 30countries U.S. the seed alfalfa exports foreignnon-GM products), customers continue to demandzero tolerance for alfalfa. RR a5percent has tolerance for byforeigntolerance GMmaterial set (Japan in level governments Japanese customers GMmaterial their forage donotwant in products. Centro, California. be over,”coming will products modified no genetically saidJeff Plourd El of El in Toro Export that go it. with andproblems theof in U.S.,politics because told alfalfa that reporters RR notwant hedid Mark Anderson ofAndersonHay oneofthe largest Inc., hay andGrain companies exporting this reason. exportfor companies submitted commentsto toalfalfa public APHISopposition RR in tolerance for hay GMOsin products.” hayof the customers alfalfa have alow indicated customer thangovernment approval. with Most “the issuesit, are more the ofaconcern with GMforage.do notwant companies andproducers insist their customers many from U.S. these governments, alfalfa export approval for have RR import received Genetics Canada. Korea,include South Taiwan, Mexico, and ayear). million exportpercent market ofthe (around alfalfa $500 mostlyexported, to Japan, which accounts for 75 while5percent is feed, animal as domestically thein western U.S. Most U.S. isused alfalfa from exported the U.S. allalfalfa Nearly isgrown 149 Even though Monsanto andForage 152 153 148 “Some of our Japanese ofour “Some haysaying customers usto documents are sign asking Other alfalfa export countries export countries alfalfa Other 154 Many other alfalfa processors Many andexporters other alfalfa have that indicated their 150 Asoneexpert put 151 Several Several 156

155

So, regardless So, ofany 55 Evidence 56 Action Five Things to increase. andmeat products oforganic prices dairy expect consumers can shortages, to orimpossible find. limited be supplies will GM feed non- andcanola, corn, andfollows soybeans, adopted iswidely theofRR precedent alfalfa that transgenictraits. notcontain any itdoes with unable guarantee to purchase grain “natural” Some producers whoprefer are beef currently alfalfa. non-GMfeed avoiding RR organic producers andhayCertified ranchers and mayexporters be farmers the only not Non-GM Shortages Washington State thousands ofjobs. to hay lendsupport growers’ concerns. wheat, which ultimatelyof GMwheat, forced Monsanto toand marketRR efforts todevelop drop its encephalopathy andJapan’s ormadcowspongiform (BSE), disease, response to the prospect byJapan response 2003and2006in embargosto in imposed bovine the beef including stop ofmarket purchasing allU.S. rejection, cases outofcontamination Similar fears. alfalfa to Japan alfalfa in $140million year.about each growers Basin export and Columbia the Northwest, in Pacific byvolume export commodity among hay exportersbe lost. that would Rim the their markets in Pacific the state, the twofears companies tension andhay causing between andincreasing growers, of someparts salesin with But Monsanto forward onmoving andForageinsisted Genetics Washington in theselling GMvariety accepted the customers technology. untilits overseas that andasked Monsanto alfalfa release ofRR immediate andForageholdoffon Genetics The imports. Washington State Hay Growers a strong Association took against stance the Even government approvals, however, with customers abroad GMalfalfa to continued reject Photo Courtesy EckenbergPhoto Farms Courtesy inthe U.S. the ofalfalfa Eckenberg exporter largest Farms,

160 159 Losing the alfalfa export market the could alfalfa cost Losing Growers fear that Japanese customers will 162 In the event of organic alfalfa hay oforganic Inthealfalfa event

158 Hay isthe largest 161 If RR IfRR 157

Ready alfalfa.”Ready to notwant buyRoundup does anddairymen, cooperatives, agricultural importers, including approvedgovernment the has alfalfa,” saleofRoundup Ready Evans says, “Japan’s marketplace, industry. in“While the export concerns theraises alfalfa serious Japanese (GM) alfalfa modified According to Brent Evans, international salesmanager for Eckenberg Farms, genetically of Seattle andTacoma for onthese exports jobs. depend directly laborers and ports at drivers, workers,the truck Thousandsofagricultural $150million. nearly make 40percent up about ofthe income from hayExports Washington, in produced at valued Taiwan consume the balance. Koreavolume, andSouth and of Eckenberg Farms’ export Japan accounts for 70percent year. per containers moretotaling than 50,00040-ft largest export from the state, Washington Eastern in isthe hay from farms basis, volume year. business–each in a On –$25million containers 40-ft moreand exports than 5,500 150,000 tons ofhay annually company buysmore than The the Northwest. Pacific in of farmers from hundreds andpurchasing hay people 100 nearly nation, employing hayexporter the in ofalfalfa Eckenberg Farms isthe largest Mattawa, Washington FarmsEckenberg - ocean-going containers. Photo Courtesy Eckenberg PhotoFarms containers. Courtesy ocean-going that andcompress resize densityin hay maximum to achieve large compressing requires machines bales double-compressed Making andstoragecomplex facilities. bagging production, large, requires ofhay Production cubes ofsizes. inavariety bales inJapan double-compressed andas industry the compound feed in used inthe ofhay form Eckenberg alfalfa cubes Farms exports

57 Profiles 58 Profiles jobs in Washington in jobs State.” constitutes alfalfa “Roundup Ready areal threatbegins, to businessandto our thousands of to study into andperhapsintroduction accept Japan. its “As however,” nowstand, things Evans for if Japanese noother than reason to its safety give customers alfalfa, ofRoundup Ready time Evans says that hiscompany research welcomes further onthe andenvironmental science Washington to listen unwilling to State andseems us.” hay industry address customers’ our concerns,” Evans explains. “ButMonsanto the concerns ofthe ignored We markets accepted Asian it. our Monsanto asked even to accompany usto Japan to help “We Monsanto asked to Washington delay in the alfalfa saleofRoundup Ready State until are unfounded. variety alfalfa marketplace. Monsanto’s He believes statements that Japanese GM customers accept its will ofJapanese theEvans, power Japanunderstands whoworked in customers the years, in for six State andonthe state’s hay industry economy, notMonsanto.” on the shoulders of the fall primarily ofwill suchconsequences a “The reaction Washington or,could cripple theentirely in worst case, stop ofallWashington exports to State Japan.” alfalfa that to fears reaction asevere the alfalfa ofRoundup Ready words, introduction “Our industry the encephalopathy in U.S. ormadcow spongiform (BSE), disease, Inhis ofbovine discovery toEvans similar Japan’s fears to areaction alfalfa Roundup Ready embargo the following beef wanted.” transfer thepollinators can GMgene where andother into populations itisnot feral alfalfa for Statement] as an[EnvironmentalImpact to assess containment alfalfa, ofRoundup Ready or Australia.with issues propagation “The real,” are very makesEvans clear. need “There isa alonemay to sendJapanContaminated alfalfa other for countries looking hay, such Canada as don’t farmers largest its Eckenberg if its market losing Farms even risks GMalfalfa. plant should nothave the costs tooftestingindustry bear for contamination. certificates will notbuyor that alfalfa,”ship weRoundup Ready that his emphasizing headds, and Evans usto ofthese companies explains.provide guarantees haverequired “Some even constitute into andother easily hays Japan,”collectively ofthe majority alfalfa imported the vast from Eckenberg alfalfa Roundup Farms Ready exporters. These companies orother American import will not havecompanies “The thatto whichindicated all we alfalfa they export Five Things Roundup Ready Alfalfaabout the Risks of a Farmer Can Do 2. Talk orsuppliers about dealer andhay seed customers, andyour seed to neighbors, your 1. 5. 4. 3. Call USDA’sCall toll-free number, is 866-724-6408,to outwhere find alfalfa Roundup Ready the risks of Roundup Ready alfalfa. ofRoundup Ready the risks Write about andranchpublications andfarm letters papers to local ofyour the editor genetic contamination. andstate thatAsk representatives local from your protect farmers policies to support field trials. alfalfa growers from genetic contamination thatalfalfa might result from Roundup Ready Write aletter to state your Agriculture Commissioner, the andask state to protect youbuyisGM-free. the seed guarantee fieldsin their county. alfalfa Roundup Ready for locating dealer to Ask seed your Tell alfalfa. Roundup Ready ofadopting the risks them USDA’s about toll-free number area. your in grown being

