March 4, 2014
Regulatory Analysis and Development
PPD, APHIS Station 3A-03.8
4700 River Road Unit 118
Riverdale, MD 20737-1238
Re: U.S. Department of Agriculture Docket No. APHIS-2013-0047
Dear Sir or Madam:
We welcome the opportunity to provide comment to the U.S. Department of Agriculture (USDA) regarding their request to identify ways to foster communication and collaboration to further agricultural coexistence. Our organizations have been active participants in the dialogue undertaken by the USDA’s Advisory Committee on Biotechnology & 21st Century Agriculture (AC21) since it was reconstituted in 2011. These comments reflect many of the recommendations that were made over the course of the five, face-to-face meetings of the AC21 in 2011 and 2012, as well as written comments submitted by AC21 members to the final report presented to Secretary Vilsack in November 2012. We applaud the USDA’s decision to move forward with a key recommendation of the final AC21 report to foster communication and collaboration to strengthen coexistence.
Our organizations strongly believe that coexistence is working. Across the U.S., multiple production and cropping systems are thriving in response to market demands. Coexistence is not a new practice, nor is it unique to biotechnology-derived crops. Individual farmers routinely incorporate multiple production practices within a single operation. Coexistence is not about health or safety; it is about finding ways to improve working relationships when different production systems are used in close proximity. During the AC21 meetings, the AC21 members discussed how coexistence has been accomplished through local and regional farm level practices such as separating crops by distance, utilizing different planting times, contracts, seed quality management systems, minimizing physical seed mixing, and respecting and communicating with neighbors. Further, during the course of the AC21 meetings, no evidence was presented that might indicate that economic harm is routinely being experienced by farmers due to the unintended presence of GE material. So, we agree with USDA’s goal to further education efforts to strengthen collaboration between neighbors.