AC21 report reflects difficulty of finding consensus on 'coexistence'

WASHINGTON, Dec. 14, 2016 - Farmers who use different growing systems to produce different products received some guidance on how to coexist – along with a primer on the difficulty of finding common ground – with the release of a final report by the Advisory Committee on Biotechnology and 21^st Century Agriculture

The AC21 report includes two stand-alone documents, along with recommendations that they be distributed to prompt discussions among farmers: “A Model for Convening Local Coexistence Discussions” and “Factors for Farmers to Consider When You or Your Neighbor Are Growing an Identity-Preserved (IP) Crop.” IP crops are generally organic or non-GE, but the report also said they can include seed and certain GE/GMO crops (such as those with new functional traits).

The “Factors” document put it simply: “Coexistence is a two-way street: It builds on the shared social responsibility of farmers and requires collaboration and compromise on both sides of the fence line.”

But some of the advice sounded like it was putting too much responsibility on the farmer who isn’t using genetically modified seed, committee member Isaura Andaluz said in comments attached to the report. “The assumption is that because a non-GE crop (IP) receives a ‘premium,’ they therefore must assume full responsibility to keep the product free from unintended (GE) presence. This is not true coexistence,” said Andaluz, who is co-founder of Cuatro Puertas, “guardian to the largest collection of native and drought-tolerant seeds in New Mexico,” according to the Organic Seed Growers and Trade Association’s website (Andaluz is on the board.)

Andaluz and Charles Benbrook of Benbrook Consulting Services filed statements critical of the AC21 report, which was submitted to Agriculture Secretary Tom Vilsack Dec. 8. Many of the other members who signed on to the report submitted separate statements that were included in the final product, reflecting the difficulty in finding consensus.

Benbrook said the committee ignored important issues such as international trade and was unwilling to address new coexistence challenges such as “approval of a new generation of multi-herbicide tolerant crops.”

The report’s findings “boil down to: The USDA and agricultural community should hold meetings, and local coexistence discussions should be facilitated,” Benbrook said in his comments. “Such meetings are unlikely, and even if they occur, there is no reason to believe they will foster changes in farming practices of sufficient scope to have a meaningful impact on coexistence.”

In particular, Benbrook said the committee avoided discussing “the responsibility of technology developers to help cover costs imposed on non-GE, IP producers as a result of gene flow. Many farmers and agribusiness interests do not accept responsibility for costs and lost income imposed on non-GE, IP producers.”

Benbrook’s call for “clear-cut, seed quality recommendations” was echoed in other comments. Laura Batcha, CEO of the Organic Trade Association, said that “easier access to information about the GE content of seed intended for use in growing non-GE crops would aid producers serving GE-sensitive markets, and food companies seeking non-GE ingredients.” USDA should make this a top priority “to move forward with a meaningful commitment to diversity in agriculture.”

And Greg Jaffe, director of the Biotechnology Project at the Center for Science in the Public Interest, said USDA should have done more since the last iteration of the AC21 finished its work in 2012 “to quantify the economic losses incurred by farmers due to unintended presence of genetically engineered material.”

USDA has “identified some minimal data” but “has not designed a specific study on this issue nor have they attempted to collect data from the different stakeholders who might have relevant data,” Jaffe said.

In the 2014 National Organic Survey conducted by the National Agricultural Statistics Service, 1 percent of certified organic farmers in 20 states reported that their economic losses from 2011-2014 due to GE commingling amounted to $6.1 million.

Committee member Keith Kisling, a farmer and former chairman of the Oklahoma Wheat Commission, said the data “showed very low levels of loss” and was both “self-reported and not independently verified.” And Barry Bushue, president of the Oregon Farm Bureau, said National Agricultural Statistics Service survey results confirm that “nationwide the amount of economic loss as a result of unintended presence of GE material, compared to overall production is incredibly small.”

Angela Olsen, senior adviser and associate general counsel for DuPont Company and Pioneer Hi-Bred, said the report resulted from “the diligence, hard work, and discussions of the AC21, and for many members, reflects compromised positions and in some instances, continued areas of respectful disagreement.” She said that “seed quality standards are based upon market expectations and are bound by the limits of biological systems” but that the seed industry is committed “to ensure that quality seed continues to be available to all growers.”

“Certain seed companies may choose, as part of their business and marketing models, to test for GE presence or percentage and provide such information on the seed bag – likely for a premium price – to cater to a small niche market that may be trying to meet certain IP contract specifications,” Olsen said, but added that companies should be free not to do so, as well. “Providing such information on all seed would be unnecessary for most in the marketplace, and would unnecessarily drive up costs for all producers,” she said.

Olsen said that despite the emphasis in the report on seed, there are other potential sources of unintended GE presence, including “machinery or livestock; wind and pollen flow; comingling of product at or after harvest, in on-farm storage systems, or during transport; or comingling in other facilities downstream.”

Lynn Clarkson, a farmer and chairman of Clarkson Grain Company in Cerro Gordo, Illinois, said that finding seed with little GE presence is a challenge but that “the market will again generally sort itself out to meet consumer distinctions.” He added, however, that “by asking seed companies “to deliver seed with a guaranteed GMO level of less than 0.5 percent, buyers are asking seed companies to accept a purity challenge much tighter than that used to guarantee varietal purity.”

Mary-Howell Martens, who runs Lakeview Organic Grain in Penn Yan, New York, said in her comments that the report’s “biggest deficiency” was its “failure to include a recommendation for third-party mediation and enforcement. In order for true co-existence to function, there must be a means for the ‘trespassed against’ neighbor to obtain assistance and support if their neighbor fails to cooperate and or fails to take effective measures to prevent drift.”

Douglas Goehring, a committee member and commissioner of the North Dakota Department of Agriculture, said that “a broad approach on mitigation and managing risk will help all farmers relate to the challenges they operate under every day and encourage them to think about how they may manage differently to prevent soil, weeds, insects, pathogens from moving to adjacent fields or how to minimize impacts on their fields using buffers.”

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