HomeMy WebLinkAboutCOM 0728.069 2000-2002 C
I~AW~~II ~~G1~ICUL~tJ1~ SLACI-I CLl®1TLI~
FORMERLY HAWAIIAN SUGAR PLANTERS' ASSOC/ATION
99-193 AIEA HEIGHTS DRIVE, SUrrE 300, AIEA, HAWAII 96701-3911
TELEPH01vE: (808) 487-5561 FAX: (808) 486-5020
http://www.hawaiiag. org/harc
TESTIMONY BEFORE TI-IE COMMITTEE ON
I~UMAN RESOURCES & ECONOMIC DEVELOPMENT
IL~~Vr~II COUNTY COUNCIL
Related to a Resolution Supporting a
Moratorium on tlae Release and Planting of Genetically Engineered
Coffee in the Districts of Nortla and Soaath Dona in Order to Protect the Bi®tic
Integrity an~I Market Value of Pure Dona Coffee
September 25, 2002 ~~;w..__m_~_--_ - ay
C.rty r~?vnsil
Chairman Arakaki and members of the committee:
My name is Stephanie Whalen. I am President and Director of the Hawaii Agriculture Research Center
(HARC). I am testifying today on behalf of the center, our research and support staff, and our members
and clients.
HARC is in strong opposition to County of Hawaii proposed Resolution No. 236-02 Draft 2, a
resolution Supporting a Moratorium on the Release and Planting of Genetically Modified (GM) Coffee
in the Districts of North and South Kona in Order to Assure and Protect the Biotic Integrity and Market
Value of Pure Kona Coffee.
There is no reason here to repeat the technical reasons for HARC's opposition already presented to the
Council at its Committee on Human Resources and Economic Development in HARC's testimony on
September 10, its requested clarifying comments submitted September 11, and by its transmission of
the Pew Initiative on Food and Biotechnology, "Guide to U.S. Regulation of Genetically Modified
Food and Agricultural biotechnology Products."
However, what I do think is important to repeat and emphasize is that HARC in no way opposes the
concept of developing and maintaining market niches for Hawaii's crops. In fact, quality differentiation
is extremely important for Hawaii's agricultural export producers to compete in a tough global
marketplace. Further, I want to correct any misinterpretations of my prior testimony on this resolution.
HARC fully recognizes and supports organic farming as one of the high value niches important in the
state's diversification. HARC actively supports this fanning process as well as the conventional
process and modern technology by seeking competitive funding in partnership with growers who
choose to work with its scientists.
However, HARC sees no value in public activities that support negative connotations about any process
in farming. We know that the parties able to address the concerns raised within the Kona coffee
community are ready, willing and able to work towazds a solution that does no harm to the valued Kona
coffee market niche. 'There is no reason to believe that the infrastructure that exists to support the
agricultural industry in Hawaii would knowingly and intentionally work to undermine the industry's
sustainability. Open communication, trust and cooperation are the keys to our future success. e ~ev
File NQ.
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I3at~ _ ~ ~ ,L
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HAWAII AGRICULTURE RESEARCH CENTER
it is the function of the leadership in our communities, agencies and organizations to foster,
promote and encourage these values for the success of the whole sector.
I believe there is general agreement amongst all the parties that there are no genetically modified
coffee plants in field tests anywhere in the State of Hawaii, and that if any coffee plants
developed through the process currently referred to as 'genetically modified' in the future
demonstrate a potential benefit and are recommended for field trials, that field tests will be done
with the agreement of the Hawaii Coffee Industry.
Consequently, it is HARC's opinion there is no need for this resolution and urge you not to
support its passage.
In the interest of promoting cooperation and co-existence amongst our farming sectors in the
future, I have provided two attachments for your information on how others are working to
address this issue.
(1) "Scenarios for co-existence of genetically modified, conventional and organic crops in
European agriculture." A report from the Joint Research Centre, as commissioned by the
Agriculture Directorate-General of the European Union.
