WHEREAS alfalfa is one of the largest crops in Canada in area with Alberta’s output comprising approximately 30% of the country’s total alfalfa hay and seed production; and

WHEREAS many of Alberta’s forage seed producers sell products into countries that forbid the import of genetically modified (GM)/engineered alfalfa products; and

WHEREAS planting genetically modified/engineered alfalfa will pose a serious threat to the province’s forage seed exports which included fourteen million kilograms of exported alfalfa seed (estimated at $75 million) in 2014 as well as export hay, feed supplements and alfalfa sprouts for human consumption; and

WHEREAS alfalfa is the first perennial genetically modified/engineered crop that is pollinated by wild and tame insects; and

WHEREAS genetically modified/engineered alfalfa has the ability to cross-pollinate with non-GM alfalfa and there is a high risk of cross contamination due to seed escape and cross pollination which, once it occurs, will be impossible to contain; and

WHEREAS feral/wild alfalfa is rampant along ditches, fence lines, field edges, and uncultivated areas throughout Alberta and pollen and gene flow is unavoidable; and

WHEREAS alfalfa is a primary feed source for much of Alberta’s organic animal agricultural production and as such contaminated feed and seed sources will jeopardize the organic status of the industry as well as threaten the booming organic export industry; and

WHEREAS neither the Canadian Food Inspection Agency (CFIA) nor Health Canada has done a complete due diligence assessment prior to the approval of genetically modified/engineered alfalfa for release into Canada, having never done a quantified government economic impact assessment on the effects of genetically modified/engineered alfalfa on Canadian export markets;

THEREFORE BE IT RESOLVED that the Alberta Association of Municipal Districts and Counties request that Alberta Agriculture and Forestry and the Canadian Food Inspection Agency work with Alberta’s agricultural service boards, marketing groups, Forage Genetics Canada and other relevant stakeholders to prevent the introduction of genetically modified/engineered alfalfa to the province of Alberta until there is a marketplace and consumer acceptance in Alberta’s export markets including China, Japan, the European Union, and the Middle East.

Alfalfa is the single most predominant legume grown for forage in Canada (Canadian Forage and Grassland Association, October, 2012).  Alberta is a valuable producer of Canada’s alfalfa crop, comprising over 30% of the country’s total alfalfa output.  By area, it is the third largest crop in Canada with over 25 million acres in production and more than 80% of that production is located in the Prairie Provinces (Canadian Biotechnology Action Network, November, 2015).  At 15 million pounds in 2012, alfalfa seed exportation ranked third in Canadian exports.

Roundup Ready alfalfa is a genetically modified (GM) crop. Although several GM crops have already been introduced into Canada, alfalfa would be the first significant perennial plant to be genetically engineered and introduced into the Western Canadian environment that is naturally cross-pollinated by insects and grows wild throughout the world.  The economic benefits of GM alfalfa crops are unclear at this time – they have not produced higher yields, herbicide costs have risen and exported alfalfa products have been rejected due to contamination.

As some countries have strict importation laws forbidding GM products, the presence of GM alfalfa in Canadian hay exports could potentially put an end to export markets for Canadian grass and forage seed growers.  In 2014, China was Canada’s second largest importer of alfalfa seed and China presently has zero tolerance for GM alfalfa products. China blacklisted three American hay exporters in 2014 and rejected hundreds of container loads of hay due to the detection of Roundup Ready alfalfa (The Western Producer, November, 2014).  As hay is partially comprised of alfalfa, U.S. hay prices have dropped by about 12% due in part to the actions of China.

Mountain Sunrise Feed Co., a small hay exporter in the U.S., had been shipping about half its product (1,000 tons per month) to China but has now stopped because of the rejection of several of its cargoes.  The owner has been forced to lay off employees and is only using 50% of its production capacity due in part to reduced exports.  Anderson Hay & Grain, one of the largest U.S. hay exporters, stated that, “it’s had a huge impact on our business” (The Wall Street Journal, December, 2014).

Heather Kerschbaumer, president of Forage Seed Canada, personally experienced a $20,000 loss three years ago when Japan detected a canola seed in a shipment of timothy seed from her farm and subsequently cancelled their contract.  She is concerned about Roundup Ready alfalfa contaminating her alfalfa seed product, which would result in an additional loss of those markets.  “We find alfalfa in 60 to 70 percent of the lots shipped out of the Peace [Region].  If it is genetically modified, we would lose all those markets as well.”

Kerschbaumer recently visited the Imperial Valley in California, where the three blacklisted hay producers are located.  “They told us if you can’t keep it out of Canada, keep it out of the West.  If you can’t keep it out of the West, you should keep it out of Alberta.  If you can’t keep it out of Alberta, you should keep it out of the Peace because there will be benefits and bonuses paid on the seed that is produced that is GE free” (The Western Producer, November, 2014).