59 Action 60 Action Roundup Ready Alfalfaabout the Risks of a Consumer Can Do 1. 5. 4. 3. 2. Tell co-op your orsupermarketyoudon’t from GM alfalfa. derived products want worc.org. worc.org. upto for Sign receive comment. updates at public opportunities and there www. be will soon, A court-ordered begin Statement will EnvironmentalImpact (EIS)for alfalfa RR alfalfa. ofRoundup Ready risks Write andconsumerthe letters about publications papers to local ofyour the editor food. from genetic contamination toprotect right farmers andprotect GM-free your choose Write letters andstate to representatives.that local your Ask thempolicies to support from GMalfalfa. derived them products you donotwant Write letters processors, toproducers andtell andfood ortalk dairy, andhoney beef, markets that toSupport pledge avoid GMingredients.

have no way to tell.” derived from GM alfalfa,” she explains. “I could buy milk or meat from animals fed GM alfalfa and I Cox also notes the absence of labeling for GM food ingredients. “I cannot tell if the foods I eat are alfalfa to be released into the environment without restrictions,” she says. unaddressed by the U.S. government. “I cannot believe that the USDA and EPA are allowing GM in Sonoma County, as she believes there are environmental and health concerns that remain member of the California State Beekeeping Association. She actively opposes GM crop cultivation Cox is a past president and vice president of the Sonoma County Beekeepers’ Association and a with the spread of GM alfalfa.” customers demand natural raw honey and they do not want any chemicals, so I will lose business contaminate my bees and hives, especially if glyphosate gets into the water that my bees drink. My we do not use any chemicals in the bee hives. The use of Roundup Ready alfalfa in the area could “We produce honey in a manner that I call ‘Beyond Organic,’” Cox says. “As part of this method, herbicides to enter the environment, increasing exposure to her and her bees. In addition to cross-pollination concerns, Cox is afraid that GM alfalfa will cause more glyphosate pollen or nectar containing GM material could contaminate my honey and weaken or kill my bees.” my bees may forage on or in the vicinity of GM alfalfa. If my bees forage on Roundup Ready alfalfa, miles away from their hives, I am concerned that Cox explains. “Because they forage up to five square “We keep the bees in twenty different locations,” area farmers’ markets and her farm stand. and backyard hives. Cox also sells honey at three breeds and sells queen bees for both pollination five years. In addition to raisingbees for honey, Cox Kathy Cox has owned BloomfieldBees Honey for California Bees Honey - Sebastopol, Kathy Cox, Bloomfield 61 Profiles 62 Action alfalfa. alfalfa. there area, to your non-GM in are your risks isgrowing steps take to youcan alfalfa minimize If youare aconventional producer whodiscovers that ororganic alfalfa (RR) Roundup Ready Alfalfa?Ready Roundup Planted What ifMy Neighbor   verify seed purity. seed verify before andhay to planting growers should considerseed seed testing their alfalfa Alfalfa purity. producer, seed If youare analfalfa to consider ensure testing harvest genetic your  not used for alfalfa. RR not used sure andspace was the equipment orshare be storagetrucking, units, or conditioning, seed harvesting,  fields. neighboring with pollination other to measures prevent cross- buffer or planted areas they took GM-free. Ask these growers if to remainit isfor alfalfa your Communicate howimportant alfalfa. RR rancher growing If youshare for equipment Talk to or the farmer Testing Alfalfa          there will be opportunities for public comment. Sign up to receive updates at www.worc.org. A court-ordered Environmental Impact Statement (EIS) for RR alfalfa will begin soon, and neighbors if they’ve identified weed resistance in their fields. Watch for glyphosate-resistant weeds that migrate from neighboring fields. Ask your about the economic and environmental risks of GM alfalfa. Be vocal in RR alfalfa discussions. Talk to your neighbors and other community members tested. documents that classify your product as “GM-free,” especially if the product has not been Know your customers and understand any contracts you sign. Be careful when signing them about the issues involved in adopting RR alfalfa. Make sure your customers are aware of your efforts to maintain GM-free products. Talk to liability risks. documents will help pinpoint the cause or point of contamination, and help protect you from alfalfa from cross-pollinating with neighboring plants. Should contamination occur, your Keep careful records of your sampling, testing, and any measures you take to protect your instructions, visit these two links: gene in conventional alfalfa at a level of 5 percent or more. For ordering information and the presence of RR alfalfa in haystacks, hay fields, and seed. The tests can identify the RR Forage Genetics and Monsanto selected two companies to develop test kits for determining confirm. they contain at least a small percentage of the RR trait. You can use one of the tests below to quarter- or half-acre) and spraying it with glyphosate. If one or two plants survive, it is likely If you use glyphosate in your operation, test your alfalfa seed by planting a small plot (a manufacturer, germination rate, weed seed content, and other information about the variety. of your seed and hay for your records. If you purchase seed, save the tag, which lists the Conventional alfalfa may be contaminated by RR alfalfa at low levels. Always save a sample Strategic Diagnostics Inc. EnviroLogix – http://www.envirologix.com/library/AS045AHF.pdf – http://www.sdix.com/ProductSpecs.asp?nProductID=19

63 Resources 64 Resources signing Monsanto’ssigning Technology Agreement. accept when farmers limitations isalist ofobligations andlegal Below the GMtrait. containing greater facechallenges crop,even isaperennial farmers in alfalfa (RR) Roundup Ready Because GMcrops. involving andmarket rejection contamination with events associated records, andshields andpersonal oftheir private property to Monsanto invasions from liability enforces aTechnology uselicense” farmers a“limited called This subjects contract Agreement. To the purchases seeds. andplants after afarmer even seeds Monsanto patent protect its rights, Patents ornot. afford grow GMseeds whether they Monsanto GM ofits farmers, ownership Liability for the spread ofMonsanto’s threat isaserious to all (GM) seeds modified genetically Technology Use Guide Monsanto’s Understanding at www.rafiusa.org/pubs/Farmers_Guide_to_GMOs.pdf ofMonsanto’soverview Technology which from their isdrawn Farmers’ Agreement, to available Guide GMOs,    

Farmers cannot save any seed grown from Monsanto’s Farmers grown save cannot any seed to orprovide any seed seeds Farmers to may settle required disputes be alllegal Monsanto concerning Louis, St. in Farmers the Technology whosign the under Federal alloftheir rights Agreement waive Farmers accept allthe terms ofthe Technology itorsimply Agreement bysigning others. (Monsanto’sMissouri regardless headquarters), of where live. they Act. Privacy the terms ofthe contract. ofMonsanto’s abag opening Farmers to have negotiate orrights seed. noopportunity Thanks to Thanks Legal GroupFarmers’ Action and Rural Advancement InternationalFoundation for this      

Farmers accept and responsibility allliability forGMcrops outofmarkets, keeping Monsanto All cotton disputes are through resolved arbitration. seed binding notusethe company’s does the Monsanto if farmer nothonorany warranties will Farmers must allowMonsanto access full to their records,USDA, including Farm

