On April 16th, 2004 Monsanto submitted a federal petition for commercial introduction of “Round-Up Ready” (RR) alfalfa in the U.S, and on Nov. 24th the USDA began its required sixty day public comment period. Given that alfalfa is a common perennial forage and cover crop used in a wide variety of animal feeds and even eaten by humans, this latest move by Monsanto to bring another genetically modified organism (GMO) into the world is now ringing alarm bells across rural America.
What will be the impact on animals that now consume alfalfa ? from cows and horses to chickens and bees? Will there be adverse health impacts downstream in the human food supply? What about the environmental consequences? Could this latest herbicide resistant GMO crop jeopardize the longterm utility of glyphosate (aka ?Round-Up?) as ?super weeds? emerge? Will alfalfa, itself, become an invasive plant largely immune to conventional control techniques? If there are problems, who will assume liability – the manufacturer, the distributor, the farmer, the consumer? Many of these questions have yet to be resolved and should be before Monsanto is permitted to bring its biotech alfalfa into U.S. agriculture.
Monsanto began work on RR alfalfa in 1998 in collaboration with researchers at Montana State University and within a year there were field trials underway in Wisconsin, Indiana, Iowa, and Idaho. In 1999, Monsanto officially licensed its RR technology for use on alfalfa to Forage Genetics, Land O?Lakes? primary seed research partner. Land O?Lakes is among the major dairy co-ops in the U.S. and has been a major advocate of GMOs since the FDA?s controversial approval of recombinant bovine growth hormone (rBGH) back in the early 1990s. If approved, RR alfalfa will be sold under the Croplan Genetics brand through Cenex Harvest States and Land O?Lakes? Farmland Industries.
Other genetic manipulation of alfalfa is also underway. Researchers at the U.S. Dairy Forage Research Center in Madison, WI are isolating genetic traits to make forage fiber more digestible. At the University of Guelph scientists are trying to splice the bacterium, Pasteurella hemolytica, into alfalfa as an oral vaccine agent for cattle pneumonia. Other University of Wisconsin-Madison researchers are altering alfalfa to produce its own phytase enzymes to improve phosphorus utilization by livestock. It is argued that this could reduce the need for imported mineral supplements such as di-calcium phosphate as well as the threat of manure pollution from concentrated animal feeding operations (CAFOs).
Like Monsanto?s other biotech varieties, farmers who use RR alfalfa will never own the plant or the seed. Instead, they will be leasing a product under a one-sided technology use agreement (TUA) with many restrictions. For instance, Monsanto reserves the right under these contracts to physically inspect (ie. trespass) and remove crop samples to insure compliance. In Canada, Monsanto has a long history of sending ?extortion? letters to farmers whose fields tested positive for their other GMO crop varieties, threatening lawsuits if they did not pay for their ?use? of the patent.
The main rationale offered by the biotech industry for introducing RR alfalfa is that it provides farmers with simpler weed suppression. This is in line with the vast majority of genetic research in agriculture (98% according to one recent USDA survey) geared towards making production easier, not necessarily to improve nutrition or protect the environment. There are already 90 weeds identified as significant in U.S. alfalfa, with 20 major herbicides used, glyphosate among them.
Dubbed ?Queen of the Forages,? alfalfa is a perennial herbaceous legume, known as lucerne in many other countries, originally from the European Caucasus and Central Asia. Since its introduction to North America, alfalfa has been among the top four field crops in the U.S. (along with corn, soy, and wheat). In 2004 the USDA estimated that 77.4 million tons was produced on 22.2 million acres, with an additional 88.5 million tons of alfalfa mixed hay produced on another 39.4 million acres.
Alfalfa is considered the best available animal feed for ruminants and is critical to the dairy industry, providing up to a third of crude protein, half of the calcium, and a quarter of the energy needed on a daily basis by a typical cow. Other livestock sectors which rely upon alfalfa include beef cattle, sheep, chickens, turkeys, and horses. Pelletized alfalfa is a common component of many pet foods for everything from iguanas and parakeets to hamsters and rabbits. Alfalfa also produces a large amount of nectar, up to 1900 pounds per acre, which is why it is so popular amongst beekeepers. In turn, honey bees, alkali bees, and leaf cutter bees are important pollinators for alfalfa producers.
Concerns are growing, though, about the potential adverse impacts of RR alfalfa. Studies are just now revealing the health fallout of too much GMO corn, soy, canola meal, and cottonseed cake in livestock feed. Monsanto uses the Cauliflower Mosaic Virus (CMV) to insert RR traits in its GMO crops, and this same promoter virus in alfalfa could have the potential to disrupt the balance of intestinal microflora and reactivate other dormant pathogens. Other studies have shown a clear downward nutritional shift in GMO crops. For example, beneficial phytoestrogens such as lignan and isoflavon are reduced by 12-14% in RR soybeans compared to conventional soybean varieties.