(2) "10 Strategies to Minimize Risks of GMO Contamination" by James A. Riddle Organic
Independents, Winona, MN.
Thank you for this opportunity to testify on Resolution No. 236-02.
~°I"I'ACI~I~N'T 1
Brussels, 22 May :002 j
Scenarios for co-existence of genetically modified, conventional and
organic crops in European agriculture
Report from the Joint Research Centre (JRC), as commissioned by the
Agriculture Directorate-General, now available at
http://www,
j rc.cec.eu. int/GECrops/
and
htep:l/www.
jrc.es/welcome.htm 1
What does co-existence of genetically modified (GM), conventional and
organic crops mean?
Co-existence means that farmers should be able to freely adopt the
agricultural production system they prefer. Production systems can be
differentiated into conventional systems including GM crops,
conventional systems using non-GM craps and organic farming systems
using exclusively non-GM crops.
Of course, different types of agricultural production are not
naturally separated. The cultivation and use of GMOs is strictly
regulated in the European Union. i;Iowever, the adventitious presence of
GM crops in organic or in conventional crops cannot be excluded during
cultivation, harvest, transport, storage and processing.
Why has the Commission carried out a study on the problem of .
CO-eXlStence?
If GM crops increase their share in EU agriculture, the question
arises as to whether adventitious presence of GM crops in organic or
in conventional crops at farm and at regional level could
significantly increase if current farthing practices are maintained.
In the Communication on "Idife Sciences and Biotechnology - A strategy
for Europe", the Commission has committed itself to take "initiatives
to develop, in partnership with Member States, farmers and-other
private operators, research and pilot projects to clarify the need and
possible options, for agronomic and other measures, to ensure the
viability of conventional and organic farming and their sustainable
co-existence with GM crops".
This study is a first step towards addressing these issues and trying
to assess the consequences of the introduction and possible increase
of GM crops, and to identify appropriate measures at the faun level to
minimise the adventitious presence of GMOs below the thresholds laid
down in Commission legislation (for labelling of GM food).
The study also aims at developing possible monitoring systems needed
for verification, and at estimating the costs of relevant changes in
farrhing practices, monitoring systems and of potential insurance
systems to cover possible financial losses due to adventitious
presence of GM crops in non-GM crops.
What is the basis and significance of the study? AT'I'~1C)i101'I° 1
2
The report, as co-ordinated by the Commission's Joint Research Centre,
is a prospective study, based on different hypothetical scenarios.
`These assumptions should not be taken as an anticipation of future
developments. This applies especially to the hypothetical GMO shares
of 10°/® and 50% and the selected thresholds of 0.1%, 0.3°/® and 1 An
increased GMO share would certainly require a corresponding demand and
would result in a different price structure. These aspects have not
been included in the study. The scenarios presented, focus on the
actual demand and supply situation and the identified costs cannot be
used to predict future prices.
To estimate on-farm levels of adventitious presence of GM crops in
non-GM crops and to compare the effects of changing farming practices
a combination of expert scientific opinion and computer models was
used. Computer models are useful for comparisons of different fanning
practices. The absolute values provided by the models (e.g. when
considering if a pareicular theeshold can be respected) have to be
taken into consideration with care, since the models are not yet fully
validated.
A set of farming practices, referred to as "current farming practices"
in the study, needed to be defined for each crop to estimate a
"baseline" level of adventitious presence of GM crops in non-GM crops.
These current farrcting practices are obviously a compromise given the
variability existing in EU farms in this regard. Therefore, when the
results indicate that changes in fatrning practices are needed to
respect a certain threshold (and the costs of these changes are
properly assessed), a significant number of farms could already be
applying proposed or similar agronomic practices (especially in the
case of seed production).
Overall data interpretation needs care, because of the limited
on-the-field evidence available and the consequently Dimited
validation of the modelling methods employed.l3asfc hypotheses and
subsequent quantitative results should also be tested on experimental
fields of adequate size before drawing more general conclusions.
