NCC Supports Deregulation of Low Gossypol Cottonseed

The NCC submitted comments on Feb. 5, 2018, to the Animal & Plant Health Inspection Service in support of the petition submitted by Texas A&M University seeking a nonregulated status for cottonseed genetically engineered to contain ultra-low gossypol levels.

Published: February 9, 2018
Updated: February 9, 2018

February 5, 2018

Regulatory Analysis and Development
PPD, APHIS, Station 3A-03.8,
4700 River Road Unit 118,
Riverdale, MD 20737-1238

Dr. John Turner
Director, Environmental Risk Analysis Programs
Biotechnology Regulatory Services
4700 River Road Unit 147
Riverdale, MD 20737-1236

RE: Docket ID Number APHIS-2017-0097.  Petitions for Determinations of Nonregulated Status: Texas A and M AgriLife Research Cotton Genetically Engineered for Ultra-low Gossypol Levels in Cottonseed. Transformation Event TAM66274.  Petition 17-292-01p.

Dear Dr. Turner:

The National Cotton Council (NCC) appreciates the opportunity to comment on the Animal and Plant Health Inspection Service’s (APHIS) “Petitions for Determinations of Nonregulated Status: Texas A and M AgriLife Research Cotton Genetically Engineered for Ultra-low Gossypol Levels in Cottonseed (TAM66274).”

The NCC is the central organization of the United States cotton industry.  Its members include farmers, ginners, cottonseed processors and merchandizers, merchants, cooperatives, warehousers and textile manufacturers.  A majority of the industry is concentrated in 17 cotton-producing states stretching from California to Virginia. U.S. cotton farmers cultivate between 9 and 12 million acres of cotton with production averaging 12 to 18 million 480-lb bales annually. The downstream manufacturers of cotton apparel and home furnishings are located in virtually every state. Farms and businesses directly involved in the production, distribution and processing of cotton employ more than 125,000 workers and produce direct business revenue of more than $21 billion.  Annual cotton production is valued at more than $5.5 billion at the farm gate, the point at which the farmer markets the crop.  Accounting for the ripple effect of cotton through the broader economy, direct and indirect employment surpasses 280,000 workers with economic activity of almost $100 billion. In addition to the cotton fiber, cottonseed products are used for livestock feed and cottonseed oil is used as an ingredient in food products as well as being a premium cooking oil.

The introduction of genetically engineered traits in cotton began in the mid-1990’s and U.S. cotton farmers have rapidly adopted the new technologies to best fit their production system.  Currently, approximately 90% of U.S. cotton acres are planted to insect resistant and/or herbicide tolerant cotton varieties.  The latest estimate of the benefits of these insect resistant varieties is 185 million pounds per year increase in production; 1.9 million pounds per year decrease in insecticide use; and $103 million per year increase in net revenue for U.S. cotton farmers.1 The benefits of herbicide tolerant cotton in the U.S. include 6.2 million pounds per year decrease in herbicide active ingredients applied and $133 million per year savings in weed control costs.2

The NCC supports the deregulation of cotton event TAM66274, which has been developed to maintain ultra-low levels of gossypol in cottonseed.  Cottonseed is an oilseed that contains high-quality proteins, and the U.S. cotton crop, on average, produces about a million tons of cottonseed protein as byproduct.  Currently cottonseed is primarily fed to dairy cows as part of the feed ration due to higher levels of gossypol in conventional cottonseed that causes underutilization in other animal species of these high-quality proteins.  However, TAM66274 has the potential to increase the value of cottonseed to cotton farmers by expanding the market beyond feed for dairy cows to include swine, poultry and aquaculture that can more efficiently convert feed to food.

The impact of TAM66274 could benefit all cotton farmers even if they are not planting this variety.  When U.S. cotton acreage increases, the price of cottonseed typically decreases due to supply and demand factors.  The price and use of cottonseed for use in dairy rations is also impacted by the market situation for milk and other dairy products.  However, if cottonseed with ultra-low levels of gossypol is accessible in more novel uses such as pet food and aquaculture, conventional cottonseed should be at a higher demand for use in feed rations for dairy and beef cattle.  Additionally, processors and manufacturers of other livestock and aquaculture feeds can benefit by gaining access to an additional source of high-quality protein.

Extensive field evaluations demonstrated that cotton varieties containing TAM66274 pose no greater ecological risk than conventional cotton varieties.  In fact, the sustainability of U.S. agriculture will be enhanced since the new food and feed supply from cottonseed containing TAM66274 will not require additional land, water, fertilizer, or crop protection chemicals.  The gossypol levels resulting from this trait are only a fraction of the levels in conventional cottonseed and are well below levels deemed safe for use in human food and non-ruminant animal feed.  Additionally, the ultra-low gossypol trait is only expressed in the seed, leaving levels of gossypol and related plant defense compounds unchanged in other plant tissues where it will continue to deter pests.  Since the only difference between this new variety of cottonseed and conventional cottonseed is the low gossypol level, coproducts such as cottonseed oil, hulls, linters and meal for animal feed can be processed in the same way.  TAM66274 is agronomically equivalent to conventional cotton and can be produced in the same manner as other varieties.  In addition, the yield, fiber quality and plant growth characteristics can be equivalent to its parental line when the trait is properly introgressed.  As a result, once TAM6674 is approved in the U.S., cottonseed containing this trait can be identity-preserved and marketed for the specific new uses it is adapted for.  However, if the seed will be sold into existing marketing channels for current uses, the seed can be comingled with conventional cottonseed.

The NCC believes that the deregulation of TAM66274 is a key step towards giving cotton farmers access to this technology and, ultimately, allows people to utilize the food and feed benefits of this technology.  The NCC appreciates the opportunity to comment on this petition and urges APHIS to grant this event a nonregulated status under 7 CFR part 340 to provide access to expanded markets and new uses for cottonseed, thereby improving the economic opportunities available to cotton famers.

Thank you for your consideration of our comments.

Respectfully submitted,

Gary M. Adams
President and CEO