OFRF Public Comment to USDA RE: Coexistence



March 4, 2014           

Secretary Tom Vilsack

U.S. Department of Agriculture

1400 Independence Ave, SW

Washington, DC         20250

Re:       Request for Public Input, Enhancing Agricultural Coexistence

            Docket No. APHIS–2013–0047

Dear Secretary Vilsack,

            Founded in 1992, the Organic Farming Research Foundation (OFRF) is a national, grassroots organization whose mission is to foster the widespread adoption and improvement of organic farming systems.  We appreciate this opportunity to respond to the USDA’s request for stakeholder input about ways to foster communication and collaboration among those involved in diverse agricultural production systems in order to further agricultural coexistence.

             OFRF commends Secretary Vilsack for revitalizing the Advisory Committee on Biotechnology and 21st Century Agriculture (AC 21) and for including in its renewed charge the consideration of appropriate compensation mechanisms to address economic losses suffered by farmers from the unintended presence of genetically engineered (GE) materials in their crops.  By doing so, USDA acknowledged the concerns long expressed by certified organic and other producers of non-GE crops and the millions of American consumers who support those producers that such unintended presence imposes an unwarranted and unnecessary economic burden.  Chartered in part to advise the Secretary on “protecting…a competitive, vibrant, and diverse farm economy”, the AC21 is uniquely empowered to defend farmers against adverse economic impacts such as those imposed by genetic contamination from GE-crops, or to identify appropriate compensation mechanisms should such impact occur.[1]

            Regrettably, the recommendations included in the AC21’s report Enhancing Coexistence released on November 12, 2012 are inherently incapable of protecting the rights and interests of farmers and consumers seeking to avoid genetic contamination of crops and foods produced free of such contamination .  First and foremost, the AC 21’s recommendations perpetuate the current voluntary approach which absolves those who produce and plant GE crops from any meaningful responsibility for preventing contamination.  This failure to assign responsibility where it appropriately rests is evident in the AC21’s statement that “The unintended presence of such (genetic) materials in others’ crops should not be a topic for assigning fault or blame.”[2]  Would USDA support a similar conclusion if the subject at hand were pesticide drift or untreated wastewater runoff from a CAFO facility onto a neighboring farm or community?

            The time is past due for USDA to acknowledge that contamination of organic and non-GE crops with unwanted genetic material constitutes a preventable problem which causes many farmers significant economic harm.  USDA should also develop and implement prevention and compensation mechanisms under which those who commercialize and plant GE crops assume responsibility for all subsequent outcomes, not solely the ones which benefit them.  USDA must look for creative opportunities to initiate this policy transition, such as the partial deregulation of GE alfalfa which it considered in 2011, since the existing regulatory framework wantonly disregards the legitimate rights of certified organic and other producers raising non-GM crops.

            OFRF appreciates USDA’s willingness to engage in dialogue with all stakeholders on the subject of coexistence and agrees that the successful resolution of these matters is vital for the future of American agriculture.  However, before communication and collaboration can enable us to move forward, we must recognize that positive outcomes are contingent upon reciprocity between all stakeholders when it comes to their rights and responsibilities.

Thank you very much,


Amy Bodiker, Interim Executive Director, OFRF




[2] Enhancing Coexistence: A Report of the AC21 to the Secretary of Agriculture, p.6.  http://www.usda.gov/documents/ac21_report-enhancing-coexistence.pdf


Organic Farming Research Foundation

P.O. Box 440, Santa Cruz, CA 95061

(831) 426-6606