beyond factory farming speaks on GE alfalfa

Here’s the latest from beyond factory farming:

Here is what Beyond Factory Farming submitted to the USDA in response to
their call for public input on the Environmental Assessment of
Glyphosate Tolerant Alfalfa. In the States, when they approve a GMO for
environmental release and sale they “deregulate it”. Glyphosate Tolerant
(GT) is Roundup Ready. There are serious implications for sustainable
agriculture in Canada if it is grown n the USA. Read our submission to
learn more.

The USDA’s comment period closes on March 3. You can find out more about
the issue and submit your own comment using the Canadian Biotechology
Action Network’s handy web page at

Numbers of submissions will make a difference, so please take a few
minutes to put in your own.


Glyphosate Tolerant Alfalfa and Sustainable Livestock Production
Submission opposed to the deregulation of gylphosate tolerant alfalfa.

Submitted to the USDA on behalf of Beyond Factory Farming, Feburary 2010.

The USDA is considering deregulating genetically engineered glyphosate
tolerant alfalfa (also known as Roundup Ready Alfalfa). This would lead
to the unconfined release of the plant into the North American environment.

Beyond Factory Farming is a national organization in Canada that
promotes socially responsible livestock production. Socially responsible
livestock production ensures that the costs of livestock production are
not externalized onto neighbours and the public, and also ensures that
livestock production promotes positive social values such as health,
biodiversity, water quality, community economic development, animal
welfare and fair livelihoods for workers and farmers.

The deregulation of glyphosate tolerant alfalfa in the United States
threatens socially responsible livestock production in Canada as well as
the United States.

Beyond Factory Farming supports certified organic farming, particularly
mixed farming that includes livestock, as well as the certified organic
production of feed crops. Beyond Factory Farming also promotes grass-fed
livestock production, also know as pastured beef, pork and poultry.

If glyphosate tolerant alfalfa is grown commercially in the United
States it will inevitably cross-pollinate with non-genetically
engineered alfalfa which is grown on conventional and organic farms, as
well as with feral alfalfa which grows wild in ditches, wilderness areas
and abandoned fields. Alfalfa is insect-pollinated by both domestic
pollinators (leaf-cutter bees, honeybees) and wild pollinators. Cross
pollination will occur as a result of foraging activities of
pollinators. Seed produced as a result of cross pollination will carry
the DNA of glyphosate tolerant alfalfa, and will confer the trait on its

The contamination of non-genetically engineered alfalfa crops will
result in the eventual contamination of alfalfa seed stock, through
cross pollination and/or admixture. Since the use of genetically
engineered seed is prohibited in certified organic agriculture, it will
become increasingly difficult to impossible for farmers to find seed
which does not contain genetically engineered DNA. Further, the farmers
will risk cross-pollination of their crops from neighbouring
contaminated stands and roadside plants. Organic certification rules
require that farmers take measures to eliminate any contamination from
genetically engineered plants that may occur on their farms. In
practice, this will mean that in order to maintain organic
certification, alflafa will not be able to be grown on organic farms.

Without alfalfa being grown on organic farms, there will be a severe
loss of feed for certified organic livestock and dairy production.
Alfalfa is an important, nutritious feed, particularly in northern areas
where feed must be stockpiled as hay for the winter months. The alfalfa
plant is able to fix atmospheric nitrogen and convert it into a form of
nitrogen useable by plants through a symbiotic relationship it has with
certain soil bacteria that colonize its roots. Alfalfa is thus able to
increase soil fertility, which improves productivity of farmland. The
nitrogen that alfalfa makes biologically available is also converted to
plant protein within the plant itself. This is why alfalfa is such an
important feed crop for meat and dairy animals which have high protein

Canadian consumers are increasingly turning to certified organic foods.
The growth in the organic sector is approximately 20% per year. Organic
meat and dairy is an area poised for even greater growth as processing
capacity is developed. In addition there is a high proportion of
imported organic food from the USA. The introduction of genetically
engineered alfalfa will reduce volume and the range of products that can
be sold organically, as the loss of organic alfalfa will have a severe
impact on the viability of organic dairy, beef, and pork production.

Canadian consumers of grassfed beef and pork are health conscious and
environmentally conscious. The strong points for pastured meat include
its higher proportion of healthy fats and its environmental benefits,
such as biodiversity, erosion-prevention, and carbon sequestration
resulting from year-round cover – all of which occur when land is grazed
rather than cultivated. The infiltration of glyphosate tolerant alfalfa
into these lands would compromise the product’s health claims, reduce
the sector’s customer base, and lead to a smaller market and smaller
land base for this type of environmentally friendly animal husbandry.

Canadians are concerned about the impacts of deregulation of glyphosate
tolerant alfalfa in the United States for two main reasons:
contamination of alfalfa through imports to US hay and seed, and
simultaneous deregulation of genetically engineered alfalfa in the
Canadian jurisdiction.

Canada’s process for approving (deregulating) genetically engineered
crops has several stages. Health Canada must approve crops for food and
feed safety, and the Canadian Food Inspection Agency (CFIA) must approve
crops for environmental release. Canada requires crop seed varieties to
be registered through the CFIA before they can be sold or used to grow a
commerical crop. No variety of glyphosate tolerant alfalfa seed has yet
been registered in Canada, so it is still illegal to grow or sell
glyphosate tolerant alfalfa in Canada.

Canada’s regulatory system has been strongly criticized by farmers for
not taking into account the impact of genetically engineered varieties
upon markets. There is a strong movement of farm organizations seeking a
reversal of Canada’s environmental release of glyphosate tolerant
alfalfa. Monsanto and Forage Genetics International have stated their
intention to commercialize glyphosate tolerant alfalfa in Canada and the
United States simlutaneously. Therefore, it is important to us to ensure
that deregulation does not occur in the USA, as it would promote the
fast-tracking of variety registration, leading to deregulation of the
crop in Canada as well.

Because glyphosate tolerant alfalfa has been approved for health safety
and environmental release it would be possible for hay produced from
glyphosate tolerant alfalfa from the USA to be imported into Canada if
the crop is deregulated in your country. It is very important to protect
the integrity of Canada’s alfalfa, and thus our certified organic farms,
by preventing contamination by imported hay, which may contain viable
seed. If American hay contains genetically engineered alfalfa Canadian
farmers may need to implement a de facto boycott of risky imports.

We strongly urge you to deny the application to deregulate glyphosate
tolerant alfalfa in the United States. The negative impacts of
deregulaton are broad, significant, far-reaching, and irreversible. The
beneficiaries of deregulation are not disadvantaged, and their interests
should not be put ahead of those of the larger population and future

Cathy Holtslander, on behalf of
Beyond Factory Farming
#200 – 416 22nd Street East
Saskatoon, SK
S7K 0C2

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