Click here to read the story on the True Food Network website

March 3, 2010

 

Comments: Docket No. APHIS-2007-0044

Regulatory Analysis and Development PPD/APHIS

Station 3A-03.8

4700 River Road Unit 118

Riverdale MD 20737-1238

 

   On our family farm we raise certified organic seed potatoes and vegetable and grain seed in northern Maine.  We have been farming organically for 34 years.  We have been certified organic for 28 years. We have been selling directly to organic consumers for over 30 years and we are keenly aware of their expectation that organic food and seed be bonafide organic, pure and free of contaminants.

   Our conclusions after studying the draft Roundup Ready Alfalfa Environmental Impact Statement(EIS) is that USDA-APHIS has done a remarkably inadequate and incomplete job in preparing the draft EIS which has led them to the erroneous position of advocating for RR Alfalfa deregulation. USDA needs to reverse course and prevent the planting of GMO alfalfa.

   We are absolutely astounded by the baseless APHIS assertion on pgs 135-136 that GMO contamination of organic crops such as corn, soybeans and canola is not impeding development of the organic sector. Because of widespread genetic contamination of organic canola by GMO canola, the organic canola industry has collapsed causing millions of dollars of  farm gate and market loss. We consider collapse an impediment to market development. It must be understood and clearly stated that the organic consumer equates organic with freedom from GMO content.  The customer is always right. It is incomprehensible and impossible to imagine that USDA-APHIS could be unaware that another USDA agency, the National Organic Program, in 1997received well over 200,000 written responses, at that time the largest display of public participation in the history of U.S. administrative procedure, to its early draft National Organic Rule. The principle reason for objection, common to virtually all letters submitted, was outrage that GMO crops were not specifically prohibited  from the proposed federal definition of organic. In time, USDA-NOP revised their Rule and defined GMOs as an “Excluded method” [See NOP Rule Section 205.2 “Excluded methods” and prohibition under Section 205.105(e)] prohibited in organic production. Lett here be no confusion: organic consumers absolutely do not want GMOs or GMO contamination in their food and seed.

   We firmly believe that GMO use fundamentally and by its very nature is synonymous with off target GMO contamination.  The essense of GMO crops is that they are faulty products by design because use according to direction (i.e. Monsanto “best practices”) results in unwanted contamination of organic and non-GMO crops. Not only are these contamination events not isolated incidents, as the biotech industry would have us believe,  but the US Government Accountability Office(GAO) has stated “ the ease with which genetic material from crops spread makes future releases likely.” Since the pollen of alfalfa is extremely mobile and weather conditions are known to occasionally prevent hay cuttings until after pollen shed, contamination of non-GMO and organic alfalfa seed is inevitable.GMO contaminated “organic” alfalfa seed is worthless in the organic market.  Since we sell organic alfalfa seed, collapse and disappearance of the organic alfalfa market, such as has happened to organic canola,  will cause us to experience thousands of dollars of lost income and our customers will lose access to a valuable and popular organic resource.

   We dispute USDA assumptions on the value of Roundup Ready crops such as alfalfa. In the Fall of2009 it was widely reported that at least nine weed species are now resistant to glyphosate (Roundup).  As the number of resistant weeds trends upward the arguable value of  Roundup Ready GMO crops must correspondingly go down.  Additionally, biotech has touted the view that GMO crops are better because they reduce chemical use.  Yet a recent study by the Organic Center explodes this myth by documenting that Roundup Ready crops have contributed to an increase in herbicide use of 318 million pounds over the last thirteen years  We have further concerns that the widespread use of glyphosate due to Roundup Ready crops is increasing background levels of fusarium in conventional farm fields and lowering food quality with increased levels of vomitoxin. .

   Throughout American agricultural history the preponderant land ethic has been the concept of “fencing in”.  That is, our neighbor is free to do whatever he wants on his farm so long as he contains hisactivities onto his farm by fencing them in That is, his fence prevents his cattle from coming onto our farm andeating our corn. We are not required to “fence out” our neighbor's cows because he respects and fulfills the traditional community land ethic by exercising self-restraint. This ethic builds community and makes good neighbors and has been proven by the test of time.

