As you may be aware, Roundup Ready (RR) Alfalfa was re-regulated and further plantings stopped in March of 2007. The USDA-APHIS (Animal and Plant Health Inspection Service) is in the process of conducting an environmental impact statement on Roundup Ready. This will take some time to complete, probably 2009. They would like to know whether their list of issues (see 18 points below) are complete or not, but they also want to know about the specifics of the issue.

This is your chance to weigh in on an issue important to alfalfa growers. Make sure your voice is heard! Any comments must be received by APHIS on or before Wednesday, Feb. 6. During the previous public comment period on the deregulation of Roundup Ready alfalfa in 2005, very few alfalfa growers commented. Although this is clearly not a popularity contest, at that time over 80% of the comments were against, 20% pro. Now is your chance to weigh in and voice your views, pro or con.

What do you think about this technology? Some of the key issues raised by APHIS (see details below in items 1-18 and on the Web site) are those best answered by growers: For example:

  • Will this technology put organic alfalfa farmers out of business? Is it possible to keep RR alfalfa in hay or seed production fields from contaminating non-RR alfalfa or organic alfalfa? Can RR alfalfa successfully co-exist?
  • What are the benefits vs. the drawbacks of RR alfalfa? If you've planted it, would you do so again? Does it dramatically change your weed control for the better or worse?
  • How does this technology compare with other (conventional) herbicides or practices? What other herbicides are used? How do the costs differ? (Be specific -- you know these issues better than the regulators!)
  • Are there environmental negatives or benefits that aren't included in questions 1-18 below?
  • Would this technology have positive or negative effects on animal or human health, to your knowledge? Would the RR technology increase herbicide use on your farm? Would there be plus or minus environmental consequences of adapting (or not adapting) this technology?
  • Do you think growers have the techniques (and the will) to prevent weed resistance from becoming a problem?
Suggestion: Be brief and to the point, and cover some of the critical issues raised by APHIS from your own experience. Better to be in-depth with a few of the issues raised, rather than covering all of them.

To comment:
  1. Portal: Submit or view public comments and view supporting and related materials electronically at www.regulations.gov/fdmspublic/component/main?main=DocketDetail&d=APHIS-2007-0044
  2. Postal mail/commercial delivery: Send four copies of your comment (an original and three copies) to Docket No. APHIS-2007-0044, Regulatory Analysis and Development, PPD, APHIS, Station 3A-03.8, 4700 River Road Unit 118, Riverdale, MD 20737-1238. Please state that your comment refers to Docket No. APHIS-2007-0044.
Here are the 18 issues being considered by APHIS. (I've abbreviated these from the APHIS document -- see the Web site for the complete APHIS Notice of Intent document).
  1. What are the particular management practices for organic alfalfa, conventional alfalfa and glyphosate-tolerant alfalfa (costs, price premiums, etc.)?
  2. What are the production levels of organic and conventional alfalfa seed and hay by region, state and county?
  3. What is the expected effect of glyphosate-tolerant alfalfa release on animal production systems?
  4. What are the potential impacts of glyphosate-tolerant alfalfa release on food and feed? Effect on food or feed value or nutritional quality?
  5. What differences are there in weediness traits of conventional alfalfa vs. glyphosate-tolerant alfalfa under managed crop production systems as well as in unmanaged ecosystems?
  6. What is the occurrence of common and serious weeds found in organic or conventional alfalfa systems, and in glyphosate-tolerant alfalfa systems?
  7. How would volunteer alfalfa be controlled in crop rotations? How would you terminate an RR stand? What is the potential weediness of glyphosate-tolerant alfalfa?
  8. What is the potential cumulative impact of glyphosate-resistant weeds, especially with the increase in acreage of glyphosate-tolerant crops?
  9. What are weed mitigation options for herbicide-resistant weeds, including those addressed by the EPA-approved label for glyphosate herbicides?
  10. What is the potential for gene flow between seed fields, hayfields and feral plants? To what extent can organic or conventional alfalfa farmers prevent their crops from being commingled with unwanted, unintended or unexpected glyphosate-tolerant alfalfa?
  11. What are the potential economic and social impacts of glyphosate-tolerant alfalfa release on organic and conventional alfalfa farmers?
  12. What are the potential impacts of deregulation of glyphosate-tolerant alfalfa on U.S. exports of hay or seed?
  13. Will increased glyphosate usage impact soil quality, water quality, air quality, weed populations, crop rotations, soil microorganisms, diseases, insects, soil fertility, food or feed quality, crop acreages and crop yields?
  14. What are the potential impacts of the release of glyphosate-tolerant alfalfa on threatened or endangered species and designated critical habitat?
  15. What are the potential health and safety risks to field workers or other workers that would come into contact with glyphosate-tolerant alfalfa?
  16. Can any of the potential negative environmental impacts resulting from the deregulation of glyphosate-tolerant alfalfa be reasonably mitigated and what is the likelihood that mitigation measures will be successfully implemented?
  17. What are the impacts of the mitigation measures on co-existence with organic and conventional alfalfa production and export markets?
  18. Are there any other potential direct, indirect or cumulative impacts from the release of glyphosate-tolerant alfalfa other than those mentioned above?