The unique feature of the study Is the multi-step approach of
identifying the sources and levels of adventitious presence of GMOs,
proposing suitable changes of agricultural management practices to
comply with defined thresholds, and the subsequent calculation of
associated costs. `Thus, the study addresses socio-economic
implications rather than simply estimating risks of adventitious
presence of GM crops in semi-quantitative terms.
The study will be one of many inputs into the Commission's
deliberations on the issue of co-existence between conventional,
organic and GM agriculeure, a subject which requires further research.
What are ehe implications of the results of the study for production
of conventional farming and for organic farming?
Three arable crops were selected as case studies representing
different biological features but also the likelihood of a future
introduction of their GM varieties in the EU: oilseed rape for seed
production, grain maize used for feed production and potato for direct
consumption and food processing.
Several farm types (both organic and conventional) were defined to ~TT'~C~~~~' 1
cover the variability present across EU farming infrastructure.)=or Pale 3
all crop-farcvc combinations, a hypothetical share of GM crops of l0% or
50% in the region was considered. A share of 50% mimics the situation
in countries that have already adopted GM crops (for instance the
share of GM oilseed rape in Canada is currently 54%), while the 10%
figure represents a scenario of slow adoption of GM crops.
The estimated levels of adventitious presence of GM crops do not
change dramatically between the two scenarios of GM crop share (10% or
50%). A practical consequence is that measures to prevent adventitious
presence of GM crops may have to be implemented in the early stages of
adoption.
On the other hand, the estimated levels of adventitious presence of GM
crops in non-GM crops -assuming current farming practices -vary
significantly depending on the crop and farm type (for example, as
much as 2.2% for a conventional intensive maize farm or as low as 0. !
for an organic potato farm). In general there is a trend to expect
lower levels of adventitious presence of GM crops on organic farms,
because of segregation systems already in place, but there are
relevant exceptions. In seed production of rape, organic farms will
face higher probability of adventitious presence of GM crops due to
problems in controlling volunteers with organic practices.
Sources of adventitious presence of GM crops are well known, and can
be divided into four main origins (seed impurities, cross-pollination,
volunteers and harvesting-storage practices). The relative importance
of each source for the final level depends on the crop and farm type.
Volunteers are a key source of adventitious presence of GM crops for
rapeseed farms (especially organic) but are of low importance in maize
fauns, where- seed impurities and cross-pollination account for most of
the adventitious presence of GM maize.
What are the implications of the results of the study for production
of non-GM seeds?
The report examines only the case of oilseed rape for seed production.
Out of more than 2 million hectares devoted to oilseed rape production
in Europe. only about 3000 hectares are devoted to seed production.
Cultivation of oilseed rape dedicated to seed -production is catried
out under completely different conditions: certified seed producers
are assumed to grow seeds according to certified production standards
(e.g. for hybrid seed: isolation distance of 300 m and a 6 year
rotation; careful post-harvest segregation). Farrtrs using farm-saved
seeds are assumed to be about ehree times larger. The conventional
farm applies a shore three-year rotation, exchanges seeds and shares
machinery with its neighbours or uses contractors.
The GENESYS computer model was used, as well as expects' opinions, for
estimations of adventitious presence of GM seed crops. GENESYS has
been developed by INItA ("Institut National de la Recherche
Agronomique'°) in France to rank cropping systems according to their
probability of gene flow from heebicide eolerant winter oilseed rape
to rape oilseed volunteers both in time via seeds and in space via
pollen and seeds. `T'he model integrates various input variables: field
pdan of a region, crop r®tations, cultfivation techniques for each
crop, type of the transgene, etc. [t is suitable for both seed and
crop production.