If farmers are caught violating the contract, Monsanto aredamages and to the seek contract, caughtIf farmers collect violating will Therelimit to isnotime this contract—Monsantofarmer’s a can documents, review elevators, or other farmers’ fields orother crops.want farmers’ thatelevators, orallowGM donot attorneys’ andcosts from fees farmers. GMseeds. its with chemicals growing Monsanto’s stopped has even aftercrops farmer and fields, the seeds. documents. andallowMonsanto purchases, andchemical toall seed copy and any receipts relevant records, andinvoices for (FSA), Management andRisk Agency (RMA) Agency Service 65 Resources 66 Resources exist, websites andprovides afew this with potentially expensive for problem. dealing available treatments.” herbicide Monsanto’s that acknowledges glyphosate-resistant weeds TUG takeout. herbicides It only for stand refers not recommend specific to “appropriate commercially does TUG The methods. consult takeout proper stand to their “regional learn guides” technical takeout. mustFarmers and volunteers stand outlines the managementRR alfalfa TUG of The Stand Takeout, Volunteers, and Weed Resistance Valley hadto anImperial sign stewardship commitments. alfalfa, Use special Agreement with Valley amountof the growers in Imperial anarea that asignificant exports Alfalfa ofCalifornia, Imperial Valley Use Agreement notexported. to this was domesticexpected sign to usecontract ensure alfalfa RR Launch.” Domestic a“Limited alfalfa Monsanto release ofRR the initial called Producers were Seed andFeed Use Agreement atGuide www.worc.org orfrom Monsanto’s website, www.monsanto.com. copy from ofthe versionofthis the Technology online downloaded be can Agreement andTUG A theproducers in TUG. should aware still andprocedures included be ofthe rules following ValleyImperial alfalfa iscurrently Use illegal, Even Agreement. alfalfa thoughRR planting were to still the bound Technology anadditional growers, andfor someCalifornia Agreement, to addition contract”—in the Technology Following Agreement. export approval, growers andFeed Use Agreement—a hadto aSeed sign “domestic seed alfalfa RR who purchased use approved the in U.S. was alfalfa forapproved growers(RR) before for planting export, itwas more Monsanto’s for than growing 50pages ofguidelines Roundup Ready Because GMcrops. thefollowing Agreement’s the publication, Technology supplementary Use (TUG), Guide toIn addition the Technology are responsible farmers and for Agreement, understanding Ready Alfalfa Use Guide & Roundup Monsanto’s Technology contract. It also prohibits growers from using RR alfalfa seeds for sprout It seeds production. contract. alfalfa alsoprohibits growers from RR using without anadditional Monsanto seed RR alfalfa growersfrom prohibits harvesting TUG The Seed &Sprout Production potential butprovides no this loss, acknowledges remedy.TUG glyphosate.with The It reads: losses of12 percent stand fieldglyphosate.to 25 trials experienced being sprayed Some after will have plant the gene for every in thattolerating not isdifferentfromRR soybeans Alfalfa RR Yield brand. trademark glyphosate generic instead ofMonsanto’s used orother compensationfor they if warranties are noteligible seed orother alfalfa problems performance RR stand with experience poor producers who RR alfalfa Thismeans must useaRoundup product. afarmer program, allofMonsanto’sAs with order in from to benefit the company’s GMseed, “Roundup Rewards” Roundup Rewards even eliminateranchers. markets and or reduce profits, farmers costs, for non-GM production that germinate late, are bythe inadvertently or arecould plant), planted, increase dropped organic (seeds with andother andthe non-GMcrops, presence GMseeds ofvolunteer their hay fieldsshouldbefore harvest cropsat or percent ofGM 10 Cross-pollination bloom. formeasures except mitigating the transfer ofthe GMtrait, to suggest growers that alfalfa RR factors that notrequire preventativeoutlines butdoes contribute to cross-pollination TUG The crops. other with alfalfa Monsanto cross-pollinates that alfalfa acknowledges RR Pollen Flow

canopy interference.canopy andto beforeplants ensure crop adequatespray weeds coverage ofemerging to gapcreated eliminateof stand byloss the ofnon-Roundup effects Ready WeatherMAX isnecessary initial application The II. orRoundup UltraMAX the first of application Roundup notsurvive susceptible andwill are upto 10%ofthe to seedlings Due the genetic diversityofalfalfa, 67 Resources 68 Resources decade. combination dueoutbythe andinsect-resistance endofthe ofeight herbicide-tolerance traits, “SmartStax,” called ofcorn variety ofstacked genes asingle in number an unprecedented a Most recently, to AgroSciences Dow introduce with the apartnership company announced company’s stacked varieties. to ofthe75to program plant insurance advantage 80percent acreage oftheir corn to the Monsanto growers corn whotake 2008,essentiallywhich subsidizes in debuts byrequiring Theprogram, andMinnesota. company’s Indiana, Illinois, Iowa, in stack hybrids corn triple to provide uptoCorporation a 20 percent the discountusing oncrop for insurance farmers one for insect-resistance Monsanto –for the Federal years. convinced Crop has Insurance usuallyoneforand herbicide-tolerance GM crops that traits, include two ormore engineered Fortraits. example, Monsanto “stacked” provided has ofcrops Theseare for years. varieties Instead, into companies of continue different money first tovarieties existing generation pour at balked the lettuce.” ofRoundup Ready introduction California of research According anddevelopment. to a2004 direction thatthe to isinfluencing consumer opposition evidence GMfoods and strawberries), lettuce, (wheat, eaten bypeople foods directly popular in traits herbicide-tolerant involving research projects several and development abandoned has industry The biotechnology are andalmost 90percentGM). oil accounts for food, ofsoybeans in 80percent ofoilsused crops GM continue ofnew The majority to enter system the in aprocessed (soybean food form approval areregulatory nolonger on the market. approved for have andvegetables commercial sale, been andmanyFew that GMfruits have and cotton canola, plants. involve soybean, corn, resistance.varieties of majority vast these The andinsect- virus-resistance, such herbicide-tolerance, which provideas farmer-oriented traits, allGMcropsNearly currently onthe market the under “first fall generation” ofplants, category pipeline? What’s inthe next 165

164 New YorkNew Times 163

article, “lettucearticle, growers in Pioneers’s trait. modified isagenetically soybean “higholeicoil” with content. soybean a to foods, reduce oreliminatein fats ofsoybean trans variety for own its petitioned has Inc. There isonlyone generation”“second International, Hi-Bred cropapproval.pending Pioneer (altered andcarnations flower color). (glyphosate-tolerant) bentgrass the creeping market: However, alreadyon for involve plants which therevarieties two petitions are noengineered just like existing GMcrops onthetolerate andviruses, market. orresist herbicides insects involve “first GMcropto for varieties generation” new engineered varieties –plant traits approval 2007,ten byUSDA ofthe nowpending twelve ofDecember petitions Still, as more varieties. nutritious to manufacturers trait onthethese tacked RR new,through allegedly genetic engineering, notdeveloped was trait Though linolenic the low products. offood fattytrans avariety in acid the are in onalargeU.S., scale alreadygrown soybeans, andare to intended reduce oreliminate first The of health. tohuman theseproducts benefit enter the marketplace, linolenic low generation,” toward public approval win aneffort through points thatto products would traits industry’sinterest burgeoning The biotechnology in consumer-oriented, or “second 166

Unlike low linolenic soybeans, the higholeiccontentUnlike in soybeans, lowlinolenic 69 Evidence 70 Evidence similar to GM soybeans and corn in the in late andcorn 1990s. tosimilar GMsoybeans crop onascale to adopted GMfood the be newest be will are 2008,they in planted widely sugar Oregon. beets in IfRR isproduced Idaho, seed Dakota, andMichigan.Most sugar beet are onmore grown than acres the 1.2million in U.S., Sugar North beets largely Minnesota, in Growers Association. executive Beet manager ofthe California Goodwin, “We have to make sure wedon’t cause ourselves more problems than we’re curing,” saidBen and transfer transgenicmaterial toanddomestic relatives. wild stay the through in ground winter,sugar beets to develop for anopportunity seeds providing climate andthe means warmer capable ofcrossingsugar with beets, weeds has Still, California andcontamination issues may aconcern. cross-pollination fall), notbe each their sugar beets year, their second in produce seed growers (whoharvest Sugar sofor beets most sugar beet ashort-termturning problem. solutioninto along-term onlyencourage the problem will ofglyphosate-resistant variety weeds, herbicide-tolerant the new believe resistance andthe sources. contaminationThey ofconventionalweed seed including crops, doother RR they as sugar have beets concernsRR about similar Opponents are labeled. ingredients to avoid export products whichin where iscommon countries consumerin GM rejection, someU.S. notplanting), (but companiesto sugar sugar may for food RR usecane import decide sugar. 3percent Only ofU.S. approved the sugar European While has isexported. Union (EU) sugar ofits supply,for half The beets on sugar depends withU.S. the restfromcane coming on the issue. noconsumerFood resistance, companies report though notmany have position taken apublic to 2008. in thatplant are poised farmers variety In 2005,USDA sugar beet RR approved anew to companies are take somefood andatachance willing least on GMsugar.the sugar industry came to a Now,standstill. beets RR performance,sugar field it trial appears poor reportedly and from Hershey candy-makers including andMars, concern consumer about rejection, The USDAfirst approved Monsanto’s in1999,butdue to beets (RR) sugar Ready Roundup Beets to Debut in2008 Sugar Roundup Ready 167

