GM Alfalfa Coexistence Plan: Evidence or Ideology?

Posted on September 14, 2013

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This week, the Canadian Seed Trade Association (an industry lobby group composed of seed and seed treatment suppliers), published “Planning for Choice:  A Coexistence Plan for Alfalfa Hay Production in Eastern Canada.” Judging by the “Facilitating Choice Through Coexistence” webpage, this publication appears to be positioned as a “flagship” plan for a larger “coexistence project.”

According to the CSTA, the genesis of the plan was a value chain workshop held in Kitchener, Ontario in October of 2012. Workshop participants represented a broad range of stakeholders from across Canada, in addition to a number of experts on the subject from the United States. The workshop proceedings are certainly worth reading, particularly in contrast to the final product. Indeed, after comparing two, I am left wondering by what kind of strange alchemy the plan is derived from the workshop.

Desire for Coexistence

Back in April, I published a blog post questioning the need for genetically modified RoundUp Ready alfalfa and noted my difficultly in finding anyone who was in favour of the product. It appears that the workshop participants felt the same way. Kurt Schmon of Imperial Seeds in Winnipeg testified:

The value that Roundup Ready Alfalfa brings to a select few is tremendously overshadowed by the value of exports of alfalfa to non-GMO zones, the agronomic benefit of alfalfa and to the economic benefit of the organic value chain. The vast majority of Canadian farmers and our customers do not want this product.

Kelvin Einarson of Forage Seeds Canada, a national organization representing forage and legume seed producers (and a seed growers and former hay exporter himself) stated:

If we can keep Canadian forages free of GE traits we have an opportunity to expand our market
share rather than having markets eliminated because we cannot guarantee the purity.
Perhaps instead of a workshop on coexistence, the Canadian Seed Trade Association should
look at a workshop on how we keep forages GM free in Canada until such time as these traits
are accepted in our markets.

Martin Boettcher, an organic farmer from Ontario seems to have been rather prescient in his remarks:

Where is the economic research, the cost-benefit analyses, behind the decision? As far as I am
concerned, this is an example of politics driving science, not science and market research
receiving approval by political bodies.
I have talked to many conventional and organic farmers and seed growers about GM Alfalfa and
I have yet to meet on who supports its approval. I therefore want to remind everybody that we,
the farmers, are the real stakeholders in this debate. Why have we never been consulted? Is
this the democracy we are taught to be so proud of?

And what of the final plan? While describing the various markets in detail, and noting that some producers had export customers who specifically request GM-free hay, the CSTA studiously avoids taking a stance on the issue, choosing instead to state twice in the plan:

It is acknowledged that there are very strongly held views on both sides of the debate on GM alfalfa.
This plan does not advocate for or against the commercialization of GM alfalfa. Nor does it favour
one production system over another. This plan strives to anticipate the future. Its purpose is to identify
clear practices that will allow all alfalfa hay production systems to be successful in Eastern Canada.

So let’s look at those practices…

Possibility of Coexistence

The workshop heard from two producers from Washington State and an alfalfa seed company representative who reported their success in segregating GM and conventional and/or organic alfalfa in their production chains. (In an ironic twist, the CSTA plan was published the same day news broke in the United States regarding the possible presence of GMO alfalfa in conventional hay exported from Washington.)

On the other hand, other participants clearly stated their opinion that “contamination” (to use an admittedly loaded term) was inevitable, citing the example of Triffid flax. Kelvin Einarson commented:

In an article in the Western Producer on May 7, 2010, Trish Jordan, a spokesperson for
Monsanto Canada said – and I quote: “Monsanto has worked closely with alfalfa seed and
forage industry groups to ensure the risks of gene escape and market damage are minimized.”
End of quote. The key here is the word “minimized” instead of “eliminated”. We are firmly
convinced that this is because there is absolutely no way to eliminate gene escapes. Gene
escapes have occurred in the past and will continue to occur in the future. That is inevitable.

The workshop also featured two presentations on “The Science of Coexistence in Alfalfa Hay”. Dr. Allen Van Deynze of the University of California, Davis discussed gene flow in alfalfa, from both a theoretical and practical standpoint. He also presented research that the cost of segregation increases exponentially as the level of tolerance decreases. He concluded:

In Agriculture and biological systems, coexistence is based on practical non-zero thresholds that allow a diversity of markets to be addressed. [emphasis in the original]

Rene van Acker of the University of Guelph presented the results of a number of studies on feral alfalfa populations in Canada. The research shows that feral alfalfa is common, occurs close to cultivated alfalfa, readily outcrosses with hay and seed alfalfa crops, and forms a persistent seed bank, even when mowed. His conclusion is that feral alfalfa populations “may be impractical to eliminate” noting that “population extinction only possible with complete roadside mowing and strict and long term (>7yrs) absolute prevention of seed addition.” His summary was quite unequivocal:

– Alfalfa has a robust and persistent metapopulation in Canada that will enable novel trait movement and persistence
– this makes absolute trait containment (in a coexistence context) impractical

Workshop participants then spent the afternoon in three break-out sessions, developing coexistence principles for various alfalfa hay markets. The reports of all three breakout sessions are prefaced with the statement that “some participants” made it clear that they did not support the commercialization of RR alfalfa in any region of Canada. The reports then list answers to several questions posed to participants, primarily concerning questions related to means “to reduce or eliminate” gene flow. Several suggestions were made that do appear in the “Best Management Practices” listed in the final Coexistence Plan. One question and answer, however, did not make the cut:

6. What is the capacity of hay producers to undertake the measures identified?

  •  No answer to this question

“Damn the Torpedoes”

A thorough reading of the plan reveals some stunning contradictions:

  1. The plan acknowledges that organic standards have zero tolerance for GMO presence in organic products, yet it never mentions that expert testimony clearly stated this would be impossible and/or impractical.
  2. The plan lists a number of “Best Management Practices” to be employed by growers, yet fails to admit that the growers consulted did not have an answer as to their capacity to perform them.
  3. Van Acker noted that because alfalfa is a crop and not a weed, herbicide references for volunteer control are “almost non-existent,” inadequate, or uneconomical; the plan omits this reality and simply advises farmers to use herbicides listed in provincial guides for weed control to control volunteer alfalfa.
  4. The plan references the studies Van Acker used to demonstrate the threat of feral alfalfa
    (as described above) to support the statement that “feral alfalfa is not expected to be a major risk for GM gene flow.”

Let’s summarize:

  1. Workshop presenters were clear and apparently unanimous that they had no desire to see RR alfalfa introduced (therefore obviating the need for a plan for coexistence).
  2. Stakeholders expressed skepticism that coexistence would be possible, and scientific experts presented evidence supporting the same conclusion.
  3. CSTA moved forward to develop a plan to “allow all hay production systems to be successful in Eastern Canada.”
  4. A true plan for coexistence would address current agronomic, economic, regulatory, and marketing realities, apprise stakeholders of the existing obstacles to coexistence, and recommend means to address these challenges. In contrast, the CSTA plan by turns glosses over, ignores, and fails to recognize the significance of all of these in an apparent effort to justify a preordained conclusion.

What’s most unfortunate here, as is demonstrated by the recent news from Washington, is that those who will pay the highest price for the consequences of premature commercialization are the farmers who do not use the technology and derive no benefit from it. Coexistence is a laudable goal, but the process and the results must respect stakeholder input and be evidence-based. This plan fails on both counts.

The CSTA’s plan for coexistence amounts to little more than a public relations tool, and as such it does a grave disservice to Canada’s agricultural sector.

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Posted in: Agriculture, Organic