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 1997 received 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. Let there be no confusion: organic consumers absolutely do not want GMOs or GMO contamination in their food and seed.