Siemon explains. In 2006, the average price received by CROPP Cooperative farmers forSiemon explains. a In2006,the farmers average by CROPP Cooperative received price conventional receive above apremium for farmers prices,” their organic milk, “Our dairy to totalpercent salesexpected reach 2007,with in growth $450million. a35 isprojecting CROPP Cooperative salesoforganic meat products. involved $7.8 million and products, salesoforganic dairy this involved Of total, $287million over2005sales. growth which represented sales, in hadatotal of$333million 2006, CROPP a38percent Cooperative Organic Valley the in organicNatural oneselling brand isthe number In Food Channel. Retail explains. to theis paramount success continued and CROPP Cooperative,” ofthe organic industry he asignature as label that brand represents ofthe the USDA integrity integrity “This organic seal. Siemon says that to consumers look the Organic Valley internationally name“Organic the under brand Valley.” throughout members theits United States and of markets theCROPP products Cooperative producers. and/or poultry and177are pork organic farms beef, organic dairy 919are farms, the Of member Organic Standards. Food Production Act of1990andthe USDA’s National accordance in operate their farms the with Organic as such and areto organic farmers, required certified are province. members USDA All one Canadian 32states in located and 1,170 organic farms family Wisconsin. of iscomprised CROPP Cooperative LaFarge, in located cooperative an agricultural of Organic Producer Pools (CROPP Cooperative), for Regions the SiemonisCEO Cooperative George LaFarge, Wisconsin ValleyOrganic - George Siemon, 71 Profiles 72 Profiles with Roundup Ready alfalfa. If certified organic seed is not available, farmers who seek non- whoseek isnot farmers available, organic seed Ifcertified alfalfa. Roundup Ready with contaminated losethis choice will the becomes if national andthey GM crops, crop ofalfalfa crops. They have chosen raisenon- to donotdesire modified to they genetically raise because have ofCROPP Cooperative ofthe chosen members One reasons to organic producers be is and dairy products to be marketed as organic, certified organic alfalfa mustbe used as forage.” “The purchase of non-certified organic alfalfa is not an option,” Siemon explains. “In order for milk whomarketfarmers their milkthrough CROPP Cooperative. the organic will devastate this stock, orseed stands, organic alfalfa contamination ofcertified Siemon says issoldcommercially, that alfalfa Roundup Ready if andthis causes the organic feed. the lack ofcertified dueto impacts economic severe have at Many reasonablefarmers organic reported prices. feed adequate certified sourcing in to members year the assist its in past to program initiate afeed supply, CROPPhas had andsupply forall prices farmers. difficulties organic increased causing CROPP’s short andcontinues to very for in be, livestockbeen, membership. Organic feed has and the in United difficult issueexpensive adequateorganic States feed for Sourcing isavery alone. approximatelyCROPP per year animals for members’ organic alfalfa 205,000tons ofcertified approximately cow eats Each day. per oforganic alfalfa 32.5pounds equates This to from mills. other organicproducers or 100 percentfeed feed certified CROPP Cooperative’s purchase orthey feed, grow animals’ andproduce members their own pasture and animals their for organicthe diet. alfalfa, of remainder 60 percenttheir certified ofapproximately comprised acombination their animals ofahighforage feed diet, members CROPP’s organicorganic livestock of100percentfeed. may adiet fed certified onlybe CROPP Cooperative’s approximately own collectively membership Certified 58,000cows. The EconomicImpactoftheLossOrganic Alfalfa percent the in United ofallorganic operations States. totalnational organic milksupply, represents total membership andits approximately 10 CROPP Cooperative’s represents membership approximately dairy 35percent ofthe 2006. in organic in $68million received premiums (a difference collectively farmers of$11.83).These $24.87,compared to aconventional was average ofmilk(cwt) of$13.04 price pounds hundred

in amannerthatin ensures crops are other safe alfalfa from cross-contamination,” Siemonadds. the nation’s untilthe USDA stocks, grown organic ensure alfalfa be can that can the GMalfalfa to stopped, prevent should contamination andplanting be of production seed “Roundup Ready integrity.” products,”GM-free dairy amajor issue becoming issue for organic Siemonsays.fast is “This andtherefore cattle GM-free alfalfa, to dairy impossible to market impossible feed become will it genes, Roundup Ready contaminated with become stocks seed “If the national alfalfa greatly market reduced. be andour will organicchoose products, greatly compromised. be Consumers will ofthemay the seal integrity nolongerproduct, If consumersthat come to the USDA believe nolonger organic represents seal aGM-free organisms. astatementamong other things, that frommodified genetically the isfree product the consumerin USDA trust devastate For organic seal. represents, the consumers, seal potentially could into industry permeating the organic of Roundup impact Ready food The The Consumers’RelianceonOrganicRepresenting Non-GMO oforganic farming. livelihood presence andlosetheir chosen losetheir market, its the will in channels, retail the farmers Organic Valley’s ability to compete the in channels. retail isnotable Ifthe brand to maintain the “Organic andaffect this production affect will Valley” tooffeed brand Ashortage market. consistent notmarket andrelies farmers’ does conventional onits to production take milk, CROPP Cooperative organic milk. able to notbe produce will they feed, unable to source adequateorganic are contaminated. Ifthe farmers been that hay are not they purchasing has GM contamination, orto ensure acropplanting that nothave does simplytolots ensure that are they forced be toorhaywill test seed and complexity ofthe test. Farmers the species upon sample, depending rangefrom $179to can $259per great expense. The cost of testing forced be to will test atGM seed a 73 Profiles 74 Resources The FirstNine Years Gone toSeed: Transgenic Contaminantsinthe Traditional Supply website, our orvisit www.worc.org. these reports, see consumers, and farmers of rights and the and For plants foods more information modified ongenetically Reports Genetically Engineered Crops andPesticide UseintheUnitedStates:

Dr. Charles Benbrook debunks GM cropproponents’ GM reduce debunks Dr. crops GM claim that Benbrook Charles thequality threaten GM cropvarieties how examines Scientists The Union ofConcerned Download at: Download since use 1996. into a122millionpesticide pound increase led andcottonhave soybeans, corn, toshow GM that data USDA anduses use, pesticide seed.html at: Download To to: order write varieties. GM from derived sequences ofDNA lowlevels with contaminated arepervasively canola and soybeans, ofcorn, varieties supply traditional that andconcludes seed of theseed www.biotech-info.net/technicalpaper7.html www.ucsusa.org/food_and_environment/genetic_engineering/gone-to- 2 Brattle Square, Cambridge, MA 02238 2 Brattle MA Cambridge, Square, The Union of Concerned Scientists, Scientists, The Union of Concerned

Seeds ofDoubt: North American Farmers’Experience withGMCrops Farmers’ GuidetoGMOs Monsanto vs. U.S. Farmers

Download at: Download for farmers. andprofitability security, food chemical use, lower higher yields, technology: GM of benefits commonly claimed challenging evidence presents Association SoilThe at: Or download To to: order write contamination. from issues andliability inspections, field saving, seed contract terms, farmers’with including ofGMOs, regulation, federal use associated issues themultifarious addresses that aguide provide (RAFI) International The Farmers’ GroupLegal (FLAG)Action and Rural Advancement Foundation at: Or download To to: order write farmers. Monsanto targeting by 100lawsuits andnearly ofinvestigations thousands revealing farmers, American the Company’s documents Monsanto against Safety for lawsuits The Center Food

www.soilassociation.org www.rafiusa.org/pubs/Farmers_Guide_to_GMOs.pdf Washington, 20003 DC St. Paul, St. MN55101 (Copies are $5. Please send a check, money order, money (Copies are sendacheck, $5.Please orcash.) www.centerforfoodsafety.org/Monsantovsusfarmersreport.cfm Farmers’ Action #500, Legal Group, Street, 360N. Robert Center for Food Safety, 660Pennsylvania Ave, Suite SE, 302,

75 Resources 76 Resources Genetically Engineered Crops toRelated Wild Plants Contaminating the Wild: GeneFlow from ExperimentalField Trials of atRisk Harvest Genetically ModifiedOrganisms, andtheLaw If Your FarmIsOrganic, MustItBeGMO-Free? OrganicFarmers,