Canada’s flax industry has been devastated due to contamination of GM material.  In 2009, even though the GM variety of flax (CDC Triffid) had been de-registered by the University of Saskatchewan, about 3.5% of the farmer and elevator flax samples tested positive and contamination was found in exports to 35 countries that had not approved GM flax.  As a result Canada’s European market, which makes up 60% of its flax market, was closed.  Canada’s flax production declined significantly from 930,000 tonnes in 2009 to 518,200 tonnes in 2012.  The source of GM contamination was never identified.

As illustrated, it is highly probable that GM alfalfa contamination will occur if it is introduced into Alberta.  Non-GM alfalfa can be contaminated by GM alfalfa through: seed escape, pollinator-mediation, and feral/ volunteer alfalfa. More specifically, contamination can occur in purchased seed, seed spillage during planting, harvest and transport, insufficient cleaning of equipment, hay transport, animal vectors, dormant seed, and volunteer alfalfa growth.

Alfalfa is pollinated primarily by leafcutter bees but also by honeybees, wild bees and other native pollinators that are capable of traveling great distances and have unpredictable ranges.  Cross-pollination occurs in nature when pollinating insects inadvertently transfer pollen from one plant to another while gathering nectar.  Since perennial plants such as alfalfa are capable of flowering multiple times per year, the risk of genetic contamination by cross-pollination is significantly higher than annual crops.

In addition, Alberta’s variable climate and annual precipitation (Alberta Water Portal) limit the ‘best management practices’ for production of GM alfalfa that indicate cutting hay prior to 10% bloom in order to contain gene flow and reduce contamination.  Fields that are in hay production one year and then seed production the next, or vice-versa, often due to the weather patterns, may also add to the problem of contamination.

New genetically modified varieties of alfalfa currently being marketed in the U.S., such as HarvXtra, a low-lignin/Roundup Ready, “stacked trait” alfalfa is being marketed as a great improvement over existing varieties, since the low-lignin trait allows hay to be cut later in the season (at least 50% bloom) without loss of feed quality, thus reducing the effects of weather on timely management and encouraging growers of mixed hay or alfalfa hay fields to take advantage of more tonnage per cut of hay.  However, as noted earlier, this increases the threat of contamination through pollen transfer and gene flow from the blooming GM alfalfa fields to non-GM nearby fields or wild populations (even roadside alfalfa plants) within insect flying distance (from three to five miles).  It is worth noting that there are currently non-GM alfalfas, such as the Alforex variety ‘Hi-Gest’, being marketed in the U.S. that have also been bred with low-lignin qualities and, therefore, the ‘advantage’ is available in non-GM alfalfas as well.

Alberta’s thriving organic agricultural industry could be jeopardized by allowing the introduction of GM alfalfa into Alberta.  As per the Canadian Organic Products Regulations and Standards, which came into force on June 1, 2009, GM ingredients in organic products is prohibited, regardless of whether or not those GM ingredients are registered (Agriculture and Agri-Food Canada).  The Canadian organic food market is positioned for exponential growth.  According to the census completed on May 16, 2006 there were 2,629 farms with organic production in Alberta, 5.3% of all farms in the province.  The predominant group of organic products grown in Alberta was hay or field crops (60.5% of the province’s organic farms), (Statistics Canada).  In 2012 organic food sales in Alberta totaled $416 million which was second only to British Columbia in the organic fruit market and second only to Ontario in prepackaged groceries (Global News, August 2014).

In order to be classified as “organic”, all agricultural products used for feeding livestock must be certified organic to the respective program and cannot contain any GM material (Alberta Organic Producers Association).  Dairy cows, in particular, are fed large amounts of alfalfa feed; although beef livestock, hogs, poultry, sheep/lamb and goats may also consume feed containing alfalfa.  Therefore, any traces of GM alfalfa found in organic hay or feed supplements would critically damage these markets, as well as the organic dairy industry.

Additionally, there is a significant market, both domestic and export, for organic alfalfa seed for hay production which would be destroyed if GM material was detected.  Canada currently has high quality seed and a reputation for clean organic products (Saskatchewan Organic Directorate).  However, the introduction of GM canola into Canada in 1995 has devastated the organic canola industry.  The unintended presence of GM canola in organic canola fields was not detectable before harvest, nor could it be prevented due to the prevalence of GM canola on prairie farms (Canadian Biotechnology Action Network, April 2013).  “Every organic grain farmer has lost the right to grow organic canola free of GMO contamination risk.  Every organic grain farmer has lost the ability to sell organic canola into Europe” (Saskatchewan Organic Directorate, May 2006).

At this time there is a very real threat to Alberta’s alfalfa industry if Roundup Ready alfalfa is introduced into the province.  Indeed, despite assurances that Roundup Ready alfalfa would enhance weed control options and flexibility, it appears that the emergence and increased presence of herbicide-resistant weeds due to increased use of Roundup has created a need for the use of a wider variety of herbicides on a crop that typically does not require application of herbicides.  According to USDA data, 90% of all alfalfa produced by farmers in the U.S. was previously grown without the use of herbicides.

