Fwd: FW: Alfalfa Alert Correction!

[Guest guest]

Sorry, they just sent me a correction. Love you, Dory

 

 

>

>

>

>

> Thanks to all of you who caught the address error in our Round Up Ready

Alfalfa alert! Our email formatting combined the two addresses into one

unusable one.

> Correct addresses are below along with the original text. We also

apologize to those of you who received duplicate newsletters yesterday, we

are working on the problem and will have it fixed for the next newsletter.

Thank you for you patience and your support!

>

>

****************************************************************************

*

> email: regulations

> web form: http://www.aphis.usda.gov/ppd/rad/cominst.html

>

> PLEASE REMEMBER TO PUT Docket # 04-085-1 IN YOUR SUBJECT LINE

>

> January XX, 2005

>

> Regulatory Analysis and Development, PPD

> APHIS, Station 3C71

> 4700 River Road – Unit 118

> Riverdale, MD 20737

> regulations

> http://www.aphis.usda.gov/ppd/rad/cominst.html

>

> Re: Comments – Monsanto Roundup Ready Alfalfa

> Docket #04-085-1

>

> To Whom It May Concern:

>

> I am a _________________ (e.g. True Food Network member, concerned

consumer, parent, teacher, dairy farmer, rancher, beekeeper, horse breeder,

cut flower grower, conservationist, pet owner, etc.) opposed to the

deregulation of Monsanto’s herbicide tolerant alfalfa variety currently

being considered by the USDA in the docket referenced above.I have a wide

variety of concerns that, as yet, have not been fully evaluated by the USDA

and other regulatory agencies.

>

> Like its RR predecessors, Monsanto's RoundUp Ready GE alfalfa poses

serious risks, but it also poses some new and unique risks that must be

fully addressed, including a full environmental impact statement (EIS),

before commercial approval.

>

> RoundUp Ready alfalfa would be the first genetically engineered perennial

agronomic crop with the RR trait, and the dynamics of a RR perennial are

somewhat different from those of annual crops like corn and soy,presenting

somewhat different risks. For annual crops, the time span for using

glyphosate (RoundUp) is one growing season; for perennial crops, multiple

applications can be made for several years (alfalfa is usually

> grown for 3-5 years)(Doll, Jerry D. The Future of RoundUp Ready Alfalfa.

> 2003. Proc. Wisconsin Fertilizer, AgLime, and Pest Management Conf. Vol.

42), resulting in an overall increase in herbicide usage. It is estimated

that in California alone, this could result in as much as 200,000 pounds

more herbicides a year(National Center for Food and Agriculture Policy.

Plant Biotechnology: Current and Potential Impact for Improving Pest

Management in U.S. Agriculture – An Analysis of 40 Case Studies –

“Herbicide Tolerant Alfalfa”. June 2002. Gianessi, Leonard P.; Silvers,

Cressida S.; Sankula, Sujatha; Carpenter, Janet E).

>

> The RoundUp Ready cropping strategy encourages excessive herbicide

> application over a longer period of time during the growing season, which

can leadto leaching into the soil and groundwater and the absence of cover

crops (treated as weeds with RoundUp), which would deprive the soil of

their soil-building and nutrient stabilizing benefits (Pridham, Jaqueline.

The Impact of RoundUpReady Alfalfa on Organic Systems. 2003). Alfalfa is

cross-pollinated by bees, creating the very real possibility of RR alfalfa

cross pollinating with neighboring conventional and organic alfalfa crops.

For organic producers this could cost them their certification, as alfalfa

is relied on not only as animal feed, which must be GE-free in order

> to be used in an organic system, but also as a nitrogen-fixer in their

soil. Neither of these options are viable if GE alfalfa is present in

> an organic producers fields. Alfalfa plays an integral role in

replenishing nitrogen in the soil as green manure and maintaining soil

> nutrient levels (Pridham, Jaqueline. The Impact of RoundUpReady

> Alfalfa on Organic Systems. 2003). For both organic and conventional

growers this contamination possibility poses incredible risks to their

livelihoods as well as our environment.

>

> The RoundUP Ready System in Alfalfa Production

> Already, RR soy and corn are widespread in US acreage. Commercializing RR

alfalfa would hand over three of the top four US field crops to

> Monsanto’s RR system. This possibility brings up many issues.

>

> Increased Herbicide Use

> Already, there have been five-fold increases in glyphosate use in the US

because of the adoption of the RR system. Alfalfa will be no

> exception. Given this rise in use, there are potentially significant

impacts on biodiversityand human health due to increased levels of

> toxic chemicals on our food. Glyphosate is generally believed to be

immobile in soil as it readily binds to soil particles; however,

> a recent study found that glyphosate can be readily released from soil

particles, and therefore may leach into water. Though glyphosate itself is

believed to have a relatively low acute toxicity to mammals, preparations

of glyphosate often include a surfactant that increases toxicity to fish

and other aquatic species. There are some indications that chronic

> exposure to glyphosate can be harmful if administered at high doses over

long periods of time (MacRae, Rod ; Penfound, Holly; Margulis, Charles.

> Against the Grain: The Threat of Genetically Engineered

> Wheat. Greenpeace. November 2002.). RoundUp can be toxic to fish

depending on several factors including hardness of water, the age of the

fish and water temperature. In some situations, concentrations as low as 10

parts per million can kill fish.

>

> Changes to Weed Populations and Impacts on Biodiversity

> As RoundUP becomes the main herbicide used in RR crop systems, weed

populations tend to shift. As RoundUp use is increased and substituted

> for other products, the result is a shift in what weed species survive.

