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Tuesday, April 28, 2015

My Comments To The USDA On Agricultural Coexistence

Today I submitted a comment on the official USDA regulatory forum on the question of coexistence in agriculture.  Here is a link for background from a workshop on this topic held in North Carolina this March.  Here is a link of you want to comment (>4500 people have so far and the comment period is open until May 11, 2015).

The point I hoped to make was that coexistence between different kinds of farming is something people have known how to do for a very long time, but it requires a certain level of reasonableness and cooperative spirit.  That is rarely a problem when you are talking about real farmers and if there are rational standards for "adventitious presence."  The issues to do with coexistence today arise from downstream players making unreasonable demands and by those which are not, by their own statements, interested in coexistence.  The USDA seems to be trying hard to make this an open dialog, but there are aspects of this debate that need to be recognized for what they are.

Text Of The Comment I Submitted 4/28/15

While the coexistence of diverse commodity and identity preserved crops is a long-standing, successful feature of American agriculture, some aspects of the current coexistence discussion warrant careful consideration.  Particularly for row crops, the definition of acceptable “adventitious presence” is critical in any identity preservation effort.  That threshold drives the costs of isolation and segregation protocols as well as the level of risk for the producer.  The threshold of adventitious presence should logically be driven by objective issues of functionality in the intended use and/or by levels that are practical in the real world.  That sort of system has long enabled coexistence in farming.

The current problems for co-existence arise in what many participants in the North Carolina workshop described as "sensitive markets."  Principally this means products intended for "non-GMO" and/or organic markets.  Unfortunately, a significant proportion of those markets have been established at the consumer end through fear-based marketing and advocacy.  For these IP segments there is no "reasonable level of adventitious presence," because the categories were never based on any reason-based functionality or safety criterion.  Perhaps "fear-based marketing" sounds like a harsh term, but if you look at examples of promotional campaigns generated by very large, for-profit, organic and non-GMO food companies, it’s hard to come up with a friendlier sounding descriptor:

1. This recent video produced by Organic Only, a consortium of organic marketers including may of the largest ones:

2. Several productions from the large, non-GMO promoting fast food chain, Chipotle:

3. This humorous, but not fair 2005 production from the Organic Trade Association: 

Coexistence requires, by definition, some level of fair play and mutual respect from the parties involved.  The corn and soybean growing neighbors who are trying to make a living in commodity and IP markets may have that sort of working relationship, but the demands coming down to them from "sensitive markets" are often driven by rather successful, fear-for-profit business models.   These downstream drivers are certainly not on the "coexistence" page at all – in fact exactly the opposite.  Some explicitly state that their goal is the elimination of biotech crops via the agency of GMO or non-GMO labeling and its effects on markets.  As is usually the case, the farmers have virtually no leverage in these exchanges.  With this enormous gulf in terms of power and intention, the prospects for rational co-existence are not encouraging.

There are certainly players in the organic and gmo-free segments that could be reasonable participants in a coexistence discussion, but their voices do not represent or apparently influence other important players.  It would be irresponsible to fail to explicitly acknowledge this “elephant in the room.”