OFRF Comments on Agricultural Coexistence

May 11, 2015

Re: Public Comments on Docket No. APHIS-2013-0047

On behalf of the Organic Farming Research Foundation (OFRF), I submit the following comments on the U.S. Department of Agricultureʼs (USDA) request for public input on enhancing agricultural coexistence (Docket No. APHIS-2013- 0047).

The Organic Farming Research Foundation (OFRF) is a national, public interest organization founded in 1990 to foster the improvement and widespread adoption of organic farming systems. The organization was founded as a response to rising demand for organic agriculture research, extension and education to meet the information needs of a growing community of organic farmers and to educate the public and policy decision makers about organic farming issues.

While we are pleased that our OFRF Director of Research was invited to attend the USDA Stakeholder Workshop “Key USDA Activities Already Underway in Response to Recommendations From the USDA Advisory Committee on Biotechnology and 21st Century Agriculture (AC21)” and “New Proposed USDA Activities in Response to Recommendations From the USDA Advisory Committee on Biotechnology and 21st Century Agriculture (AC21)” held in Raleigh, NC on March 12 and 13th, we are concerned by the lack of balance and scientific integrity during  several of the presentations. Clearly much work remains before the U.S. Department of Agriculture (USDA) understands the documented scientific benefits of organic agriculture and OFRF would like to work with the Department to play a role in advancing this work.

The comments and recommendations of OFRF are based on our extensive experience and research on organic farming systems.

National research to determine the causes of incidental transgene presence.

Because no one agency at USDA has the full responsibility to regulate the impact of transgenic crops, organic farmers face two challenges. 1) increased rate of pesticide drift due to gaps in regulation, and

2) uncontrolled gene drift that can lead to transgenic sequences in organic and identity-preserved seed and crops.

OFRF supports a national research effort to identify the causes of incidental transgene presence, to determine at what stages of production and distribution these occur and to identify solutions for the users of GE technology to address the ongoing problem of incidental transgene presence in organic crops.

Evaluation of the commercially available non-GE and organic seed varieties.

OFRF supports the reestablishment of the National Genetic Resources Advisory Council. Their future report evaluating available non-GE organic seed varieties and identifying market needs for producers serving GEsensitive markets will be helpful for organic farmers. Once this report is complete, OFRF supports USDA targeting additional resources to ensure increased organic and public cultivar development. These steps would ensure that USDA helps reverse the trend of fewer public plant breeders along with the loss of biodiversity and genetic resources. Given the challenges related to food security and a changing climate, our country needs to focus on maintaining and increasing a diverse stock of plant and animal genetics.

Update procedures and best management practices for GE traits in plant germplasm and breeding stocks.

OFRF supports a revision of procedures and best management practices for GE traits to reflect the changing research environment and concerns of organic farmers. To maintain genetic diversity, USDA must protect our nationʼs seed supplies from transgenic sequences and keeping them true to type.


OFRF is committed to working with as a partner with USDA to represent the needs of the organic research community and organic farmers. The issues we raise in our comments reflect our communication and work with the broader organic community.

Unfortunately, without a balanced and clearly defined process that reflects the shared responsibility between the producers of GE crops and those who suffer loss of market value due to the unintended transfer of


transgenic sequences, co-existence will not occur. US agriculture is at a critical juncture as we try to balance food security and a changing climate with an increased need for genetic diversity. Given these high stakes, voluntary solutions to GE contamination are not sufficient.

OFRF asks that USDA take the lead on this issue to ensure there is shared responsibility for the incidental presence of transgenes in organic crops.

Thank you for your time and attention.  We are happy to provide more detailed perspective on any of these points. We look forward to continuing our work with USDA on behalf of organic agriculture.


Brise Tencer

Executive Director