**Comments on Department of Agriculture, APHIS**

**Docket No. APHIS-2007-0044-0003**

The review of Glyphosate tolerant alfalfa will examine many aspects
relative to the current concerns and the pending EIS. However, the
question relative to seed production of this product can be boiled down
to the concept of monitoring the seed you produce and do not ship any
seed to a market that does not want it or will find fault with it.
Further, we must balance the economics against the need for sufficient
segregation. The question facing the industry is how can this be done?
The seed industry is currently involved in stewardship programs to
monitor seed production that have proven to be very effective at meeting
goals for genetic purity of the seed crop.

Currently, the alfalfa seed industry had chosen to produce seed in
several production areas in order to find adequate isolation.

Any attempt at regulation needs to consider several areas, Education,
Communication, Cooperation, Compromise and Respect for opposing
viewpoints.

**Education --** The seed industry needs to continue to produce science
based programs that educate seed growers and hay growers in the best
management practices to achieve the goal. This is the stewardship side
of the equation and is already in place. Non-GMO producers need to adopt
stewardship programs also. Use of the seed certification system and
third party audits will allow for better communication and education.

Current research needs to be implemented into standards such as has been
done in some state seed certification programs. The industry could also
benefit from working with the new AOSCA plan for expanded services.

Seed production schemes are well run and due to buyer seller
arrangements in the trade seed production can be monitored to fit the
market you intend to sell into.

**Communication -** Notification of planting and location of fields has
always been a "secret." However, ask any grower who has GMO alfalfa and
they will give you directions to the fields. Better disclosure of field
location may assist in production of crops to meet export demand. Also,
timely sharing of planting plans and experiences will facilitate the
process.

The small number of production companies makes for effective
communication in the seed industry.

**Cooperation** -- Pinning protocols are in place to monitor GMO corn
and alfalfa and these plans are quite effective in the cooperative
effort to produce GMO and non-GMO crops.

The major question facing the alfalfa industry regarding seed export is,
"Will a threshold for LLP of GMO ever be established and agreed to by
all parties concerned?"

Working with seed certification agencies will allow better cooperation
between conditioners and growers. This is an area that organic growers
need to be aware of. Utilizing seed certification for organic seed
production can help. This will assist in planting decisions.

Cooperative efforts need to extend to other countries that produce seed
that is imported into the US for conditioning and then exported.
(Australia)

Allowing for farmers to choose the type of production they will have is
also an important part of cooperation.

**Compromise** - It may be time for the non-GMO portion of the industry
to develop their own set of best management practices as the GMO sector
has done.

Recently the industry agreed, within the confines of seed certification,
that the current isolation standards were not sufficient to reach
desired levels of genetic purity. The compromise position was to develop
boiler plate language to allow a seed company to request added services
to produce a product that was to meet a higher purity standard. This has
always been an option in seed cert. but is now formalized.

The realistic approach in seed production is to realize that zero is not
attainable. This is the area of compromise. Sophisticated tests are in
place and are being utilized. Buyers can attain the product they want
and can avoid those they do not want.

**Respect for opposing viewpoints** -- This will be a key to being able
to sit down with the entire industry in order to achieve the points
listed above.

The industry can avoid the use of GMO in areas of production where the
product ends up in a sensitive market. This is a management practice and
not a regulatory problem.

Parting Questions: If GMO had world wide acceptance and all growers had
access to GMO contracts what would be the level of concern in the
industry? Therefore, the major focus for the industry may be market
acceptance. A goal they have not been able to achieve yet but will come
with time and work in the areas mentioned above.

Greg Lowry, Executive Vice President

Idaho Crop Improvement Association, Inc.

55 SW Fifth Ave, Suite 150

Meridian, Idaho 83642

<Ghlowry@aol.com>