Comment to USDA by March 4 - Can Organic and heritage seeds and GMO seeds coexist?
GMO Agricultural ‘Coexistence’ Rule: COEXISTENCE ≠ GMO CONTAMINATION PREVENTION
Obama’s Agriculture Department wants to act on a specific set of implicit anti-science assumptions that undergird a coexistence policy for GMO and non-GMO farmers. This involves the genetic science equivalent of climate change denial: It requires we ignore the threats and damages posed by the indisputable facts of introgression, horizontal gene transfer, resistance of targeted organisms, and other effects meticulously documented by an emergent predictive ecology of transgenic crops and their impacts on native land race heirloom varieties and their wild relatives.
The USDA is asking for public comments on a proposed policy for agricultural “coexistence”. This can be read as an attempt to impose a policy of détente between GMO and non-GMO farmers and handlers. How will this relationship of coexistence and cooperation be defined and managed? The deadline for comments was extended from January until March 4, 2014. I invite all my fellow heirloom plant breeders and seed savers, both farmers and handlers, to post comments by the deadline. The links are provided below. I ask that you consider posting comments in which you reject the policy of coexistence. Among many reasons for this rejection is the fact the rule will impose an environment that can never be “GMO-free” even if farmers as a class eventually were united in their preference for non-GMO practices and methods.
This means that thousands of plant breeders and seed savers in the U.S., including skilled indigenous farmers who are responsible for the origin, preservation, and development of our nation’s plant genetic resources and especially the infinite and still evolving diversity of heirloom and native crops, will have to sacrifice this heritage for the sake of the antagonistic claims of the profit makers whose product threatens the genomic integrity of the so-called Mesoamerican Vavilov zone. Simply put: As a seed saver and plant breeder I believe the coexistence policy infringes on our ability to manage and protect this bio-cultural heritage and to defend our own property rights against damages associated with the uses of commercial agricultural biotechnology.
The proposed rule violates the Obama Administration’s self-professed adherence to the Principles of Environmental Justice outlined in Executive Order 12898. In the longer term perhaps the rule will not pass judicial muster? The rule can be seen as a sneaky way on getting Monsanto and other corporations another layer of protection against those who would bring damage claims for genetic pollution. It could actually mean that farmers will have to forfeit the ability to file future claims of economic injury and damages against Monsanto and other purveyors of biotechnology, since coexistence might imply a neutral litigation-free and imposed arbitration scheme. We have already seen how well that has worked out for workers and labor unions. Arbitration of this sort always favors management and capital above the claims of workers, farmers, and other marginalized groups.
Coexistence means that we have to adapt to the likelihood of transgenic contamination of heirloom and /or organic cultivars through introgression and other disruptions of our land races’ genomic integrity.
According to the USDA, coexistence is the principle that the relationships between GMO and non-GMO farmers can be strengthened. A USDA Blog entry explains the objectives of the coexistence policy initiative:
U.S. farmers in the 21st Century engage in many forms of agriculture, including conventional, organic, identity-preserved, and genetically engineered (GE) crop production. USDA is unequivocal in its supports for all these forms of agriculture. We need all of them to meet our country’s collective needs for food security, energy production, carbon offsets and the economic sustainability of rural communities. Our goal is to promote the coexistence of all these approaches through cooperation and science-based stewardship practices.
Exactly what the USDA means by “science-based stewardship” remains entirely unclear but many of us doubt that this will include the agroecological and ethnoscientific knowledge of indigenous farmers and other so-called protected classes. If it does not, then we have a serious environmental justice and civil rights problem unfolding before our eyes.
While it is true that U.S. farmers follow different models, the USDA has over the past half century consistently demonstrated a program budgetary and research and development bias toward ever-larger capitalist growers. Beyond the scandalous decades of racism and gender discrimination in the credit markets and local FSA committees, the USDA’s other agencies have also failed to deliver equitable support and services to non-GMO producers. Pro-GMO investments outstrip those allocated to nonGMO heirloom farmers across agencies like the AMS, ARS, NRCS, NIFA, REE, etc.
