Baker Creek Heirloom Seed Issues Public Comment on APHIS Notice

WASHINGTON, May 12 -- Martin Walsh, seed production manager at Baker Creek Heirloom Seed Co., Mansfield, Missouri, has issued a public comment on the Animal and Plant Health Inspection Service's notice entitled "Petition for Determination of Nonregulated Status: Bayer/Monsanto; Maize Genetically Engineered for Dicamba, Glufosinate, Quizalofop, and 2,4-Dichlorophenoxyacetic Acid Tolerance with Tissue-specific Glyphosate Tolerance Facilitating the Production of Hybrid Maize Seed". The comment was posted on May 11, 2020:

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I am the Seed Production Manager for Baker Creek Heirloom Seed Company. We specialize in open-pollinated heirloom varieties of both common and rare garden crops, flowers, and herbs. Our primary customers are backyard gardeners, market farms and organic farms and we sell and ship seeds to all parts of the world. We would like to submit that the deregulation of Monsanto GE Maize would significantly burden and hinder our ability to provide gmo-free corn products to our target market. We respectfully ask that APHIS not accept Monsanto's petition. In their petition, it is declared that the action would not cause a negative economic impact. We believe this comment to be false.

Baker Creek Seeds spends tens of thousands of dollars on testing of our corn varieties for the presence of GE Maize traits. It is our policy that we not carry or sell any corns which are contaminated with GE corn. If a sample of corn for which we contracted and which we need in our inventory tests positive for GMO then we are not able to purchase that corn from the contracted producer and we therefore are not able to acquire the needed corn seed in our inventory. This is a great loss to the producer and to Baker Creek Seeds as well as any customers who depend upon receiving a specific variety which they would not be able to receive because of contamination.

Prior to 2014, testing for GE maize in our corn varieties received from our producers discovered that annually, approximately 30% to 50% of the samples showed contamination with GE maize. This created significant economic loss for both our company and our producers. As a result of this, Baker Creek Seeds initiated a policy of requiring a 5-mile isolation distance for producers who are contracted to grow corn for us. This is an extreme measure to take since the recommended isolation distance from USDA for corn is only 660 feet and others in the open pollinated seed industry as well as some organic regulatory authorities recognize 2 miles or less as adequate isolation for maintaining varietal purity.

Our policy did work for us - and we have not had a GMO/GE contamination event since then with exception of a few commercially sourced corns (these sources do not produce for us on a contract basis and therefore might not use our standard of 5 miles for isolating their crop). Nonetheless....it is difficult, expensive and burdensome for us to maintain this extreme policy. Finding corn growers with this required isolation distance is very difficult. In fact, we do not have enough producers of corn with this degree of isolation in order to produce all of the varieties we require each year. Because of this, we must remove some varieties from our offerings due to a lack of inventory. Also, because of the extremes that our producers must satisfy and because of the increased risk of growing gmo-free corn (we will not buy the corn if it tests positive), we must pay the producers of our corns substantially more than they would receive for growing hybrid corns....considering that a bushel of corn weighs 56 lbs, Baker Creek Seeds is paying $840 per bushel for many of our corn varieties and that does not include costs associated with gmo testing and the extra handling time required to insure that we are offering gmo-free seeds to our customers.

Please decline the petition from Monsanto. Their product creates a dilemma for organic producers, open-pollinated seed companies and the end user (the growers - our customers). It is a shame that everyone except for the purveyors of GE maize must bear the financial burden of contamination. Deregulation of GE maize will exacerbate the difficulty in keeping our products free of contamination and could result in growers being unaware that their crop is actually a genetically engineered product.

Thank you for considering our comments.

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The notice can be viewed at: https://www.regulations.gov/document?D=APHIS-2020-0021-0001

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