> ***What issues should USDA consider regarding coexistence among
> diverse agricultural systems in a dynamic, evolving, and complex
> marketplace*?**
>
> **A consensus response prepared by the USDA Advisory Committee on**
>
> **Biotechnology and 21^st^ Century Agriculture**
>
> **March 5, 2008**
>
> **Introduction**
>
> **A. Committee Charge from the Office of the Secretary**

The AC21 has been charged by the Office of the Secretary with addressing
the question, **"*What issues should USDA consider regarding coexistence
among diverse agricultural systems in a dynamic, evolving, and complex
marketplace*?"**

**B. Definition of Coexistence**

*Coexistence, for the purposes of this paper, refers to the concurrent
cultivation of conventional*[^1]*, organic*[^2]*, and genetically
engineered (GE)*[^3] *crops consistent with underlying consumer
preferences and choices.*

**C. Methodology**

The AC21 has discussed a number of topics relevant to coexistence of
conventional, GE, and organic crops and their associated production
systems in reports delivered to the Secretary of Agriculture in 2005 and
2006.[^4] Among the topics discussed in these reports are (1) identity
preservation, (2) testing and tracing, (3) the effects of asynchronous
product approvals, (4) local moratoria on the planting of GE varieties
in the United States, (5) U.S. government policy regarding the
adventitious presence of GE materials, and (6) the ability of the
overall federal regulatory system to address consumer concerns. Rather
than repeat these discussions, the reader is directed to the earlier
reports for further information.

The AC21 has met 5 times to discuss the current charge. The Committee
considered presentations from outside experts and USDA representatives.
The information contained in those presentations is available on the
USDA AC21 website. This paper is based upon the Committee's
deliberations on information offered in those presentations and is
shaped by the broad collective substantive expertise of the Committee
members. The AC21 discussed a number of issues and factors that are
important to conventional, organic, and GE production, but consistent
with the charge from the Secretary, our discussion here is focused on
two key areas: 1) factors broadly enabling coexistence, and 2) factors
broadly inhibiting coexistence in the future

D.  **Overview**

Coexistence among the three categories of crops is a distinguishing
characteristic of U.S. agriculture, and makes it different from some
other parts of the world. The Committee gathered information from
participants in different parts of the U.S. food and feed supply chain
and reviewed data to analyze the current status of coexistence in the
U.S. The following interesting facts came to light.

-   The U.S. is the largest producer of GE crops in the world.

-   The U.S. is one of the largest producers of organic crops in the
    world.

-   The U.S. is one of the largest exporters of conventionally-grown,
    identity preserved, non-GE crops in the world.

-   Some U.S. farmers currently are producing a combination of organic,
    conventional, and genetically engineered crops on the same farm.

It appears to the Committee that U.S. agriculture supports the
coexistence of conventional, organic and GE crops. AC21 members have
different views about how well coexistence is working, but agree that
fostering coexistence is an important and worthwhile goal. It must be
recognized that the concurrent use of different production systems can
sometimes limit individual choices of both farmers and retail
consumers[^5]. The proximity of different production systems sometimes
causes problems among neighboring farms, although farmers generally
cooperate to reduce those problems. At the retail consumer level, some
consumers cannot find the products they desire. While consumer demand
eventually influences what farmers grow, sometimes there are lags in
redirecting production resources to meeting emerging demand for a
particular crop or product.

The Committee explored the aspects of the U.S. agricultural system that
currently support and inhibit coexistence, and tried to anticipate
market changes that could impact coexistence in the future. The
Committee hopes that this analysis of what is currently working well,
where issues exist, and what potential problems could occur in U.S.
agriculture in the future, will help USDA support the diverse needs of
stakeholders in the supply chain, as well as retail consumers.

The success of coexistence assumes market demand for organic,
identity-preserved conventional, and GE products continues and that the
government will support different agricultural production systems. That
support plays an important role in ensuring that production systems in
the United States for these three classes of crops will continue to
thrive, prosper, and meet the needs of the marketplace.