Instead of pursuing an agricultural coexistence policy, the Obama Administration needs to assign an environmental justice inspector general to investigate the USDA for continued discriminatory practices, especially as this involves inequitable allocation of assets toward the larger corporate-run industrial GMO monoculture operations that benefit from the scale of disproportionate investments the USDA makes in support of these capitalist interests against non-GMO family farms and smallholder farmers.
I remind my readers that this has previously been subject to successful lawsuits over civil rights violations by the USDA against African American, Native American, Latina/o, and women farmers. (The settlements were outrageously unfair). The coexistence policy will result in the enlargement of the class of farmers who are experiencing the disparate impacts of a policy that violates environmental justice principles by encouraging a new form of institutionalized discrimination toward these protected groups and their efforts to flourish as organic, identity-preserved farmers and producers of heirloom varieties through heritage seed saving and plant breeding. This actually also applies to breeding of farm animals.
Like other attempts at “enforced cooperation” involving unequal political economic powers, the imposition of a top-down expert-driven apparatus will force all farmers to get along while continuing to privilege the corporate GE sector in all areas of the Department’s mission – research, subsidies, payments, and credit. The policy instead should start with a moratorium on further commercial-scale planting of transgenic crops – and especially the first generation glyphosate-resistant and Bt transgenics that have resulted in a “GE treadmill,” with super weeds and resistant bugs and worms, and the reality of the generalized collapse of biodiversity in refuge buffers and corridors.
All the while, the proposed rule will encourage further simplification and obscuring of the serious and intractable problems posed by a specific set of implicit anti-science assumptions that undergird the coexistence policy. This involves the genetic science equivalent of climate change denial and requires we somehow accept or ignore the indisputable facts of introgression, horizontal gene transfer, and resistance of weeds and insects that have been meticulously documented through the better late than never attention to an emergent predictive ecology of transgenic crops.
I know farmers who want off the GMO treadmill and are having a hard time figuring out how. One farmer, from North Dakota, told me she hates the emptiness of a GMO monoculture – the veritable lack of life. She despises the huge scale of mechanization and the massive fuel costs. Above all, she hates the continuing decline of the towns and communities around her. “I became a farmer because of my family ties to this region only to see how this modern industrial form of agriculture is destroying it.”
Many GMO farmers do not want to coexist. Instead, they want to find a way out of the dominant paradigm of biotechnology. They seek alternatives and want to be farmers again, rather than mere precision contract-guided growers. An increasing number are sickened by their status as GPS-tethered bioserfs. They are stressed and sickened by the heavy debt and economic stress of the high annual costs associated with being a Monsanto contract grower. If the USDA supported these farmers, this could significantly enlarge the number of farmers who follow organic and non-GMO practices, joining the fastest growing segment of the agricultural producer sector.
And you know what? The USDA has no idea how to help them. It cannot provide much guidance or material and technical support for the growing number of farmers who wish to make a transition from GMO to non-GMO. No one bothered to do collaborative research with farmers despite the fact that a growing number of us want off the GMO treadmill. The USDA has been too busy discriminating against the new minorities because it was too busy retrofitting and servicing all the GMO corporate factory farms.
The National Organics Coalition (NOC) believes USDA should be focusing on GMO Contamination Prevention. As part of their opposition, they have crafted a very useful set of briefing points to assist you with the development of a public comment on this policy. I am sharing this information with the hope that my farmer colleagues, fellow seed savers and plant breeders, who understand that the only way to protect agricultural biodiversity is through a non-GMO environmental policy. There is to be no coexistence if Monsanto gets the right to introgress my dancing maíz de concho.
Leave a comment by March 4 at the USDA website. Or submit mail comments to: Docket No. APHIS–2013–0047, Regulatory Analysis, and Development, PPD, APHIS, Station, 3A–03.8, 4700 River Road Unit 118, Riverdale, MD 20737–1238.