Or download at: Or download Washington, 20003 DC To to: order write species. wild torelated crops engineered genetically of trials field experimental from flow gene on reports Safety for The Center Food who donotadoptRoundup wheat. onfarmers Ready andtheimpacts adoption including andindustry, of thecost ongrowers impacts economic andprojects adoption ofRoundup wheat Ready consequences the probable describes Dr. Benbrook Charles at: Or download To to: order write certification. fororganic from therequirements differ that upon farmers responsibilities impose may contracts in which oftheways sales discussion abrief well as as farmers, applytoorganic they as handling requirements addresses also article The organic. certified become to wish orwho organic whoarecertified farmers cropand livestock affect that engineering ofgenetic toavoidtheuse requirements theFarmers’ article, In Action comprehensive this Legal Group (FLAG) examines

Download at: Download www.worc.org/issues/benbrook.html www.centerforfoodsafety.org St. Paul,St. MN55101 http://www.flaginc.org/topics/pubs/index.php#OrgnicsGMOs Center for Food Safety, 660Pennsylvania Ave, Suite SE, 302, Farmers’ Action #500, Legal Group, Street, 360N. Robert

Pharmaceutical andIndustrialCrops A Growing Concern: Protecting theFood Supply inanEraof Market RisksofRoundupReadyHard RedSpring Wheat Transgenic Crops

To to: order write crops. tothese applied practices andmanagement production commodity to the aremade changes supply substantial ofthefood –unless contamination preventing while crops pharmaceutical as used be cannot andsoybean corn problem that concluded this toanalyze Scientists bytheUnion commissioned ofConcerned experts Six substances. andindustrial toproduce drugs engineered genetically bycrops contamination supply theU.S. food from ofprotecting thechallenge addresses Concern A Growing at: Download years. tosix two in theU.S. withinspring thenext wheat red hard GM commercializing from andprices markets onexport impacts the potential Dr. Wisner, atIowa University, Robert ofEconomics State examines Professor University producers. organic on and impact concerns, liability regulations, the U.S., including effects, theunintended in crops ofGM Technology,Appropriate overview acomprehensive farmers provides for oftheNational Center service information agriculture asustainable ATTRA,

Or download at: Or download at: Or download To order call: -1-800-346-9140 www.worc.org/issues/benbrook.html Cambridge, MA 02238 MA Cambridge, www.ucsusa.org www.attra.ncat.org/attra-pub/geneticeng.html The Union of Concerned Scientists, 2 BrattleSquare,Scientists, The Union of Concerned

77 Resources 78 Resources A GrainofCaution: A Critical Assessment ofPharmaceuticalRice

The Center for Food Safety details the potential human health impacts of impacts human health potential the Ventria’s details Safety for The Center Food Or download at: Or download To to: order write public experts. andother health Health Organization bythe recommended World of diarrhea treatment and forprevention solutions effective forVentria’s and cheap theneed discussing disputes also rice, report pharmaceutical andtheFDA’s rice pharmaceutical toapproveVentria’s refusal The drugs. rice-grown

www.centerforfoodsafety.org Washington, 20003 DC Center for Food Safety, 660Pennsylvania Ave, Suite SE, 302,

Endnotes only for two years, and is grown throughoutonly for andisgrown the two nation. years, cropperennial isthe first Hawaii.Roundup Ready in alfalfa to enter Roundup Ready grown the marketplace,if 14 reg.html. Events J101&J163,April L.) sativa (Medicago 16.http://www.aphis.usda.gov/brs/not_ Alfalfa Roundup Ready 13 1996 to 2006,June 29,www.monsanto.com/pdf/pubs/2006/Q32006Acreage.pdf. 12 7,2007). October 11 Supply, http://www.ucsusa.org/food_and_environment/genetic_engineering/gone-to-seed.html. 10 City, July 18–21. Quebec Canada, Quebec, ImprovementConference Conference Alfalfa ofthe American 39th North andthe 18th Trifolium Conference, 9 in the 21st century, ofalfalfa www.alfalfa.ucdavis.edu/subpages/Wildlife/BrochureFINAL.pdf.benefits 8 proceedings/2004.html. 13-15.http://alfalfa.ucdavis.edu/+symposium/ December &Forage Diego, CA, San Alfalfa Symposium, 7 anrcatalog.ucdavis.edu/pdf/8153.pdf. Series, California in Biotechnology 6 in the 21st century, ofalfalfa www.alfalfa.ucdavis.edu/subpages/Wildlife/BrochureFINAL.pdf.benefits 5 www.ncfap.org/40CaseStudies.htm. alfalfa, for management pest U.S.impact improving in tolerant studies, herbicide Ananalysisof40case agriculture: 4 www.biotech-info.net. Biotech InfoNet, years, 3 itdominates,”as York New Times, May 31. David.2003.Monsantowww.etcgroup.org/en/materials/publications.html?pub_id=48; even struggles Barboza, 2 in the 21st century, ofalfalfa www.alfalfa.ucdavis.edu/subpages/Wildlife/BrochureFINAL.pdf.benefits 1

Genetically engineered papaya trees were the first perennial to be commercialized, and are primarily andare papaya were trees primarily perennial the be first commercialized, to engineered Genetically Monsanto and ForageInternational. 2004.Petition Genetics for Status: ofNonregulated Determination Monsanto Company. Forecast, Monsanto Trait 2006.Preliminary Biotechnology Acreage: Fiscal Years ofHerbicide Resistant Weeds, International Survey http://www.weedscience.org/in.asp (accessed Transgenic to Seed: 2004.Gone the in Traditional Contaminants Union Scientists. ofConcerned Seed Teuber, (Apisbee Joint pollination, mellifera)under honey in alfalfa flow al.2004.Gene et L.R., and importance The andthe environment: wildlife &Forage 2001.Alfalfa, Alfalfa Association. California Woodward, W.T.W. the in marketplace, ofCalifornia 2004.Issues GMOalfalfa with Proceedings technology, Anemerging Agricultural Roundup ready alfalfa: University ofCalifornia-Davis. and importance The andthe environment: wildlife &Forage 2001.Alfalfa, Alfalfa Association. California National Center for Food andAgriculture Policy. Current andpotential 2002.Plant biotechnology: the usein United cropsfirstnine The andpesticide States: engineered 2004.Genetically C. Benbrook, 2005,http:// Concentration –2005,Communique, Industry Etc September/October Group. Seed Global and importance The andthe environment: wildlife &Forage 2001.Alfalfa, Alfalfa Association. California 79 Resources 80 Resources not_reg.html. Events J101andJ163,April L.) sativa (Medicago 16.http://www.aphis.usda.gov/brs/ Alfalfa Roundup Ready 33 32 all plants”. in for production its material necessary 61FR40338(Aug. 2,1996). andthe genetic EPSPS] requirement [CP4 ofatolerance for ingredient residues inert ofthe pesticide plant 31 30 29 28 27 26 25 not_reg.html. Events J101andJ163, April L.) sativa (Medicago 16.http://www.aphis.usda.gov/brs/ Alfalfa Roundup Ready Monsanto andForageInternational. 2004.Petition Genetics forStatus: ofNonregulated Determination EPA 11,1997); 47808(September ofapplications62Fed. for registrationReg. ofpesticides, expedite review Pesticides” aresponsefor to Biological Protection was the Food Act Quality of1996,which requires that 24 not_reg.html. Events J101andJ163,April L.) sativa (Medicago 16.http://www.aphis.usda.gov/brs/ Alfalfa Roundup Ready 23 1,2007). October fieldtests1.cfm (accessed 22 percent withhtml. 35 crop.) a (The cover remaining isplanted Events J101andJ163,http://www.aphis.usda.gov/brs/not_reg. L.) sativa (Medicago Alfalfa Roundup Ready 21 edu. &Forage Visalia, Alfalfa http://alfalfa.ucdavis. Symposium, ofCalifornia CA, systems,production Proceedings 20 19 in the 21st century, ofalfalfa www.alfalfa.ucdavis.edu/subpages/Wildlife/BrochureFINAL.pdf.benefits 18 &Forage Visalia, Alfalfa http://alfalfa.ucdavis.edu. Symposium, California CA, 17 usda.mannlib.cornell.edu/reports/nassr/price/zcv-bb/cpvl0206.txt. 16 www.nass.usda.gov/Statistics_by_Subject/index.asp. 15 Monsanto andForage International. 2004.Petition Genetics for Status: ofNonregulated Determination 22984(May 57Fed. 29,1992). Reg. rule an §180.1174; This andestablished extends 40CFR alfalfa, to Roundup Ready “exemptionfrom the 10,2004). 65081(November 69Fed. Reg. Ibid. Ibid. 51303(August 69Fed. Reg. 18,2004). 27,2002). 60934(Sept. 67Fed. Reg. 18894(April 67Fed. Reg. 17,2002). ofConventional Pesticides Initiative and Review “Guidelines the under Reduced-Risk for Expedited Monsanto andForageInternational. 2004.Petition Genetics forStatus: ofNonregulated Determination Information Systems for Biotechnology. 2007.Field test the releases in http://www.isb.vt.edu/cfdocs/ Monsanto andForageInternational. 2004.Petition Genetics forStatus: ofNonregulated Determination Putnam,D. to 2005.Market andmethods ensure sensitivity tolerance ofbiotech andnon-biotech alfalfa Ibid. and andthe environment wildlife the importance &Forage 2001.Alfalfa, Alfalfa Association. California N.P. Martin, of cattle Proceedings andnovel uses, for &Mertens,2005.Reinventing dairy D.R. alfalfa U.S. 2006.Crop ofAgriculture, 2005,http:// National values, Department Agriculture Statistics Service. http:// U.S. 2007.Hay ofAgriculture, (Dry), National alfalfa Department Agriculture Statistics Service. Feb. 13,2007). Approve Farms v. APHIS’ Seed 518624(N.D. Judgement. Proposed 2007WL April Johanns, Cal. 7.Geertson 53 52 www.biotech-info.net. Biotech InfoNet, years, 51 10.http://www.plantmanagementnetwork.org/pub/cm/news/2004/agtech/.February 50 49 Article?article_id=17054. 48 . brs/pdf/RRA_A8_final.pdf 47 46 45 44 43 variety. plum engineered genetically to deregulate a response fromResearch 96commentsin to theAPHIS received Agricultural apetition Service 23302,June 1984(51Fed. in 26,1986).In2006, statement Reg. products for biotechnology regulating policy FDA ofrespondents. 34commentsonits to ahighnumber received 663commentsappears be and food, 42 reprint/101/40/14533.pdf. amarker,as ofthe National Academy101(40)14533-14538,www.pnas.org/cgi/ Proceedings ofSciences, EPSPS CP4 with bentgrass creeping geneflowfrom modified genetically pollen-mediated for landscape-level, milesfrom fieldet al.2004. S., trials; thirteen L. Evidence species Watrud, grass wild in trait bentgrass the RR byMonsanto produced Scotts andwas andTheCompany.and lawns, of was discovery prompted by TheEIS 41 40 39 fda.gov/~rdb/bnfm084.html. Additive Safety. Consultation Note to 2004.Biotechnology the 8.http://www.cfsan. File 000084,December BNF 38 37 36 ipcm.wisc.edu/wcm/pdfs/2005/05-20Weeds2.html. 35 34

