Thank you.
Monsanto and Forage Genetics International have developed Roundup Ready alfalfa. Forage Genetics International has plans to release the GM variety to Canadian producers in the very near future. This event was approved by CFIA in 2005 and approved in the United States prior to that; however, since that time, Roundup Ready alfalfa has been banned for sale in the United States. The effects of Roundup Ready alfalfa in its short commercial life are more evident than the decision documents acknowledge.
I would like to address the fact that Imperial Seed is not opposed to the new technology. What we are opposed to is the release of such products until they have market acceptance. I would also like to state very firmly that Roundup Ready alfalfa does not improve the fitness of the alfalfa plant; it only allows Roundup to be applied to the plant for weed control. I would also like to stress that the continual application of the herbicide Roundup on Roundup Ready alfalfa may add to the growing list of herbicide-tolerant weeds in Canada.
Alfalfa is the third-largest crop in Canada, with 4.5 million hectares in production. Approximately 70% to 75% of the production is in western Canada, and the remaining amount is in Quebec and Ontario.
Approximately 80% of the seed sown for hay is mixed with grass or another legume. Alfalfa is a legume that is often requested by all levels of government to be added into grass mixtures for the purpose of seeding and reseeding new roadside ditches.
There are very few stands of pure alfalfa in Canada. Unlike many areas of the world, Canada has both seed and hay production of alfalfa in the same area, and at times on the same section of land.
It is also a known fact that there is feral alfalfa growing in our national and provincial parks, on roadsides and walkways, and in other public areas in all parts of Canada. Roundup Ready alfalfa will cross-pollinate with the feral alfalfa and, as a result, Canada will have Roundup Ready alfalfa growing in all the locations where the feral alfalfa is growing.
In Canada, most of the alfalfa and alfalfa/grass hay is cut when alfalfa has approximately 10% flower on the field and the weather allows for proper drying. There are also fields of alfalfa hay and alfalfa/grass hay that are cut prior to flowering. However, if the weather is not accommodating, these fields will be left until the weather allows for a proper dry-down of the hay. This delay may allow the alfalfa hay to reach 10% flower as well.
It is also a common production practice in Canada for hay producers to leave strips of hay standing throughout the field on their second cut to help trap snow for a proper insulation cover heading into winter. These strips are usually two feet wide and run the length of the field, leaving approximately 5% to 10% of the field in hay strips. The alfalfa in these strips is often in flower at the time of cutting. If any of the alfalfa plants left in these strips have been pollinated with Roundup Ready pollen, there can be viable seeds that may contain the Roundup gene.
The potential market for Roundup Ready alfalfa is very limited, as 75% to 80% of the seed sold for hay and pasture is mixed with another legume or grass, eliminating the advantage of applying Roundup to the field.
Alfalfa is a perennial crop with several fairly unique attributes.
One, it is a cross-pollinated crop that requires insect pollination. The isolation required to guarantee zero escapes has never been studied on a scientific basis. It is widely recognized that honeybees and some native species have the ability to carry pollen at least five miles. What isolation is required to guarantee control? Ten miles? Twenty miles? What happens in a storm when pollinators are blown dozens of miles away? This is not speculation or conjecture. There are numerous honeybees and native species throughout western Canada.
Two, alfalfa has a hard seed component that is particularly high in western Canada. Some lots from the 2007 crop had a hard seed content in excess of 50%, and this is not unusual. It is known that hard seed can lie dormant in the soil for many years, and possibly for decades. Assuming there were no escapes during the trial years, as is required for varietal registration, who will be responsible for monitoring all the sites during the trials and after they are completed? How do you determine the number of years this has to continue in order to ensure there are no escapes?
Three, there is a feral alfalfa population in western Canada. In some respects, one might say that alfalfa is an indigenous plant and is very common in all types of places, from roadsides to meadows, headlands, and native hayfields. When there are escapes into this population, how is this going to be monitored, identified, and controlled? Not only do subsequent escapes of feral or volunteer crops become “weeds” in other crop kinds, but they are so undesirable that their very presence in some species declines those species. For example, a Roundup Ready alfalfa seed in clover or ryegrass can condemn that lot of seed for export.
