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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.
Click
here to read the rest of our comment on our blog.
Wood
Prairie
Farm Home Page.
Click here for our Wood
Prairie
Home Page to order Organic Seed Potatoes
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