The Honorable Thomas Vilsack, Secretary
United States Department of Agriculture (USDA)
1400 Independence Avenue SW
Washington, DC 20250

March 4, 2014

Re: Docket No. APHIS-2013-0047

Dear Secretary Vilsack:

The Pennsylvania Association for Sustainable Agriculture (PASA) is one of our nation’s largest member-based, sustainable farming organizations, with about 6,000 mostly farmer members located primarily throughout Pennsylvania and across the Mid-Atlantic region. Our mission is to promote profitable farms that produce healthy food for all people while respecting the natural environment. In keeping with this mission, we wish to express our grave concerns regarding the issue of “Enhancing Coexistence” as framed by the Report of the AC21 Committee in 2012.

For the more detailed substance of our comments, we will merely refer to those being submitted by the National Sustainable Agriculture Coalition (NSAC) and endorse those for your consideration, since supporting the process of assembling those comments has been where the bulk of PASA’s time on this issue was spent. However, we also have several brief comments to make for the sake of emphasis, as follows:

 PASA feels very strongly that a crop insurance model is not the appropriate path for USDA to follow in compensating for the effects of genetic drift and contamination on organic and sustainable farms that are otherwise free of genetically engineered (GE) seeds and other materials. Apparently, the AC21 Committee agrees with us on this, since the individual comments contained in the 2012 report indicate significant and consistent displeasure for this approach, even if for varying reasons. Compensation does need to happen, but through a fund developed from a surcharge on the seeds, chemicals and technology fees associated with GE farming techniques. It would be unprecedented and frankly unethical to expect a damaged farm to bear the cost of defending itself against aggressive technology doing harm with no offsetting benefits to the aggrieved party.

 It is very important to PASA that the USDA not expect coexistence issues to be resolved among neighboring farmers in such a way that pits farmers against other farmers, as a mostly passive process is likely to do. The technology developers and owners are just as important to this equation as the farmers, and should be expected to take responsibility
for assuring that the technologies they have created do no harm as a priority. This is common in the automobile industry, for instance, but only in the face of significant government intervention, regulation and expectations for continuous improvement within the industry.

 While PASA is concerned about pollen drift and the inadvertent contamination of non-GE crop varieties being grown on organic, sustainable and many conventional farms, by far our bigger concern is the even greater tendency for pesticides of various sorts used in conjunction with the GE technology to drift onto neighboring farms. We feel it is especially poignant to note that public comments on the potential approval of seed varieties engineered to be resistant to 2,4-D are also being collected at this time, since 2,4-D is well-known to drift even farther than other chemicals more commonly used today. The point is, farmers of specialty crops and other non-resistant broadleaf varieties stand to realize much larger losses from chemical drift than other farms will due to genetic contamination. We are also greatly concerned about the cumulative effects of pesticide use on the efforts of many farmers to maintain improved pollinator habitat, and on the pollinators themselves. How can one calculate and compensate the real losses to farmers, and to the health of our people, if even one specialty crop producer goes out of business as a result of this new technology? And there will be many…

 PASA’s greatest concern, however, lies in the term “coexistence” itself, since it connotes a passive approach to a very active and pernicious problem. Much of the GE technology in use on farms today offers very little demonstrated benefit – except perhaps fields that appear attractive in the sense that they are “weed free,” at least until the weeds gain resistance to the chemicals used to support the GE production systems. It is well-known that many non-GE varieties achieve yields that are comparable to, or even exceed their GE competition, and modern farming systems utilizing diversification, crop rotation and emphasizing soil quality as the top priority can improve both yields and farm profitability even farther. If only the research dollars available for these alternatives equaled what has gone into developing GE approaches, surely we would be far ahead in our overall efforts to feed the world and conserve its resources. So who, Mr. Secretary, will compensate future generations of our children for what we have shortsightedly implemented today? There can be no effective coexistence without first insisting on excellence in our research and development of farming methods that assure sustainability for generations to come.

Again, we commend to you the more detailed comments submitted by NSAC, and urge you to consider a much more active and effective approach to dealing with the problems presented by GE technology as it is manifested on farms and in the food system today and for the future.

Yours sincerely,

Brian Snyder
Executive Director