The cost of herbicide is high, foreign export markets are tightening and, in turn, producers stand to lose millions of dollars in sales as markets become more limited due to contamination of genetically modified biotypes.  At this time, genetically modified / engineered alfalfa must not be introduced into Alberta.

List of Sources

Alberta Organic Producers Association, Alberta Organic Certification, Online.

Alberta Water Portal, Climate in Alberta, Online.

Agricultural Biotechnology in California Series, Roundup Ready Alfalfa: An Emerging Technology, Online, 2004.

Beckie, H., Status of Herbicide Resistance in Canada, Online, January 2014.

Canadian Biotechnology Action Network, The Case for Preventing the Introduction of Roundup Ready Alfalfa, Online, April 2013.

Canadian Forage and Grassland Association, Alfalfa in Canada, Online, Oct. 24, 2012.

Global News, Is Alberta the Next Organic Hotspot?, Online, Aug. 18, 2014.

Government of Alberta/ Alfalfa Seed Commission of Alberta, Online, April 2015.

Inter Press Service News Agency, U.S. Report of GE Alfalfa Contamination was ‘Inevitable’, Online, Sept. 13, 2013.

Saskatchewan Organic Directorate, Roundup Ready Alfalfa & Organic Agriculture, Online.

Saskatchewan Organic Directorate, “The Apellants Factum”, Online, May 29, 2006.

Statistics Canada, Organic Farms, Online.

Sustainable Pulse, Center for Food Safety Sues USDA Over GM Alfalfa Approval, Online, March 14, 2014.

The Wall Street Journal, China’s Hard Line on Biotech Burns U.S. Hay, Online, Dec. 15, 2014.

The Western Producer, Roundup Ready in Alfalfa Exports ‘Catastrophic’, Online, Nov. 28, 2014.

Wong, D., Alberta Agriculture and Rural Development, 2011/ 2012 Canadian Grass and Legume Seed Exports, Online, Oct. 1, 2012.

The AAMDC has no active resolutions directly related to this issue.

Agriculture and Forestry: The regulation of genetically modified (GM) crops is coordinated between the Canadian Food Inspection Agency (CFIA) and Health Canada. GM crops go through intensive regulatory reviews in Canada that are based on international standards and guidelines. These plants cannot enter the marketplace unless a rigorous assessment by the CFIA and Health Canada determines these plants are safe for use as food or feed, and that they are as safe for release into the environment as other conventional plant varieties already being grown.

The federal regulatory assessment process does not assess social or economic factors, such as marketplace and consumer acceptance. The CFIA and Health Canada regulate for safety and efficacy of GM products, but are not responsible for evaluating need. To date, the CFIA and Health Canada have not enacted restrictions on GM crop producers.

Our government operates under federal legislation and regulations when it comes to GM crops, and supports the federal government’s science-based evaluation system for GM crops. We also support the responsible and appropriate development and adoption of biotechnology in agriculture to allow for the commercialization of innovative products, while safeguarding public interests, such as human food safety, human health, animal feed safety, animal health and welfare, and environmental well?being.

Although the CFIA and Health Canada have approved certain GM alfalfa technologies as safe for food, feed, and the environment, we recognize there are concerns regarding potential market access implications, as GM crops are not universally accepted throughout the international market.

The Government of Alberta deferred responsibility on this issue to the Canadian Food Inspection Agency (CFIA).  In response to this resolution, the CFIA indicates that environmental safety assessments take into account the potential of the plant to become an agriculture weed or to be invasive of natural habitats; the potential consequences of gene flow to other plants; the potential to increase the activity of a plant pest; and the potential impact on non-target organisms and biodiversity.

CFIA notes that Roundup Ready (RR) (glyphosate tolerant) alfalfa was authorized in 2005, and alfalfa with reduced lignin was authorized in 2014 after undergoing safety assessments by the CFIA and Health Canada. The response from CFIA also explains that before varieties of alfalfa can be fully commercialized in Canada, they are subject to variety registration to ensure that varieties sold meet the definition of a variety and are accurately represented in the market; facilitate the seed certification process; provide tracking and tracing in commercial channels; and help ensure varietal identity and purity in the market. Proceeding with variety registration is a business decision that rests with the applicant.

In 2013, five RR alfalfa varieties were registered in Canada and in 2016, an alfalfa variety with both the glyphosate tolerance and reduced lignin traits was registered. Once a GM crop has been authorized for environmental release and obtained other appropriate regulatory approvals, including variety registration where applicable, it is considered to be like any other commodity crop.

The CFIA response emphasizes that the Government of Canada believes that the industry itself is best positioned to make decisions regarding plans to commercialize GM alfalfa in Canada and to implement stewardship programs to facilitate the coexistence of GM alfalfa with conventional types.  Further, the response emphasizes that the Government of Canada believes that producers should have choice in selecting the agricultural practices, products and technologies that offer them the most benefits, both economic and environmental.

As the response from CFIA does not express any interest in preventing the introduction of genetically modified or engineered alfalfa, this resolution has been assigned a status of Intent Not Met.