Shortly after I published my last blog post on GM Alfalfa Coexistence, a couple of people contacted me, wanting to know my reaction to the specifics of the Best Management Practices that were included as part of the plan.
Of course, shortly after the post went up, it was also confirmed that the hay exported by a Washington producer was indeed “contaminated” by GMO alfalfa, so it could certainly be argued that the concept of coexistence has already been severely undermined. Nevertheless, let’s proceed to look at the Canadian Seed Trade Association’s proposed measures – this was actually what I intended to do in my first post, before the glaring disconnect between the consultation and the final product blew me off course.
Many of the practices identified are basic record-keeping exercises which are certainly valuable in terms of demonstrating compliance and allowing trace-back. I’ll set those aside to focus more on the mechanics and practicality of other recommendations, using the same headings identified on the checklist. I’ll also insert some of my own recommendations.
The key recommendation here is to “purchase certified seed.” The success of this measure depends entirely on the seed industry’s ability to maintain segregation between GMO and non-GMO alfalfa seed during breeding, multiplication, grow-out, and the subsequent cleaning, packaging, distribution, and sales of alfalfa seed.
This coexistence plan focuses on the production of alfalfa for hay, so addressing potential issues in seed production is clearly outside the scope of the project. Nevertheless, seed purity needs to be addressed here – experience with other crops suggests that genetically-modified seeds are present in many non-GMO seed lots. I would add that growers should:
- demand that non-GMO alfalfa be accompanied by test results demonstrating that the seed lot purchased tests negative for the presence of GM material.
The idea of making seed companies accept the return of unopened GM seed is a positive step towards sharing the responsibility of coexistence between all the players (as are the record-keeping and monitoring requirements for both GM and non-GM alfalfa growers. Now if they would accept responsibility for supplying verified non-GMO seed in the first place…
This is where the rubber really hits the road. The record-keeping, equipment cleaning, crop labeling, and segregated storage ideas are all common practices in organic production, so they should be feasible measures for all growers to take. Two other aspects of stand management are problematic, however:
1. “Mow any alfalfa on field edges, in ditches and roadsides near GM and organic alfalfa hay fields – before flowering”
This seems to make perfect sense, and it does – in an ideal world. The reality is much messier: field edges, ditches, and roadsides in many parts of the country (especially where livestock and therefore alfalfa are produced) do not lend themselves to easy mowing. Steep slopes, rocks, rotten fences, trees, brush, and other obstacles can pose real hazards to thousands of dollars worth of equipment and the people operating it. If mowing these areas were easy, they’d probably already be harvested as hay! The timing can be a challenge, too – farmers racing to finish harvesting hay while the sun shines are unlikely to devote extra time to making sure that rough areas are tended before the feral alfalfa in them flowers.
It’s rather ironic, too, that at a time when farmers are being encouraged to create habitat for pollinators (i.e. areas of wild flowering plants), these guidelines are asking alfalfa growers to do the exact opposite!
In addition, the research presented at the workshop by Rene Van Acker clearly demonstrates that feral alfalfa cannot be effectively controlled by in the short-term by mowing. (The claims made about feral alfalfa in the plan are actually directly contradicted by Van Acker’s research on a startling number of points.)
2. “Harvest GM alfalfa fields before 10% bloom”
Again, theory and reality don’t always match up. This past spring, I drove past many hay fields in mid-June that had yet to be harvested due to the prolonged wet weather. Other fields were pock-marked with patches of un-cut hay marking spots that were obviously too wet to cut. It’s quite likely that many of these areas weren’t cut again until second cut, simply because they stayed wet while the farmer moved on to other urgent work.
Overall, it is difficult to imagine a GM alfalfa grower going to all of the extra time and expense to protect someone else’s market. The experience of refugia plantings in Bt corn crop makes it clear that even when it is clearly in the best long-term interests of the producers themselves, and even when it is relatively simply and convenient, compliance with trait stewardship requirements tend to decline rapidly over time.
Establishing buffer zones which can be easily managed around plantings of GM alfalfa is probably a better way of controlling potential pollen/gene flow, but this would obviously not be a popular measure with farmers wanting to plant their fields to GMO alfalfa. Without more research, I can’t say how large these buffer zones would need to be – maybe a reader can help in this regard.
End of GM Alfalfa Stand Management/Post GM Alfalfa
The recommendations here are for a combination of herbicide “burn down” and tillage. This is in keeping with Van Acker’s research. However the plan fails to mention that the choice of following crops in the rotation needs to take into account the possibility of “hard seeds” germinating in future years; therefore, following crops must permit the removal of volunteer alfalfa plants (i.e. by herbicide compatibility).
The photo below illustrates the challenge nicely: on a family walk this afternoon, we happened to be crossing a field that had been growing alfalfa in 2003, the year we bought the farm. The field was plowed the following year, and has since seen a rotation of cover crops and vegetables, with multiple passes of mowers, plows, discs, and cultivators, but never another alfalfa seed. Shortly after the thought to check for alfalfa popped into my head, I spotted this plant along our path – it’s hard to say how many more plants like it are out there!
Again, it is not clear here how much time and effort and how many limitations of crop choices GM alfalfa growers will be inclined to tolerate, or as the photo illustrates, how many years they’ll be willing to maintain their vigilance!
A New Approach to Coexistence
According to the Canadian Seed Trade Association, coexistence planning is based on the following principles:
The goal of coexistence planning is to provide producers with freedom of choice and opportunity to pursue diverse markets.
Coexistence plans will be based on good communication and mutual respect between neighbours, individuals and companies who have opted for different approaches to production, to capture different market opportunities (e.g. organic, conventional and biotechnology)
Coexistence plans are built on science based stewardship programs and tools for monitoring the efficacy of such programs.
Coexistence standards/practices/tolerances must be practical, achievable and economically feasible, and must be focused on market opportunity They are not meant to address health and safety of food, feed and the environment, which is the focus of regulation.
Those who benefit from each system must accept the responsibility for implementing the practices required to achieve coexistence
Considering the reality of what’s happened in Washington, the disconnect between the information delivered at the workshop and the final plan, and the challenges identified in implementing the best management practices, it’s very difficult to see how the present plan meets any of these principles.
In my opinion, achieving meaningful coexistence will involve turning the whole process on its head. Instead of making farmers responsible for trying to achieve impossible standards of purity, the seed industry, if it wants to sell a novel product, must ensure that their product does not interfere with the orderly movement of products already in the marketplace. (Would Apple be allowed to sell an iPhone that generated electrical interference for other, competing devices?) International market acceptance is the only secure, reliable way to achieve true coexistence in keeping with the above principles.