Applying current practices' levels of adventitious presence of GM 1
crops are estimated to range from 0.42% to I.OS% depending on the farm ~
type, in the case of the 50% GM oilseed rape for seed production
scenario. Ali farm types, organic as well as conventional, could
achieve a hypothetical 0.3% threshold for GMOs in seed production by
changing farming practices. For farrdas using Earns-saved seeds costs
would however be disproportionately high. These farms would most
likely stop saving seeds and instead use certified seeds.
A 0. I threshold would be more difficult to reach. Theoretically,
levels of adventitious presence of GM crops could be reduced to very
low levels 0.1 by reinforcing the changes in farming practices.
The only exception would be conventional fauns using farm-saved seed,
where achieving such low levels seems not to be feasible without
completely changing the post-harvest farming strategy.
What are the possibilities for reduction of the adventitious presence
of GMOs in conventional or organic crops?
The different possibilities depend on farm-crop combination. The
theoretical thresholds used in the analysis are 0.3% for seed
production of allogamous species (rape) and 1 foe maize and potato
crops (for food-feed uses). Ali farm types producing oilseed rape seed
or conventional c8aaize will need significant changes to meet their
thresholds. In some cases (dependent on farm type) changing farming
practices at the individual farm Level will be insufficient. In these
cases changes may involve co-operation between neighbouring farms.
Examples are the introduction of flowering date differences between GM
and non-GM varieties, or region-wide border management. In contrast,
all potato faun types and some maize farm types (organic) could meee
these thresholds with current farming practices (with all the
reservations for the value of absolute figures).
The possibility of changing practices to meet very low thresholds for
all crops, near the analytical limit of quantifccation 0.1 is
also considered in the report. This reflects the situation in organic
farming where the use of GM varieties is not permitted (Council
Regulation (IEC) 1 X04/1999), setting a de facto threshold. The report
concludes that a 0.1 limit will be extremely d'aff~cult to meet for
any farm-crop combination in the scenarios considered (10% and SO%
GMOs in the region), even with significant changes in farming
practices. Some farm types producing seed of o'alseed rape could
approach such thresholds, but only with significant changes of farming
practices.
What are the implications for the I % threshold currently in piece in
EU food legislation?
Compliance with the I% threshold is possible, however in some cases
only through changes in farming practices. This also means setting up
monitoring systems as well as insurance needs. le may result in
additional costs of 1 to 10% of current product price for the
farm-crop combinations studied (in the 50% scenario of GM crops in a
region).
.~T`TAC~iIl~IEN'T 1
Costs reductions might be possible with segregation becoming an Page $
integrated part of agricultural practices and with decreasing costs of
GMO analysis. In general, organic fauns face higher costs, especially
indicative insurance cost, than conventional fauns. Q°~lowever, when
relating eosu to product prices, the price premium foe organic crops
reaay reduce this difference in percentage terms. Cultivation of GM and
conventional or organic crops on the same farm might be an unrealistic
scenario, even for larger farms.
Do we need further analyses on this issue?
The study provides the first results on ehe issue of co-existence. The
Commission's Joint Research Centre will keep working on this topic.
One of the conclusions of the study is, as far as the likelihood of
adventitious presence of GM crops in non-GM crops is concerned,
additional research is necessary to provide experimental data on gene
flow for oilseed rape, maize, potato and other crops not taken into
account in this study. More information on actual levels of seed
impurities in the lots marketed in the EU is key for simulations like
the ones presented in this study. It is also necessary to undertake
the same work for maize seed, to better understand how co-existence
will impact on seed production and to provide information for an
adaptation of seed production standards.
Regarding economic data, the study Lacks the cost estimation of same
of the proposed agricultural changing practices. To assess the real
costs of, for instance, introducing large isolation distances, the
alternative use of agricultural land has also to be analysed. Changing
post-harvest management could include changes of the logistics at the
next step of the supply chain, again making a very complex analysis
necessary. This points out to the need for further stud'aes, focusing
on economic aspects and probably going into more detail with a reduced
number of cases and considering the complete economic structure of a
farm.