   The biotech industry, patent holders of the faulty GMO technology used by farmers since the mid 1990s, has turned this traditional land ethic upside down. Now biotech asserts that it is the organic  farmer's responsibility to fence out biotech's unwanted GMO pollen and that the buffer area between  their genetic polluting GMO crops and neighboring organic crops must come from the organic side of the fence. Some crops, for example, corn and canola disperse pollen over greatdistances.  And in the case of alfalfa,which is bee pollinated, pollen distribution can range up to 5-6 miles. Theseare tremendous distances far greater than the land base of virtually all farms.As organic farmers we reject this foreign self-serving land ethic imposed upon American farmers by an arrogant biotech industry. We have a right to grow crops free from GMO contamination for our families and for the customers who buy from us and provide our livelihood. We assert that right and it is up to USDA to protect us and other organic farmers from the genetic trespass of GMO crops.Towards this end, USDA should immediately ban GMO crops beginning with Roundup Ready alfalfa.

   On Wood Prairie Farm we maintain a protocol for testing seed in an effort to determine whether there is GMO contamination in certain organic seed lines that are potentially subject to contamination, seed which we grow and use and sell or resell.  We perform standard 10,000 seed PCR tests at a cost approaching $1000 annually. Seed lots which test hot and contain GMO contamination do not meet market requirements for sale as organic seed and are completely worthless.  In some cases an organic seed lot might represent a one of a kind line selected over many years of careful development.  Such potential loss resulting from GMO contamination would be irreplaceable and the financial loss would be tremendous and very difficult to calculate.

   While we bear these GMO testing costs ourselves, this situation is unfair because organic farmers did not create this GMO pollution problem and instead we are victims.  GMO testing costs as well as compensation for the consequences of GMO contamination should be totally borne by the biotech companies which own the technology patents and which are the owners of the genetic pollution. We look to USDA to correct thisinjustice.  USDA should create a large indemnification program, funded by the biotech industry out of which compensation could be made for such GMO inflicted costs such as testing, loss and bankruptcy from GMO contamination and loss of reputation

  In summary, we urge you to reconsider your plans to deregulate RR Alfalfa. Such deregulation would place an undue burden on organic farmers, create a threat to the integrity of the organic market and create severe regulatory difficulties with the continued contamination of the organic seed supply by a technology that is a clearly legally excluded method from organic production systems.

 

Sincerely,

 

Jim & Megan Gerritsen

Wood Prairie Farm

49 Kinney Road

Bridgewater, Maine 04735 

 

We now have the Carrot Harvest Video up on You Tube

 
   On Dec 14, 2009 the USDA released its draft Environmental Impact Statement on GMO Roundup Ready Alfalfa, grudgingly forced by lawsuit and the courts to carry out this legal requirement.  The USDA draft EIS is an outrageous snow job that negates any environmental or economic impact caused by GMO alfalfa.  The draft EIS clearly backs Monsanto and works against the best interests of the public and organic and non-GMO conventional farmers by completely deregulating GMO alfalfa and allowing its unlimited planting nationwide.  Alfalfa is the United States' fourth most widely grown farm crop and it is a critical feed for livestock including organic dairy cattle.  Because alfalfa is insect pollinated it will become impossible to prevent alfalfa seed contamination by GMO pollen, thereby resulting within a few years in the GMO contamination of all alfalfa fields, organic or otherwise.  The USDA must be stopped from this insider GMO-precedent establishing whitewash and we must protect the consumer's right to choose food that is free of GMO content.
  Written comments are urgently needed that counter the USDA draft EIS.  If you write only one letter this year to help protect our planet and our children from a dark Monsanto-GMO future, this is it!  Please do it today! Comment deadline Feb 16, 2010.  Thanks! Jim
Click here to get background on the GMO Alfalfa issue. http://www.non-gmoreport.com/ArchivesTwo/org&nongmo_feb10.pdf
Click here to learn specific talking points and where to address your letter http://www.seedalliance.org/Advocacy/alfalfa-alert/

January 21, 2010

 Wood Prairie Potatoes fly to New York to appear tomorrow morning - January 22 - with Martha Stewart  on NBC

Chef Robin White, our Potato Sampler of the Month customer and friend has a new Blog, full of good food ideas.   I love her new entry on Haiti. 

   I absolutely do agree that those of us who farm must do our very best to provide our customers with safe and nutritious food by designing and executing sound production systems. I think the highest quality food comes from family farmers who embrace the quality-by-design approach in their organic culture and that their results are far superior to those found in the competing quality-by-regulation system.

    Russell Libby, Executive Director of the Maine Organic Farmers and Gardeners Association (MOFGA)  is an unrecognized hero for the organic community.  He has been shuttling to Washington DC trying to influence food safety legislation with the goal of  providing the public with good food and keeping the regulatory requirements for family farmers practical and achievable.  Here are a couple of links to recent articles on food safety written by Russell.   Jim

MOFGA article by Russell Libby

MOFGAPositionStatements/FoodSafety

American Agriculture.    December 31, 2009
   The U.S. Department of Justice and the U.S. Department of Agriculture are for the first time soliciting public comment on the appropriate role for antitrust and regulatory enforcement in American Agriculture.  