Freese, W. Defendants’ Opposition to Motion ofPlaintiffs’ to Support in Declaration 2007.Legal 21. February Farm Delta Press. burden 2007.Glyphosate-resistantgrowers’ pocketbooks, weeds the usein United cropsfirstnine The andpesticide States: engineered 2004.Genetically C. Benbrook, technology, 2004.Helping Plant Management growers ofagricultural protect Network. the value 43222(August 72Fed. Reg. 3,2007). Hay, Matt. 2007.Brave New Jenkins, June 11,http://www.hcn.org/servlets/hcn. News, HighCountry USDA, 2007.Supplemental APHIS. Administrative Order. 18.http://www.aphis.usda.gov/ December Ibid. Farms v. Seed 518624(N.D. 2007WL Johanns, Feb. Cal. Geertson 13,2007). Ibid. Ibid. 27,2005).Compared to comment public onthe ofother regulation GEcrops 36918(June 70Fed. Reg. golf courses in used 7C.F.R. aturfgrass bentgrass, 372.5(d); anEISfor creeping APHIS ispreparing RR Ibid. Ibid. U.S. Administration, Food andDrug Center for Food Safety andApplied Nutrition/Office of Food 3,2005). 5601-5602(February 70Fed. Reg. 24,2004). 68300-68301(November 69Fed. Reg. approved J.for Doll, use, alfalfa 2005.Roundup Ready Wisconsin Crop Manager, 12(20),July 21.http:// Administration, 10,2006. Food communication, andDrug October personal C. Hendrickson, 81 Resources 82 Resources 72 externalstories/alfalfa.shtml. technology, agricultural information the April about to new producealfalfa objective 1.http://ucanr.org/ 71 518624(N.D. 2007WL Johanns, Feb. Cal. 13,2007). 70 Crops the in U.S., from http://www.ers.usda.gov/data/biotechcrops/ 8,2007). (accessed September 69 www.ncfap.org/40CaseStudies.htm. alfalfa, for management pest U.S.impact improving in tolerant studies, herbicide Ananalysisof40case agriculture: 68 Hower,authored A. byArthur Jayson Harper, K. Harvey. R. and Gordon ofthe U.S.project ofAgriculture National Pesticide Agricultural Department Assessment Impact and Program, pest andotherpesticides managementin of practices a production, importance Thealfalfa U.S. Alfalfa: entitled http://hayandforage.com/mag/farming_roundup_ready_alfalfa_2/index.html; isa Thisfigure result ofa study 67 15. December Successful Missouri, in Farming, confirmed resistant ragweed 19. http://westernfarmpress.com/news/9-29-04-roundup-ready-alfalfa/; Mike. 2004. Glyphosate- Holmberg, 66 65 http://deltafarmpress.com/mag/farming_resistant_pigweed_looms/. 64 7,2007). October 63 62 61 60 59 com/news/050721-resistant-weed/. 58 57 www.biotech-info.net. Biotech InfoNet, years, 56 pp. 703–705. 55 518624(N.D. 2007WL Johanns, Feb. Cal. 13,2007). 54 Livestock Weekly. April studying roundup resistant 15. ofalfalfa. 2004.Scientists strains 2004.University studies engineered genetically ofCalifornia Service. HigherEducation News Ascribe Farms v. Gurian-Sherman, for D. Seed Permanent Declaration April 2007.Legal Injunction, 5.Geertson Engineered U.S.2007. Adoption ofAgriculture, Economic ofGenetically Research Department Service. National Center for Food andAgriculture Policy. Current andpotential 2002.Plant biotechnology: Wilke, C.W. mightcorn, too, benefit Hay alfalfa 1998.Roundup Ready & Forage Grower, 1. January challengesexamined, alfalfa of Roundup Ready H.2004.Benefits, Cline, Western September Press,Farm 21. February Farm Delta Press. burden 2007.Glyphosate-resistantgrowers’ pocketbook, weeds Farm Delta onMid-South Press, looms August horizon, David.2005.Resistant 12. pigweed Bennett, ofHerbicide-Resistant Weeds, International Survey http://www.weedscience.org/in.asp (accessed Ibid. Ibid. Ibid. Ibid. James, Lamar. costly, could be 2005.Resistant weeds Farm Delta Press, July 21.http://deltafarmpress. 21. February Farm Delta Press. burden 2007.Glyphosate-resistantgrowers’ pocketbooks, weeds the usein United cropsfirstnine The andpesticide States: engineered 2004.Genetically C. Benbrook, VanGessel, Mark J. from Delaware, 2001.Glyphosate-resistant Weed Horseweed Vol. Science: 49,No. 6, Farms v. Gurian-Sherman, for D. Seed Permanent Declaration April 2007.Legal Injunction, 5.Geertson org/sub-531036. 90 89 roysoc.htm#enviro. 88 87 Supply, http://www.ucsusa.org/food_and_environment/genetic_engineering/gone-to-seed.html. 86 org/sub-531036. 85 products/organic-products-206/overview/. itpays 2006.When to http://www.consumerreports.org/cro/food/diet-nutrition/organic- buyorganic. Reports. 84 July 23. supply News, oforganicDaily Maine,Bangor milkin Demand 2005. exceeds S.K. Mack, www.ers.usda.gov/amberwaves/feb03/findings/organicagriculture.htm; 83 publications/briefs/35/executivesummary/default.html. 82 Crops the in U.S., from http://www.ers.usda.gov/data/biotechcrops/ 8,2007). (accessed September 81 3(2):99-106. Environment, 80 Applications, 15(2)pp. 377-404. organisms andthe environment:Current status engineered Ecological andrecommendations, Genetically 79 http://westernfarmpress.com/news/9-29-04-roundup-ready-alfalfa/. 78 Tablehttp://nysipm.cornell.edu/publications/eiq/default.asp (See values). 2:EIQ Cornell University, ofpesticides, impact York New York, New Station Geneva, State Experiment Agricultural 77 76 75 19. http://westernfarmpress.com/news/9-29-04-roundup-ready-alfalfa/. 74 externalstories/alfalfa.shtml. technology, agricultural information the April about to new producealfalfa objective 1.http://ucanr.org/ 73