**II. Factors Enabling Coexistence**

Several features of contemporary U.S. agriculture have contributed to
the current success of coexistence. They include the following:

-   The cooperation and market orientation of all stakeholders (e.g.,
    growers, commodity and specialty product handlers, processors,
    retailers and consumers);

-   A legal and regulatory framework that has enabled different markets
    to develop without interfering with the ability of participants in
    the food and feed supply chain to establish standards and procedures
    (e.g., not setting specific mandatory adventitious presence (AP)
    thresholds and having process-based rather than product-based
    organic standards);

-   The development and availability of identity-preservation (IdP)
    systems and accepted test methods to meet market-based thresholds
    for adventitious presence appropriate to specific applications and
    needs;

-   A relatively predictable manner of introduction of new products into
    the marketplace, allowing markets to adjust and segment, as needed,
    to enable different entities to capture value in different ways;

-   Commercial agreements (contracts) based on clear, verifiable and
    achievable specifications (e.g., allowing for variable,
    contractually established standards rather than
    governmental/regulatory standards or thresholds);

-   The ability of the seed industry to provide diverse seed inputs to
    meet a wide range of grower demands;

-   Expert knowledge and crop production management skills at the farm
    level, enabling the co-production of different crop types;

-   An infrastructure and distribution system capable of handling both
    commodity and specialty products;

-   The comparatively small size of organic and identity-preserved,
    non-GE crop acreages, in relation to GE acreages, has allowed easier
    accommodation of the production needs of organic and IP non-GE crop
    production systems (e.g. isolation distances, land, management,
    storage) at relatively small incremental costs, keeping the smaller
    systems profitable;

-   The willingness of some customers[^6] and retail consumers to pay a
    premium for differentiated food products, e.g. organic, non-GE, and
    other specialty products; and,

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-   The long-established practice of local, regional, and State-level
    stakeholders developing rules, practices, standards (e.g., planned
    timing of flowering and harvesting of different crops, grower
    districts, crop improvement and seed certification associations,
    seed sourcing standards, and noxious weed standards) that enable
    coexistence of specialized or sensitive agricultural products and
    meet diverse consumer and marketplace demands.

**III. Factors Potentially Inhibiting Coexistence**

In addition to identifying the factors enabling coexistence discussed in
the previous section and highlighting the need for continued attention
to them, Committee members also identified a number of factors that pose
a challenge to coexistence. One key factor that has inhibited
coexistence is adventitious presence (AP). While Committee members
believe that participants in the food and feed supply chain generally
take steps to minimize the potential for AP, an occasional problem can
have huge ramifications for coexistence. Below are examples of how AP
can create challenges to coexistence.

-   Trace levels of GE events that have obtained U.S. regulatory
    clearance have occasionally been found in either certified organic
    or identity-preserved conventional crops. While AP discovery does
    not directly affect the certified organic designation, it may have
    an impact on customer choices and contracts, as well as choices for
    those retail consumers seeking GE-free products.

-   Failure to adequately contain regulated GE events or products being
    developed through breeding programs and/or field trials associated
    with product development and their presence in commercial crops can
    cause market disruption and erosion of confidence in all three
    agricultural production systems.

-   Decisions by technology providers to produce or commercialize GE
    products in the U.S. market before regulatory clearances have been
    obtained in countries that are key U.S. export markets can
    potentially have significant upstream and downstream effects.
    Exports of an entire crop (GE, organic, and non-GE) can be placed at
    risk.

-   The availability of a seed supply that meets diverse customer
    expectations may be limited in the future because of the
    adventitious presence of GE traits in GE, conventional or organic
    seed.

Please see the AC21's earlier report entitled, "Global Traceability and
Labeling Requirements for Agricultural Biotechnology-Derived Products:
Impacts and Implications for the United States" for further discussion
of these topics.

Other factors identified by the Committee that could inhibit coexistence
(some of which reflect potential breakdowns in factors enabling
coexistence) include the following:

-   Procurement policies adopted by dominant market players can create
    *de facto* purchasing standards for an entire industry and
    potentially preempt farmers' decisions about what to grow. Non-GE
    procurement policies adopted by major marketing associations (e.g.,
    in the case of wheat) or by retail chains (e.g., by McDonalds in the
    case of potatoes) have affected product adoption for domestic and/or
    export use.

-   The potential expansion of transgenic traits into additional crops,
    beyond those few currently in commerce, may add complexity to and
    change cost of organic and identity-preserved conventional
    production and distribution systems.

-   Introduction of GE crops that do not have adequate test methods
    available to manage them in the supply chain have the potential to
    impact coexistence. Introduction of such crops would impact the
    ability of markets to meet implicit/explicit standards.

-   Any reduced diversity in the seed supply for whatever reason would
    be problematic for all three agricultural productions systems. Those
    reasons may include business and market developments.

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-   Failure to expand and modernize our transportation and storage
    infrastructure will hinder the ability to deliver diverse products
    to retail consumers and increase the expense of delivering diverse
    products to customers and retail consumers.