These changes could ripple through the ecosystem as food sources for birds

and insects change or disappear through this weed control program. In

> addition, spray drift to borders and neighboring native vegetation can

cause damage to wild plants and flowers. This can also lead to harmful

> effects on birds, insects and other animals that depend on this

vegetation for food or shelter. There may also be impacts on soil biota due

to

> over-reliance on one herbicide. Researchers in Arkansas found that

glyphosate has a negative effect on a nitrogen fixing bacteria that lives

in association with soybeans. Another recent study showed a higher

incidence of a fungal disease, Fusarium, on soybeans treated with

Glyphosate. These suggest that increased glyphosate use may disrupt soil

organism population dynamics. This can have a large effect on the ecosystem

because changing soil dynamics usually trigger changes in crop management,

often leading to more fertilizers, changes in crop rotation and more or

different pesticide applications, these in turn have larger impacts on the

soil and ecosystem (MacRae, Rod ; Penfound, Holly; Margulis, Charles.

Against the Grain: The Threat of Genetically Engineered

> Wheat. Greenpeace. November 2002.).

>

> RoundUp Resistant Weeds

> With the increase in adoption of the RR system comes the increase of

RR-resistant weeds. After just 6 years of widespread planting, RR

> crops may have doubled the number of glyphosate-resistant weeds that

developed in the previous 25 years (Canon, S. 2001. Weeds Developing

Resistance to Widely Used Herbicide, Some Say. The Star (Kansas City),

> 21 August 2001.). Scientists have already documented

glyphosate-resistance in many problem weeds. In 2001, Marestail

(Horsegrass) was found to survive even 10 times the recommended application

rate of RoundUp. Waterhemp, Ryegrass and Quackgrass have also presented

signs of resistance. The number of resistant weeds is expected to increase,

and as such will force farmers to use additional, and likely more toxic,

herbicides to manage these resistant weeds.

>

> Alfalfa Poses Unique Risks

> As alfalfa is used primarily for livestock feed, many questions arise as

to how such a change in diet could effect the livestock and the products

> they produce. Alfalfa is used in feed for dairy cows because it is lower

in fiber and higher in protein than any other single forage. Eighteen

> pounds of alfalfa provides one-third of the fiber, over a third of the

crude protein, one-fourth of the energy and half of the calcium required

for a high level of milk production (National Center for Food and

Agriculture Policy. Plant Biotechnology: Current and Potential Impact for

Improving Pest Management in U.S. Agriculture – An Analysis of 40

> Case Studies – “Herbicide Tolerant Alfalfa”. June 2002. Gianessi, Leonard

P.; Silvers, Cressida S.; Sankula, Sujatha; Carpenter, Janet E.). There are

currently studies underway examining the risks of transgenes from feed

being passed on to gut microflora in livestock – a huge concern in the case

of alfalfa.Recent studies have also questioned whether genetically

engineered crops have the same chemical composition as their conventional

counterparts. The biotech industry has always claimed that the GE varieties

are “substantially equivalent” and that nothing but the gene they have

introduced has changed. But scientists are beginning to see differences in

GE and non-GE crops. A 1999 independent study analyzed the phytoestrogen

concentrations in two varieties of genetically modified herbicide tolerant

soybeans and their conventional counterparts grown under similar

conditions. An overall reduction in phytoestrogen levels of 12-14 percent

was observed in the genetically altered soybean strains(Alterations in

Clinically Important Phytoestrogens

> in Genetically Modified, Herbicide-Tolerant Soybeans. Journal of

Medicinal Food v.1, n. 4, 1jul99.Marc A. Lappé, Ph.D., Center for Ethics

and Toxics, Gualala CA E. Britt Bailey, M.A., Center for Ethics and Toxics,

Gualala,

> CA Chandra Childress, M.S., Children’s Hospital Medical Center,

Cincinnati, OH Kenneth D.R. Setchell, Ph.D., Children’s Hospital Medical

Center, Cincinnati, OH). Phytoestrogens, which include lignans and

isoflavones are oestrogen-like compounds which occur naturally in many

plants and fungi and which are biologically active in humans and animals.

Soybeans are rich sources of phytoestogens in the human diet and are

currently believed to reduce the risk of certain cancers, especially those

which are hormone dependent such as breast and prostate. Such a change in

nutritional value in GE alfalfa could greatly diminish its value as animal

feed.

>

> Another significant difference between forage and grain production is

that weed control in alfalfa seldom results in higher forage yields as

> compared to soy, corn or wheat. This is because weeds are usually

harvested along with the alfalfa for feed. In fact, overall forage yields

may be lower when weeds are controlled and higher when they are not (Doll,

Jerry D. The Future of RoundUp Ready Alfalfa. 2003. Proc. Wisconsin

Fertilizer, AgLime, and Pest Management Conf. Vol. 42).

>

> In addition, While only 5% of US grown alfalfa is exported, 75% of those

exports go to Japan. If RR alfalfa is allowed on the market those exports

could be lost. The largest buyer in Japan has already stated they would not

buy any US wheat if GE wheat was commercialized due to concerns of

contamination and lack of segregation in our current agricultural

> system. Alfalfa could likely face the same rejection.

>

> I believe Monsanto’s RoundUp Ready alfalfa poses serious ecological,

agronomic and health risks while offering little benefit to farmers and no

> benefit to consumers. Commercializing RR alfalfa will benefit only

Monsanto’s corporate profits at the expense of consumers, farmers and the

environment. As such, I believe a full EIS is needed to fully evaluate the

possible impacts before commercial approval is considered.

>

> Thank you for taking my comments into consideration.

>

> Sincerely,

>

> NAME

> ADDRESS

>

>

> ***********************************************************************

> gean

>

> You are d as: dz1

> To reply to this email with in the subject