- European Commission May 22 News Release:
http://europa.eu.ini/rapid/startlcgi/guesten.ksh?p_action.getbct=gtdcdo
c=MEMO %20/02/100®~RAP1DdcIg=EN
AT'I'AR,CI~~IEN°T
10 Strategies to Minimize Risks of GMO Contamination by James A. ~a~e 1
Riddle Organic Independents, VNinona, MN
More and more consumers are looking for organic foods. (t is the
largest growing sector of the food industry, with growth rates of
20-25% per year for the last 12 years. The new pederal rules for
organic production prohibit the use of genetically modified organisms
(GMOs) in organic production. Even though organic farmers don't plant
GMO seeds, crops can become contaminated by GMO pollen drift, use of
contaminated seeds, and/or sloppy handling practices.
Since it will soon be planting season, organic, transitional, and
nan-GMO crop farmers need to know steps they can take to minimize
risks of GMO contamination. The following list, which has been
distributed nationwide, outlines some strategies L'1at farmers can
employ to minimize risks.
1. Know your seeds - Prior to planting, verify that non-GMO seeds
will be used. Obtain statements from seed companies concerning the
non-GMO status of the varieties to be planted. ~fave seeds tested for
all applicable GMO "events". Retain copies of test results and
letters from seed suppliers.
2. Know your farm -Know your fields and determine which have the
lowest risk of GMO contamination. Select isolated fields for wind
and/or insect pollinated crops (corn, canola). Know the prevailing
wind direction. Establish physical buffers, such as windbreaks and
hedgerows. 3. Know your neighbors -Establish good lines of
communication with neighbors, especially those who directly adjoin
organic fields. l~otify them that you are an organic farmer, and where
your organic fields are located. Get to know farmers who farm
adjoining fields, even if they rent the land. Post "Organic fiarm"
signs along field margins, where needed.
4. Know your neighbors' crops -Gather information from neighbor,
seed dealers, and farm input suppliers on the types of crops being
grown in the vicinity. Know which GMO events are being planted. If
neighbors ace growing ~t crops, ask them to plant their "20®/o non-Bt
refuges" in areas that adjoin organic fields, to provide some buffer
protection. If possible, delay your planting dates so that your
organic crops do not pollinate at the same time as GMO crops.
5. Know your equipment -Know what your equipment is used for. This
includes rented and borrowed equipment and equipment used by custom
operators. Know how to clean all pieces of equipment, including
planters, combines, wagons, trucks, etc. Clean equipment prior to use
in organic fields, and keep records to document your equipment
cleaning activities.
6. Know your harvest -Submit samples prior to harvest for GMO
testing. If contamination is likely, collect samples along a grid
pattern, going from areas with the highest risk to areas with low
risk. Submit the samples separately, in case part, but not all, of
the field is contaminated. Make sure samples are tested for al[
applicable GMO events. Keep copies of test results.
A'T'TE4C~'Ill~I~lei'I' ~
7. Know your crop storage -Carefully inspect storage units prior to ~
use. ®ust from GMO crops can contaminate organic crops. 'Thoroughly
clean augers, bins, grain dryers, rotary screen cleaners, etc.,
especially if they might have previously been used for GMO crops. 8.
Know your truckers -Carefully inspect and clean trucks and trailers
prior to loading with organic grain. Make sure that transport units,
including overseas shipping containers, are free of grain, dust, and
ocher foreign material. Keep records to document, including clean
transportation affidavits and bills of lading.
9. Know your records - ®ocument your efforts to minimize GMO
contamination. With good records, you will have a better chance of
limiting losses, identifying causes of problems, and determining
liability. Valid records of organic yields and sales may help
establish claims for losses, should contamination occur.
10. Know your buyers -Know ehe contract specifications under which
the organic crop is being grown. Know your buyer's sampling and
testing protocols. Know the market-driven GMO rejection levels
(tolerances) for the crops grown. Communicate witty buyers and organic
cereifying agents concerning GMO contamination issues.