Some retail consumers may purchase organic products because of a primary
desire to avoid GE materials. However, organic products and production
systems were not developed for this purpose and are not guaranteed to be
GE-free. If future domestic production systems are not able to
adequately deliver "zero" levels of GE material, some food processors
and retailers can be expected to use foreign sources to meet consumer
demands.

Future events that may enhance/inhibit coexistence include new
developments in technology, changes in laws and regulation, lawsuits and
judicial decision, domestic and global market factors, and initiatives
undertaken by participants in the food and feed agricultural production
system.

New management systems also could address some issues (e.g., admixture).
New programs under development or recently launched by the government
(e.g., USDA's Biotechnology Quality Management System, BQMS) and the
private sector (e.g., the Biotechnology Industry Association's (BIO)
Product Launch Stewardship Policy and the continued development and
implementation of the BIO Quality Management Program) may also help
address some potential inhibitory factors for coexistence among
different agricultural production systems.

Ultimately, retail consumer preferences in the marketplace dictate
changes in some production practices and requirements for coexistence.

**IV. Conclusions**

The members of the AC21 see the need for the continued existence of, and
support for, all three production systems as part and parcel of
coexistence.

We believe that USDA should:

-   Continue to support those factors enabling coexistence among
    identity-preserved conventional, organic and GE production;

-   Take note of the potential factors inhibiting coexistence; and,

-   Consider actions it might take to further foster coexistence among
    different agricultural production systems.

**Appendix A**

**The following is the list of individuals involved in the preparation
of this paper who were AC21 members at the time of its completion and
therefore joined in consensus:**

Patricia Layton (Chair), Clemson University

Nancy Bryson, Venable

Daryl Buss, University of Wisconsin at Madison

Guy Cardineau, Arizona State University

Leon Corzine, Farmer

Michael Dykes, Monsanto Company

Bowen Flowers, Farmer

Sarah Geisert, General Mills

Randal Giroux, Cargill Incorporated

Duane Grant, Farmer

Gregory Jaffe, Center for Science in the Public Interest

Nicholas Kalaitzandonakes, University of Missouri

Russell Kremer, Missouri Farmers Union

Margaret Mellon, Union of Concerned Scientists

Steven Pueppke, Michigan State University

Bradley Shurdut, Dow AgroSciences

Jerome Slocum, Farmer

Carol Tucker-Foreman, Consumer Federation of America

Alison Van Eenennaam, University of California at Davis

Stephanie Whalen, Hawaii Agriculture Research Center

**The following AC21 members joined the Committee too recently to join
in consensus**:

Fuller Bazer, Texas A&M University

Michael Engler, Cactus Feeders

James Robl, Hematech.

**The following are the *ex officio* members of the AC21, who may
participate in discussions but under the Committee Charter may not join
in consensus**:

Dinah Bear, Council for Environmental Quality

Marcia Holden, National Institute for Standards and Technology

Kathleen Jones, U.S. Food and Drug Administration

Elizabeth Milewski, U.S. Environmental Protection Agency

James Murphy, Office of the U.S. Trade Representative

Adrian Polansky, Kansas Secretary of Agriculture

Paul Saxton, U.S. Department of State

[^1]: "Conventional" crops in this paper refer to crops produced from
    non-GE crop varieties that are not produced in compliance with the
    requirements of the Organic Standards Act. They may be grown with
    the intent of entering the general commodity stream, in which case
    they may be mixed with GE varieties of the crop, if commercial GE
    varieties exist; or they may be grown under identity preservation
    conditions and enter the market specifically as non-GE products~~.~~

[^2]: "Organic" refers to those crops or products produced in compliance
    with the Organic Standards Act.

[^3]: "Genetically Engineered" refers to organisms, or products derived
    from them, produced through recombinant DNA processes.

[^4]: "Impacts of Global Traceability and Labeling Requirements for
    Agricultural Biotechnology-Derived Products: Impacts and
    Implications for the United States," referred to as the "T & L
    report," and "Opportunities and Challenges in Agricultural
    Biotechnology: The Decade Ahead," referred to as the "O & C report".
    All of these reports are available on the USDA AC21 website.

[^5]: "*Retail consumers" are individuals who personally use or consume
    a good or a service from a retail establishment. Note that the AC21
    distinguished between "retail consumers" and "customers." See
    footnote on page 4 for the definition of "customers."*

[^6]: "*Customers" are individuals or groups who purchase, are provided
    with, or use, products and services. Note that the AC21
    distinguished between "retail consumers" and "customers." See
    footnote on page 3 for the definition of "retail consumers."*