As with other GMOs, there is the clear danger of ?gene jumping? between RR alfalfa and conventional alfalfa varieties, as well as between alfalfa and wild relatives, such as black medic ? a common naturalized weed in North America. Given the promiscuous genetic dominance of GMOs, this could mean rapid transfer of glyphosate resistance, as well as the spread of other traits (such as enzyme or vaccine production), especially if several GMO alfalfa varieties are approved and put into simultaneous production.
As has been well documented in the case of Bt corn and RR canola, there is obvious potential for ?genetic drift? between fields planted with Monsanto?s RR alfalfa and other nearby alfalfa fields and pastures. Besides wind, insects are particularly good at transporting pollen over long distance, and bees are known to travel several miles in search of alfalfa. Most alfalfa hay is cut after some of blossoms have already bloomed and the pollen is viable. Alfalfa allowed to reproduce also produces a lot of ?hard seed? that can remain viable in soil for years to come.
This threat is of special concern to alfalfa seed growers and dairy/livestock producers who stand to lose their value-added markets and organic certification. Alfalfa seed production is concentrated in just a few northwestern states and provinces and could be vulnerable to genetic contamination. For many dairy farmers who rely on managed intensive rotational grazing (MIRG), Monsanto?s RR alfalfa offers no real benefits, since a healthy pasture has no real ?weeds.? In fact, straight alfalfa often yields less fodder per acre than more diverse forage systems.
Herbicide resistant GMO crop varieties are widely perceived by farmers as just another way to encourage dependence on expensive inputs. Predictably enough, the introduction of RR varieties did lead to a five fold increase in glyphosate use across the U.S. Because alfalfa is perennial and often grown for 3-5 years in a row, the introduction of RR alfalfa could well increase overall herbicide use ? by an estimated 200,000 more pounds per year in California alone. As with other GMO crops, the promised yield gains and cost savings may not materialize, leaving farmers holding the bag for the higher seed price that always comes with Monsanto?s patented technologies.
An estimated 5% of U.S. alfalfa production is also exported ? 2.9 million metric tones in 2002 worth $480 million. About 75% of this forage market is in Japan where consumer awareness and resistance to GMOs is high. U.S. refusal to sign the Convention on Biological Diversity, including the Cartagena Protocol (which went into effect on Sept. 11, 2003), or to even mandate segregation naturally fuels suspicions of biotech ?dumping? overseas and prejudices other GMO-free U.S. exports. Some also foresee the rapid international spread of RR alfalfa through less formal means, such as casual travel of pollen, seed, and fodder between the U.S., Canada, and Mexico. About 7% of alfalfa seed in the U.S. is also eaten by humans in the form of sprouts, and such natural food consumers are also highly wary of potential GMO contamination.
Those in the business of prairie restoration, as well as many conservationists and officials interested in controlling invasive plants on public and private lands, are concerned that the introduction of herbicide-resistance traits in a perennial like alfalfa could make their job more difficult. After just six years of planting RR crops across the U.S., the number of glyphosate-resistant weeds doubled. As super weeds emerge, chemical control will shift to more toxic, persistent, and less desirable herbicides such as 2,4-D and Paraquat.
The fact that alfalfa has a taproot up to 20 feet deep and complex symbiotic relationships with nitrogen-fixing bacteria exacerbates the potential environmental consequences. Alfalfa is an important crop in many field rotations, contributing up to 200 kg of soil nitrogen per acre per year. Researchers in Arkansas, though, have found an adverse impact on symbiotic nitrogen-fixing bacteria associated with soybeans after treatment with glyphosate. Scientists have also noted an increase in the presence of the fungal disease, Fusarium, on RR crop varieties.
In weighing the relative costs and benefits of bringing RR alfalfa to market, many people remain unconvinced. Is this technology really necessary to grow alfalfa or is it just another marketing opportunity for agribusiness? Are there not cheaper weed control options that do not pose such serious threats to the future of farming in the U.S.?
Comments on Monsanto?s petition to the USDA to introduce ?Round-Up Ready? alfalfa (be sure to reference Docket #04-085-1) can be sent to:
Regulatory Analysis and Development, PPD APHIS, Station 3C71 4700 River Road Unit 118 Riverdale, MD 20737
Email comments can also be submitted to:regulations (at) aphis.usda.gov An online form is also available at: http://www.aphis.usda.gov/ppd/rad/cominst.html
For the Federal Register Notice (published 11/24/04), Monsanto?s GE alfalfa petition (submitted 4/16/04), as well as the USDA/APHIS environmental assessment go to: http://www.aphis.usda.gov/brs/not_reg.html or call #301-734-5715
For more info on how you can get involved in this and other related GMO issues, contact: Farmer to Farmer Campaign: #877-968-3276 or Family Farm Defenders: #608-260-0900