Good afternoon, everyone. I'd like to thank you for allowing the Manitoba Forage Seed Association to address Bill C-474.
The Manitoba Forage Seed Association is an incorporated, not-for-profit, producer-driven organization representing forage seed growers across Manitoba. The focus of our organization is to facilitate the advancement of the forage seed industry in all aspects. This is achieved by providing its members with production and agronomic support through research, advocacy, and linkages with industry partners.
In September 2008, the Manitoba Forage Seed Association released its most recent position on recombinant DNA technology and subsequent genetically modified alfalfa, including Roundup Ready alfalfa, as follows.
We recognize that the future of biotechnology may well be accepted when benefits to consumers, producers, the environment, and human health are demonstrated.
We also recognize that consumers are not united in the understanding and acceptance of products from genetically modified crops produced via recombinant DNA technology.
We support a regulatory environment based on sound science that openly communicates clear and meaningful information to stakeholders.
We will not support testing that poses a risk of release of a specific transgene into the environment or commercialization of any transgenetic alfalfa variety--including Roundup Ready alfalfa--in Canada until such time as the variety receives Canadian regulatory approvals for food, feed, and environmental safety; the regulatory approval for specific transgenetic alfalfa varieties is obtained in Canada and the following export markets: the U.S., the European Union, China, Japan, Mexico, and South America; an identity preservation system for alfalfa varieties is in place in Canada; and a rapid, cost-effective test for identification of specific transgene is available.
In March of this year, the Manitoba Forage Seed Association also passed the following resolution:
Whereas once Roundup Ready alfalfa is introduced into the environment there will be a transfer of pollen from Roundup Ready alfalfa plants to non-Roundup Ready alfalfa plants by pollinating insects and other means, regardless of the intended use of the crop;
Whereas Canadian alfalfa seed producers are growing significant quantities of conventional alfalfa seed varieties for European and other foreign markets where the presence of Roundup Ready trait is not accepted;
Whereas the commercialization of Roundup Ready alfalfa will jeopardize lucrative foreign market access as a result of cross-contamination between Roundup Ready alfalfa and conventional varieties;
Be it resolved that the Manitoba Forage Seed Association support the Private Member's Bill C-474 as presented by Alex Atamanenko, NDP Agriculture Critic.
MFSA is not opposed to the use of genetically modified crops. It is our position that any genetically modified crop that is currently not being produced in Canada should require the developer to conduct an economic impact study or assessment of potential market harm as part of the initial regulatory process before granting an unconfined release status, thus eliminating the potential for irreparable harm.
It is our position that crops such as genetically modified corn, canola, and soybeans that are currently being grown commercially should remain in place and should not require an analysis of potential harm to export markets.
Currently, there are no genetically modified or herbicide-tolerant forages or forage seed varieties registered or being grown commercially in Canada. Forage and turf seed produced in Canada is exported to markets around the world. We know there is market resistance to GMO seed for many of the countries that represent a significant portion of international trade in the forage seed industry. These markets are not only willing to purchase GMO seed; they are very concerned about any GMO contamination in weed seeds or volunteer crops.
Experience in other crops where GMO technology has been introduced has shown that technology does not stay confined to the field where crop production is occurring. Well documented are the escapes of the technology through seed movement, transmission through pollen movement, and outcrossing to volunteer plants or similar weeds.
Before considering the introduction and release of GMO forage seed, there are a number of questions that we feel need to be asked.
Is there a significant market in Canada or the world for GMO forage seed? What will be the effect on profitable Canadian export markets with the release of GMO forage seed?
Who will realize the greatest gains and profit the most by releasing such varieties? Who will suffer the greatest economic losses with release of GMO varieties?
Lastly, if the forage seed export industry collapses, which in turn will shrink the industry and make it far less viable, who will be accountable for those losses?
We've all heard the comment that countries that currently have a zero tolerance policy to GMO seed need to change the policy and allow certain contamination at low levels, but what gives Canadian agriculture the right to dictate to countries what policies they should agree to?