GeneWatch 2005,http://www.genewatch. 2005.GMContamination &Greenpeace. Register UK Report 2005.U.S. C. launches Macilwain, probe into Nature, salesofunapproved transgenic corn, March 22. use,plants forfood http://genaction-kr.jinbo.net/archivve/Society. modified The Genetically Royal 1998. Ibid. Transgenic to Seed: 2004.Gone the in Traditional Contaminants Union Scientists. ofConcerned Seed GeneWatch 2005,http://www.genewatch. 2005.GMContamination &Greenpeace. Register UK Report Organic Trade 2006.Organic salescontinue Association. to grow at asteady pace, May 7;Consumer ground, gaining U.S.2006.Organic agriculture ofAgriculture, Economic Research Department Service. Biotech/GM Crops. Status Global 2006.http://www.isaaa.org/resources/ ofCommercialized ISAAA. Engineered U.S.2007.Adoption ofAgriculture, Economic ofGenetically Research Department Service. Marvier, M.&Van Acker, Frontiers kept crop onaleash? transgenesbe 2005.Can and the Ecology in R.C. Snow, Andow, P., A.A., D.A., Gepts, Power, Hallerman, E.M., Tiedje, A., J.M. &Wolfenbarger, 2004. L.L. Delta 29. September Press,Farm challengesexamined. alfalfa of Roundup Ready H.2004.Benefits, Cline, J. Kovach, &Tette, J., Degni, Petzoldt, C., J. to the IPMAmethod measure Program. environmental Ibid. Ibid. challengesexamined, alfalfa of Roundup Ready H.2004.Benefits, Cline, Western September Press,Farm 2004.University studies engineered genetically ofCalifornia Service. HigherEducation News Ascribe 83 Resources 84 Resources 12. http://www.uspirg.org/. 113 112 111 National Academy transport, Press: intended Washington,of Regulation DC. 110 gov/oig/webdocs/50601-08-TE.pdf. www.usda. organism controls release permits, overissuance engineered ofgenetically Service Health Inspection 109 108 107 cropchoice.com/leadstry0898.html?recid=289. 106 stories/2002/01/31/health/main326681.shtml. 105 Washington Post, August 19. 104 103 102 101 100 Washington Post, August 19. 99 98 97 96 1.http://www.centredaily.com/mld/centredaily/news/7386628.htm. December Newspapers, 95 94 www.cropchoice.com/leadstry8b5a.html?recid=232. 93 of_genes.html. 92 91 U.S. Field PIRG. Risk: Testing 2005.Raising Crops the in United Engineered States, April ofGenetically Baker,crops 14. costing producers money,November modified Daily News, Minot M.2007.Genetically Vogel, G. 2006.Tracing the transatlantic spread vol.313,p. 1714. ofGM rice, Science, National of Research 2002.EnvironmentalEffects and Council. Scope The Adequacy Transgenic Plants: and 2005.Plant Animal General. U.S. ofAgriculture, OfficeAudit ofInspector report: Department 17044-17059(March 58Fed. Reg. 31,1993). The Non-GMO Report. 2005. GMO impacts on organic spreading worldwide.www.non-gmoreport.com. Cropchoice, costs ofGMtesting. bears April organic farmer 2001.Nebraska 11.http://www. R. Schubert, Taco to Recall Kraft 22.http://www.cbsnews.com/ September News, 2000.CBS Shells. Weiss, rice, 2006.U.S. isfound long-grain in altered variety R. supply rice contaminated: Genetically Ibid. Ibid. D. Farm Delta Press, action, Bennett, class to contamination 2007.GMrice leads May proposed 25. Baker,crops 14. costing producers money,November modified Daily News, Minot M.2007.Genetically Weiss, rice, 2006.U.S. isfound long-grain in altered variety R. supply rice contaminated: Genetically D. 2001.Asbiotech crops Barboza, multiply, consumers get little choice. TheNew York Times, 10. June Ibid. Ibid. Jacobs, P. still corn crop. contaminating 1%ofUScorn GEStarLink Knight Ridder 2003.Banned D. 2001.Asbiotech crops Barboza, multiply, consumers get little choice. TheNew York Times, 10. June biotech6.http:// about contamination. 2001.February Cropchoice. worry organic Dakota farmers North Zitner, 2001.Fields Angeles A. Los Times, ofgene factories. June 4.http://www.biotech-info.net/fields_ 1. December San Bee, The mix-up. Francisco seed in cleared M.2004.UCD Lee, parl.gc.ca/37/1/parlbus/commbus/senate/com-e/agri-e/rep-e/rep10jun02-e.htm. 132 canola_pesticides.pdf. Manitoba Agronomists Conference, www.umanitoba.ca/afs/agronomists_conf/proceedings/2005/hammond_ 131 http://www.biotech-info.net/triple_resistance.html. 130 518624(N.D.2007 WL Feb. Cal. 13,2007). 129 not_reg.html. Events J101andJ163 April L.) sativa (Medicago 16.http://www.aphis.usda.gov/brs/ Alfalfa Roundup Ready 128 ?request=get-abstract&issn=1540-9295&volume=003&issue=02&page=0093. Frontierskept onaleash? 3(2):99–106,http://www.esajournals.org/esaonline/ andthe Environment, Ecology in Weed inputs. InMarvier, 51:83-86,cited seedbank Science, M.&Van Acker, crop transgenesbe 2005.Can R.C. 127 pubs/mt200504.html. 126 Health, 6(1),http://www.cnr.berkeley.edu/~agroeco3/the_ecological_impacts.html. 125 westernfarmpress.com/mag/farming_resistant_alfalfas_face/. 124 D.123 Lehnert, 1998.Tap the market for organic hay, Hay &Forage Grower, 1. February articles/2007/06/11/business/biz49.txt. 122 121 120 119 5,2007). (accessed October www.ers.usda.gov/Data/organic/ 118 117 Committee, Advisory AprilBiotechnology 17.www.rsc.ca/foodbiotechnology/indexEN.html. 116 2007, http://www.aphis.usda.gov/brs/ph_permits.html. Proteins for Human Consumption, orfor Phytoremediation, orPending14, Granted ofSeptember byAPHIS as 115 gov/oig/webdocs/50601-08-TE.pdf. www.usda. organism controls release permits, overissuance engineered ofgenetically Service Health Inspection 114

