Guest guest Posted January 24, 2005 Report Share Posted January 24, 2005 Alfalfa Alert Correction! JoAnn Guest Jan 23, 2005 16:55 PST Sun, 23 Jan 2005 13:59:42 -0800 truefo- Add to Address Book Alfalfa Alert Correction! angelpri- Hello JoAnn, 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 your patience and support! ********************************************************************* email: regula- 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 regula- 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 usuallygrown 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 lead to 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. Eighteenpounds 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 Phytoestrogensin 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 ascompared 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 *********************************************************************** ge- AIM Barleygreen " Wisdom of the Past, Food of the Future " http://www.geocities.com/mrsjoguest/Diets.html Quote Link to comment Share on other sites More sharing options...
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