As an exporting nation, we have to be prepared to produce what our customers not only require but also demand. If this means GMO-free seed, we have the choice to provide it or lose the market.
Coexistence between GMO forage seed varieties and conventional varieties will be impossible, even with sound agronomic practices. Cross-pollination with perennial crops will occur. There are a number of possible routes where this will happen: biological processes, such as long-distance pollen dispersal; seed movement by animals; and human error, such as failure to perform scouting for volunteers, inadvertent mixing of GM and non-GM seed, improper cleaning of equipment and storage facilities, or poor production practices. We have seen these scenarios with annual crop species, but I must stress that with forage seed crops it will be much more difficult to control due to the nature of perennial plants.
Forage seed growers believe that there is not a significant market for GMO forage seed. Canada will lose substantial portions of its forage seed export market, as we will be unable to guarantee GMO-free seed. One only needs to look as far as the Canadian flax industry to see how sensitive markets can be and the economic harm that can result by the releasing of GMO species when your markets do not accept them because of a zero tolerance policy. If GMO forage seed were to be produced commercially in Canada, the family farms and small independent seed companies would bear the greatest economic losses.
To ensure a viable forage seed industry in Canada, it is imperative that we keep Canada free of all genetically modified forage seed until it is accepted into our major export markets. If genetically modified alfalfa seed is introduced into Canada, we'll see a reduction in alfalfa seed acres due to lost export markets.
One aspect that I have not heard commented on is the fact that alfalfa leafcutter bees are used to pollinate blueberries and hybrid canola fields. Unlike honeybees, which will fly for several miles, the leafcutter bee has a short flight zone. Companies that are producing certified hybrid canola seed rely on alfalfa leafcutter bees to pollinate the female plant, as it is easier to avoid cross-contamination with these bees.
Although these bees are used on other crops, alfalfa seed acres are the source of reproduction for leafcutter bees. A reduction in alfalfa seed acres will result in fewer bees available to pollinate crops such as blueberries and hybrid canola.
As we continue to see survival problems with the honeybee colonies, it is imperative that we maintain leafcutter bee populations. A significant drop in alfalfa seed acres would make this impossible.
In conclusion, we have to ask ourselves this: who are the real beneficiaries of GMO forage seed? In the case of Roundup Ready alfalfa seed, there'd be very little benefit, as the majority of forage acres in Canada are a blend of alfalfa and grass species. The Roundup Ready technology is of no value as the Roundup will eradicate any grass species being grown in the forage or hay mix.
There is no doubt that in canola, soybeans, and corn, weed control has become easier with the introduction of GMO and herbicide-tolerant varieties. Having said that, we have not seen any significant increase in net farm income because of it, but at the same time, farmers have seen the price of seed increase three- to fivefold in the last dozen years.
With flax, we have seen the ramifications of GMO technology showing up in markets that have a zero tolerance policy. In addition to lost markets and lower prices, Canadian farmers have had to bear the added costs of testing seed prior to being able to sell their seed. The same will hold true if GMO forage seed is introduced into Canada.
In the case of Roundup Ready alfalfa, Monsanto has repeatedly stated--and I quote Trish Jordan, Monsanto spokesperson--that “Monsanto has worked closely with alfalfa seed and forage industry groups to ensure that the risks of gene escape and market damage are minimized”.
The key word here is “minimized”, not “eliminated”; there is absolutely no possible way to eliminate gene escapes. Only having them minimized means there will be gene escapes resulting in cross-contamination. Once the transgenes have escaped, it is highly likely, if not certain, that they cannot be retracted.
As mentioned previously, given that GMO technology is already widely used in canola, soybeans, and corn, the Manitoba Forage Seed Association would envision that these crops not fall under Bill C-474. This would ensure that research on these crops would continue in Canada.
However, the forage seed industry does see Bill C-474 as being a necessity when it comes to crops that are not currently produced commercially as GMO or herbicide-tolerant crops. Bill C-474 is the first step in offering some protection in the future for Canadian family farms. Market acceptance must be made part of the evaluation process and incorporated into the Seeds Regulation Act.