   Public workshops will occur over the course of 2010, but today, December 31 at 6pm EST, is the final day to submit written comments.
   What follows are the comments we submitted today. 

 

                                                                                              WoodPrairie Farm      

                                                                                                49Kinney Road

                                                                                                Bridgewater,Maine 04735

 

                                                                                                December31, 2009

 

Dear Attorney General Holder and Secretary Vilsack,

 

   We are Americanfarmers.  On our farm in northern Mainewe have been growing organic seed and tablestock potatoes; organic seed,vegetables and grain for over 30 years. Over this period of time we have observed an alarming contraction of theagricultural and food infrastructure.

    In the past therewas relative diversity of markets for farm crops and similar diversity forinputs needed on the farm such as seed and supplies.  As time has gone by there has been a dramatictrend nationally towards consolidation and contraction which we believe hasresulted in widespread loss of market opportunity and downward price pressureon farm gate prices.  As an example, inthe 1980s and 1990s we had four New England organic produce wholesalers that wesold to.  Through consolidation thatnumber is now down to one.

   Additionally, farminput prices have steadily increased, sometimes dramatically, as for example,fertilizers, equipment and fabrication metal, and hybrid and GMO seed.  Along with these steep price increases havecome occasional availability problems, such as that of rubber tires for farmequipment.  We attribute many of thesemaladies to the growing problem of corporate concentration.

        The overalleffect has been a drastic squeeze on family farmers resulting in bankruptcy andforced exit from agriculture.  Tragic asthis has been for individual farmers and our rural communities, this loss offamily farmers and the resulting consolidation of food production makes thewhole of agriculture and our nation's food resource much more precarious.  As grocery chain consolidations advance,retail price levels continue to escalate with minimal relation to farm gateprices. Livestock production has to a great extent shifted from the fields offamily farms to inhumane factory confinement units which produce meat ofdubious quality. The United States is at a point where monolithic seed and foodcorporations have been allowed to grow so large that they represent a seriousthreat to our society, our democracy and our security.

  We believe it isappropriate to view this dilemma as a major national security issue.  It is in the United States' best interest tohave widespread land ownership by family farmers and healthy food production onAmerican soil.  The destabilizing ofAmerican agriculture and the increasing reliance on foreign production must beseen as a real threat to our nation's security particularly now as we enter anera marked by the end of cheap oil. Unchecked corporate consolidation andconcentration is the chief factor in this failing agricultural scenario andthis must be reversed through enforcement of antitrust law.

  Two finalpoints.  First, the patenting of lifeforms and the resultant patenting of seeds, as well as the potential patentingof plant traits (for example, the red color in red lettuce) has been a colossalerror of catastrophic proportions and must be reversed.   A free society can not endure when it's mostprecious food resources are appropriated by corporate theft.

  Second, one of thetools that these corporate consolidators have been employing for their ownadvancement is the clamor for increased universal hygiene regulations.  Under the guise of “food safety,”corporations promote regulations that, not surprisingly, only they are able toafford to implement.  It is essential that we expose this charade as an attack on family scale business.  In reality, these corporations are attempting to deny Americans choice and access to wholesome food produced locally and by family operations. Burdensome, expensive and unnecessary  hygiene requirements have the very real likelihood of pushing out of business the family businesses that  Americans are increasingly voting with their pocketbooks to support. The corporate operation that weekly processes 50million servings of salad mix, while focused on maximizing short term profits,clearly needs government regulation.  Buta family farm is different.  His or her entire business is built upon quality by design.  Success and well being is attributable to integrity, reputation, permanence and membership in the community.  This family farmer does not need government regulation. When it comes to real food safety the government should focus onthe corporate problem, not on the family farm solution.

  In conclusion, we hope you will take this opportunity to enforce antitrust statutes, restrain corporate control and abuse, and allow to prosper a democratic, de-centralized and vibrant food system.

 

Jim & Megan Gerritsen

Wood Prairie Farm

Bridgewater, Maine

You are encouraged to submit comments of your own to the Department of Justice and the USDA.  But today, Thursday December 31 at 6pm EST, is the last day to do so!  Click here to sign a petition to DOJ/USDA supporting good agriculture or to learn how to submit your own comments.  

Food Democracy Now