In the last five years, Canada has averaged in excess of $20 million worth of forage and turf seed exports into Europe, which has a zero tolerance towards GMO. Canada currently produces many crops that are marketed to GMO zero-tolerance countries. As demonstrated by Europe with the Triffid flax issue, when any amount of seed from a non-approved event is identified, the buyer will cancel contracts and send the seed back to the seller, creating a loss for the company and the producers of this crop.
Currently, the contracts for all legume and grass seed species written between European and Canadian companies have clauses in them which state that if any GMO species are found in the received seed, the seed will be returned to the seller and the contract cancelled. Our industry is faced with the challenge of dealing with GMO canola in our conventional seed, which at times has caused the seed to remain in Canada due to the presence of the GMO seed. We have taken extraordinary steps and precautions to avoid the possibility of canola contamination; however, it still exists.
Alfalfa is like all species. Not only can it be a seed, but it can also be an undesirable in other crop kinds. A study conducted by the CFIA noted that alfalfa was an impurity in 648 samples of different crop kinds. Any one of those samples tested could be seed that was to be sold in Canada or possibly exported to other countries. Only alsike clover was noted as a higher impurity in retrieved samples of pedigree and common seed.
This is a huge issue for many crop kinds, where alfalfa is noted as an impurity due to the fact that if Roundup Ready alfalfa is released for sale, the alfalfa found in such samples may contain the Roundup Ready alfalfa gene.
These issues, together with the fact that Roundup Ready alfalfa will cross-pollinate with the feral and tame alfalfa, puts at risk Canada's entire export market in zero-tolerance zones. We must consider market acceptance prior to the release of this technology.
Canada's science-based approach works very well for the domestic marketers of seed, the Monsantos, the Syngentas, and the Bayer CropSciences, but what does it do for the producer? This approach does not take into consideration what the producers want, nor does it address what the market wants. These are the two most important issues and they are absent from the registration process.
Producers want to grow crops they can market. In the case of Roundup Ready alfalfa, the producers of Canada do not want it, and that is proven today by my fellow colleagues who are here at my side.
One of our large trading partners, the European Union, has also made it very clear: they will not accept any non-approved GMO seeds. The market has spoken.
Our science-based ideas are not adequate. The science-based decision-making process considers only the relative safety of the product compared to the non-transformed species.
There is no assessment of the monetary impact the GMO product will have on the marketplace. Where are the negative impacts belonging to the agronomic performance? They are ignored and covered with the statement, “Let the market decide”. The market has decided. And the answer is no. Allowing only this so-called science-based approach does nothing but create a monopoly.
Since the release of Roundup Ready alfalfa in the United States, the contamination issue has been brought to the attention of many companies and producers of alfalfa. Cal/West, a large U.S. seed company, has lost export market share due to Roundup Ready alfalfa contamination. This company has approached Imperial Seed for possible production contracts for Cal/West into these non-GMO zones.
Analyzing potential market harm and realizing the potential risk may create an economic benefit for our industry in Canada as we wait for market acceptance. Other countries that move forward with this unapproved technology will lose the market, and Canada will gain the production and market share.
In conclusion, the implementation of Bill C-474 should allow for the continued production of the current approved GMO crops produced in Canada. The bill should be applied to: any new technology directed at new crops, any new technology being applied to existing crops, and any old technology being applied to existing crops. This implementation would grandfather in the existing canola, soybean, and corn crops we have.
The large developers of seed threaten Canada by saying that if Bill C-474 passes they will no longer be interested in developing seed for Canada. In my opinion, this is simply a threat that will not be acted upon. Seventeen million acres of canola will be planted in Canada this year and no company is going to walk away from a market that large.
As new technology is developed there is ample time for the market analysis to take place. It takes years to develop new technology. During the submission time, CFIA Plant Biosafety can conduct the extra step of market analysis. It would be prudent for our industry, in order to not jeopardize our members' rights to make a livelihood, to err on the side of caution when introducing new products prior to their approval in the markets of major trading partners.
Coexistence will not exist if Roundup Ready alfalfa is released for sale in Canada. It will destroy the forage and turf seed market into Europe and other markets where there is no tolerance for non-approved events.
In closing, it has been said that Bill C-474 will create another layer of “red tape” for seed companies to go through in order to sell seeds in Canada. I feel this is better than creating “red ink” on the producer's bottom line.
Thank you.