U.S. Secretary of Agriculture Tom Vilsack announced recently that USDA will publish a notice in the Federal Register asking for comments on coexistence in the U.S. for biotech crops and conventional and organic crops. This is in response to a recommendation from USDA’s Committee on Biotechnology and 21st Century Agriculture. The alfalfa hay industry in eastern Canada (Ontario and Quebec) has gone through a process to develop a voluntary plan for coexistence for the region.
Perennial biotech crops and forages are not currently available for commercial planting in eastern Canada. Alfalfa genetically modified to be resistant to glyphosate herbicide (Roundup) was given full approval for food, feed and environmental release by Canadian regulators in 2005. In 2012 Roundup was approved for over-the-top use on Roundup Ready alfalfa. Ontario and Quebec has about 70 percent of Canada’s dairy production, the primary market for alfalfa hay. Only about 1 percent of eastern Canada’s alfalfa is exported, but that is expected to increase.
The Canadian Seed Trade Association (CSTA) took the lead in facilitating the coexistence plan to prepare farmers for the possible planting of biotech alfalfa. It established a set of Best Management Practices (BMPs) to allow biotech alfalfa hay production to coexist with non-biotech alfalfa. The plan does not advocate for or against the commercialization of biotech alfalfa and does not favor one production system over another. The plan identifies practices that will allow all alfalfa hay production systems to succeed in eastern Canada. Everyone in the industry does not agree with every feature of the plan.
About 1-2 percent of the alfalfa produced in eastern Canada is certified organic, but the issue is not just organic. Many growers of conventional alfalfa have contracts that limit the amount of biotech alfalfa to be found (low level presence) or have a zero tolerance. Commercial alfalfa seed is not produced in eastern Canada which simplifies the coexistence requirements.
The U.S. Agricultural Attaché in Canada in the 2012 Biotechnology Annual Report explained that the coexistence between biotech and non-biotech crops is not regulated by the Canadian government. The producers of alfalfa that wish to avoid a low level presence of biotech events have to be proactive in achieving that outcome and receiving a premium when their alfalfa products are sold. Growers of organic alfalfa are required by existing government regulations to have distinct buffer zones or other features sufficient to reasonably prevent prohibited substances or techniques from affecting organic production. All producers will have an incentive to voluntarily find a cost effective solution to keeping fields separate.
The plan is built on five ‘principles of coexistence’: 1) producers’ freedom of choice to pursue diverse markets, 2) good communications and mutual respect between farming neighbors and companies who have different approaches to production and markets, 3) coexistence standards and practices that are practical, economically feasible and focused on market opportunities, 4) stewardship programs based on science, and 5) those who benefit must accept the responsibility for implementing practices.
The biology of alfalfa is part of the coexistence effort. Alfalfa seed is formed predominantly by cross-pollination and relies on insects (bees) to “trip” the flowers to release pollen. Alfalfa requires an insect pollinator to visit each flower; wind alone cannot act as a pollinator. Alfalfa has varying degrees of self-incompatibility, and self-fertilization may occur, although this typically results in fewer and less competitive seeds than cross-pollinated cases. In the eastern Canadian environment, alfalfa requires 6-8 additional weeks after fertilization to develop viable seed. Some portion of every lot of seed is considered “hard seed” which has post-harvest dormancy and may remain dormant after planting. It can subsequently germinate in field conditions, and represent a source of volunteer alfalfa plants in following crops. There are no known wild relatives of alfalfa, but feral alfalfa on roadsides or in ditches does occur.
The process of establishing a coexistence plan began with the CSTA board convening a value chain workshop in October 2012 with 45 participants, representing the seed sector across eastern Canada. After the meeting, the draft plan was sent to the participants and other interested groups for additional input. After the coexistence plan was finalized, a group of ‘experts’ decided the BMPs based on the plan.
BMPs are outlined in the plan for biotech alfalfa hay and for alfalfa hay destined for non-biotech markets. Accurate record keeping is required for both practices and all seed company stewardship requirements must be met. Biotech seed should not be planted for any use that does not require active management and timely cutting to avoid a chance of seed production. All equipment must be thoroughly cleaned after use and before moving to other areas. Neighboring farmers are to talk to each other and be aware of other alfalfa fields and pollinator colonies. All field edges, roadsides and ditch banks are to be inspected and mowed early if alfalfa plants are present. Biotech alfalfa is to be harvested at 10 percent bloom or before. Stewardship agreement practices are to be followed for taking out a biotech stand and volunteer plants are not to become established after removing a stand. Producers are to watch for weed shifts with biotech alfalfa and follow stewardship requirements.
Canadian Certified Organic producers must be in compliance with standards set by the Canadian Food Inspection Agency. To avoid low level presence of biotech traits, organic alfalfa producers and conventional producers serving markets with low or no tolerance for biotech should chose fields that have not previously grown biotech alfalfa and are not near fields currently growing biotech alfalfa. The seed used should be free of biotech traits. Care should be used in hay harvesting and storage to avoid low level presence of biotech traits.
The critical factors in this plan are the balance of costs and returns that each producer has for complying with the program and the efforts that technology companies make to help implement the plan. Costs and benefits for all producers should encourage them to respect the rights of other producers and the production systems they use.