The Standing Committee The on Standing and Agriculture Forestry.www. 13. Canadian June Risk, 2002. Farmers at of2005 Proceedings ofCanada, Hammond, Council D. Canola andtrade, pesticides 2005.Canola MacArthur, M. 2000.Triple-Resistant Weeds Canola Western Found Alberta, in Producer, 10. February Farms v. for Seed Permanent Declaration April 2007.Legal Johanns, Injunction. 4.Geertson C.C. Shock, Monsanto andForageInternational. 2004.Petition Genetics forStatus: ofNonregulated Determination largenapus) cause (brassica canola losses A.G. 2003. Harvest S.J., Shirtliffe, &Thomas, Gulden,R.H., Montana State University. crop, asuccessful 2005.Establishing http://www.montana.edu/wwwpb/ alfalfa crops oftransgenic Ecosystem onagroecosystem health, impacts ecological 2001.The M.A. Altieri, face challenges, Western H.2005.Resistant alfalfas Cline, Farm Press, 15.http:// January Dininny, supply. tests feed Shannon. 2007.Organic boom http://www.missoulian.com/ Missoulian, cow, 2005.Anorganic cash K. York Severson, New Times. 9. November Weinraub, J. &Nicholls, W. Washington 2005.Organic milksupply short, falls Post, June 1. Valley City Times-Record. May to for Dakota North 10. feed. looking organic farmers 2005.California http:// Organic production, sets: U.S.2006.Data ofAgriculture, Economic Research Department Service. J. afield? far for Gillis, 2002.Corn growing Washington 16. November Post, A Submission Modified Food: Canadian to D.the McCalla, ofGenetically al.2001.Regulation et U.S. ofAgriculture,Value Permits Release APHIS. Industrials, for Department Pharmaceuticals, Added and 2005.Plant Animal General. U.S. ofAgriculture, OfficeAudit ofInspector report: Department 85 Resources 86 Resources GE crops, and it is legal for RR alfalfa to be shipped there. to shipped be for alfalfa anditislegal GE crops, RR doesn’t anapproval process. butisdeveloping Taiwan regulate feed, animal system for regulatory avoluntary has Weekly, August 12.http://www.seedquest.com/News/releases/2005/august/13194.htm; Korea currently 151 149 Farm Press, 11.http://westernfarmpress.com/news/1-11-05-herbicide-resistant-alfalfa/. January 148 %20Woodward.pdf. 18-19.www.wa-hay.org/.../Roundup%20Ready%20Alfalfa%20Test%20Kits%20and%20Influence%20-January of 2006Washington State Hay Growers Association’s Conference Annual &Trade Show, WA, Kennewick, 147 24,2007). September Press/health_benefits_of_sprouts.htm (accessed 146 16,2007). (accessed November cfdocs/fieldtests1.cfm 145 Wild_Report.pdf. crops towww.centerforfoodsafety.org/pubs/Contaminating_the_ related plants, engineered genetically wild 144 518624(N.D.2007 WL Feb. Cal. 13,2007). 143 518624(N.D. 2007WL Johanns, Feb. Cal. 13,2007). 142 Depts/CoopExt/TRA/Agronomy/Alfalfa/Hammon.RRpollenflow.pdf. 141 14-15. December & Forage Diego, CA, San Symposium, 140 Washington State Hay Growers Association’s Annual Conference & Trade Show, Kennewick,139 WA, January 18-19. 138 content/stewardship/tug/2007TUGPDF.pdf. 137 13-15. December Forage Diego, CA, San Symposium, 136 City, July 18–21. Quebec Canada, Quebec, ImprovementConference Conference Alfalfa ofthe American 39th North andthe 18th Trifolium Conference, 135 101,107-114. andGenetics, Theoretical Applied effects, dependent 134 cbc.ca/news/story/2001/10/13/organic011013.html. 133 Moore, T. 2005.Washington Press Capital hay Agriculture at growers balk alfalfa, Roundup Ready Ibid. worthwhile, Western challenging, be will marketing herbicide-resistant alfalfa H.2006.Growing, Cline, Woodward, W.T.W. andinfluence teston the market, Proceedings kits alfalfa 2006.Roundup Ready Supply, International of sprouts, Health S. benefits Specialty Meyerowitz, http://www.sproutnet.com/ Information Systems for Biotechnology. 2007.Field test the releases in U.S., http://www.isb.vt.edu/ Center for Food Safety. genefrom of 2006.Contaminatingthe flow trials field wild? experimental Farms v. Snow, for Seed Permanent Declaration April 2007.Legal Johanns, Injunction. A. 4.Geertson Farms v. Gurian-Sherman, for D. Seed Permanent Declaration April 2007.Legal Injunction, 5.Geertson Production Hammon, Fields, B., al.Pollen et from www.colostate.edu/ Seed Movement from Alfalfa Alfalfa Mueller, ofCalifornia Proceedings issues production alfalfa, for enhanced genetically 2004.Seed S. Woodward, W.T.W. 2006. Roundup Ready alfalfa test kits and influences on the market, Proceedings of 2006 Komp,crop,Standard,New March 2006.Farmers The suealfalfa 3. C. USDA overmodified The Monsanto Company. 2006.2007 www.monsanto.com/monsanto/us_ag/ Use Guide, Technology Woodward, W.T.W. & Alfalfa the in marketplace, ofCalifornia 2004.Issues GMOalfalfa with Proceedings Teuber, (Apisbee Joint pollination, mellifera)under honey in alfalfa flow al.2004.Gene et L.R., Amand,P.C., St. Skinner, transgenedissemination andscale- D.Z., ofalfalfa 2000.Risk &Peaden, R.N. 13. http://www. to October battle poised GMOcompaniescourt, 2001.Organic farmers in News. CBC 167 Pollack, Andrew. York New Round 2for biotech beets, Times, 27,2007. November 96E2D48DC7EA7D63. 17. http://www.brownfieldnetwork.com/gestalt/go.cfm?objectid=1536CFC1-B254-C37D- September America, 166 14. September in Corn, Stacked Offering Gene 165 17.http://www.checkbiotech.org/green_News_Genetics.aspx?infoId=16456. December premiums, 164 Supply, http://www.ucsusa.org/food_and_environment/genetic_engineering/gone-to-seed.html. 163 162 issues/gmwheat.html#. onU.S. wheat introduction GMO spring http://www.worc.org/issues/art_ wheat export markets andprices, 161 160 17.http://hayandforage.com/ar/Japan-Approves-RR-Alfalfa/.February Hay &Forageorg/news/2005/0805/081205/alfalfa.shtml; Grower. 2006.Japan approves alfalfa, Roundup Ready 159 http://www.wa-hay.org/resources/.see the Washingtoncorrespondences between State Hay Growers andMonsanto Association andForage Genetics, Weekly, August 12.http://www.seedquest.com/News/releases/2005/august/13194.htm; To view 158 launch. product www.wlresearch.com/WLHaymakerWinter06FP.pdf. full with forward 157 %20Woodward.pdf. 18-19.www.wa-hay.org/.../Roundup%20Ready%20Alfalfa%20Test%20Kits%20and%20Influence%20-January of 2006Washington State Hay Growers Association’s Conference Annual &Trade Show, WA, Kennewick, 156 asp?pageid=116276. 155 org/ud2005/ujan05a.html. 154 Mark Toro AndersonHay including El Inc., andGrain, alfalfa, andHaykingdom. Export, 1?OpenView June (accessed in large 2005).Three RR companies of submittedexport in opposition comments 153 %20Woodward.pdf. 18-19.www.wa-hay.org/.../Roundup%20Ready%20Alfalfa%20Test%20Kits%20and%20Influence%20-January of 2006Washington State Hay Growers Association’s Conference Annual &Trade Show, WA, Kennewick, , 152

Russell, Dave. 2007.Monsanto, announce AgroSciences SmartStax,” Dow Brownfield for Ag News 2007.Monsanto, AgroSciences. Dow Agreement Paves Dow the Way for Industry’s First-Ever, Eight- for noweligible lowerrisk whouseMonsanto technology farmers 2007.Corn Checkbiotech. advanced Transgenic to Seed: 2004.Gone the in Traditional Contaminants Union Scientists. ofConcerned Seed Tusick, W. Montana communication, July Natural personal 19,2005. Beef, Ibid.;Wisner, potential of The short-term wheat: impacts modified ofgenetically 2003.Market risks R. Ibid. Tri-City growers, worries 2005.Roundup ready alfalfa A. Herald, August King, 5.http://www.newfarm. Moore, T. 2005.Washington Press Capital hay Agriculture at growers balk alfalfa, Roundup Ready Themoving ResearchHaymaker: 2006. Progress andManagement. Roundup alfalfa Alfalfa in ready Woodward, W.T.W. andinfluence teston the market, Proceedings kits alfalfa 2006.Roundup Ready this J. year, 2005. Biotech alfalfa Bernick, AgWeb.com, March 17.http://www.agweb.com/get_article. 2005.Growers Avoid A. King, Tri-City Altered Alfalfa, 20.http://www.saynotogmos. Herald, January No. found Docket 04-085-1at in be https://web01.aphis.usda.gov/regpublic.nsf/04-085- can Comments Woodward, W.T.W. andinfluence teston the market, Proceedings kits alfalfa 2006.Roundup Ready 87 Resources