Mark McCaslin and Zelig Golden agree on one thing regarding the recently issued draft environmental impact statement (EIS) on Roundup Ready alfalfa: Concerned growers should submit comments to USDA during the public comment period that ends Feb. 16.

“We think it's in growers' best interest to step up and share their views,” says McCaslin, president of Forage Genetics International, the company that developed the first Roundup Ready alfalfa varieties and introduced them to the marketplace in 2005. “Somebody's going to speak up, and if it's not growers speaking up for themselves, then who's going to do it?”

“We're calling on everyone who's concerned to voice their opinions so the USDA can really understand the magnitude of the concern,” adds Golden, a staff attorney for the Center for Food Safety, which filed the lawsuit resulting in Roundup Ready alfalfa seed coming off the market in 2007.

But McCaslin and Golden are at odds over the 1,476-page document prepared by USDA's Animal and Plant Health Inspection Service (APHIS). In the draft EIS, APHIS preliminarily concludes that Roundup Ready alfalfa poses “no unreasonable environmental risk” and should be given non-regulated status, meaning seed sales should be permitted without restrictions.

McCaslin applauds the findings, stating that the agency did a thorough analysis, gathering information from a variety of sources on both sides of the issue.

“It appears to me they bent over backwards to be science-based and objective,” he says.

But Golden says the EIS conclusions put growers of organic and export hay at risk of losing their markets.

“The USDA, whose job is to protect all farmers in America, has disregarded these farmers,” he says.

If Roundup Ready alfalfa is grown unrestricted over a wide area, conventional alfalfa will quickly become contaminated with the transgenic gene, he maintains. Contamination is inevitable, because “alfalfa is a perennial crop that's pollinated by insects that travel many miles,” he adds.

“Once this is released without any type of protections or restrictions, the entire industry will have to be GMO (genetically modified organism) because of contamination, and then there will no longer be a choice to grow non-GMO alfalfa. Further, the draft bluntly predicts that any approval will hurt all small alfalfa farmers, yet it doesn't even consider any options that might protect them, such as isolation distances.”

Golden points out that Organic Valley, said to be the biggest organic milk cooperative in the U.S., has “grave concern, and that concern was not addressed in the EIS; in fact, it was completely disregarded.”

Some contamination is possible, McCaslin admits. But he says safeguards are in place that will minimize it, and APHIS took that into account when preparing the draft EIS.

He points to a 2007 Council of Agricultural Science and Technology publication on pollen flow in alfalfa, which concluded that pollen movement occurs predominantly between seed fields. The amount of pollen flow from seed fields to hayfields and vice versa is “infinitesimally small,” according to the publication, called Gene Flow in Alfalfa.

Armed with that knowledge and led by the National Alfalfa & Forage Alliance (NAFA), alfalfa breeders, seed marketers and other industry representatives developed a set of best practices to manage pollen flow between seed fields. One of them establishes new isolation distances. Roundup Ready and conventional seed fields must now be at least 900' apart if leafcutter bees are used for pollination, one mile apart if alkali bees are used, and three miles apart if honeybees are the pollinators. Read the best practices document at

“What we've established as best practices isolation distances are extraordinarily higher than what's required for normal seed certification,” McCaslin points out.

The NAFA best practices require an annual audit of the “adventitious presence” of Roundup Ready alfalfa seed in conventional seed lots. Results of the 2009 audit, conducted by officials from three state seed certifying agencies, verified that the best practices are keeping contamination at very low levels, he says.

McCaslin feels that alfalfa needs Roundup Ready and other transgenic traits to stay competitive with other crops and that increased yields and other benefits of biotechnology will play a key role in feeding the world's growing population. That's why he encourages growers to read the draft EIS and submit comments.

“It's important for growers and agriculture in general to step up to the plate and speak to our collective best interests,” says McCaslin. “We're convinced that those best interests are aligned with what it's going to take to feed the world 20 years from now.”

But Golden notes that Failure To Yield, a publication from the Union of Concerned Scientists, argues that biotechnology doesn't actually increase crop yields. It can be viewed at

“It outlines in very good scientific research and data that yields are either flat or reduced by GMO crops,” says Golden. “And we have evidence that the same is true for Roundup Ready alfalfa. Nothing is increased from Roundup crops except Monsanto's pocketbook.”

After reviewing the submitted comments, APHIS is expected to publish a final EIS later this year. Then the crop may again be deregulated.

“We're hopeful that we'll get deregulation in time for sales in the latter half of 2010,” says McCaslin. “But we've got our fingers crossed.”

Golden declined to say whether his organization will take further legal action to keep the seed off the market.

“We're assessing the EIS to ensure it complies with all environmental and agricultural laws. We'll file comments to the USDA and await its further analysis. The agency has not yet decided any course of action, and all regulatory options are still open.”

The draft EIS can be downloaded at To submit comments, go to