Verbal trashing of the USDA and/or the staff that did this rule is
not helpful, and fails to recognize the nature of the process and the
political context in which it evolved. Moreover, it will not make it easier
to fix the many problems with the proposed rule. It may make individuals
feel better, but my advice is -- get it out of your system and start
drafting your comments, sharing them with others, exploring commonalities, etc.
A concerted effort MUST be made to fix the rule in order for the
organic/consumer/environmental community to be in a position to pursue other
options later in the event the effort to fix the rule fails.
Those urging the community to just "kill the rule" (and the program) are
playing chicken with a process that will, in my judgement, go forward with
or without their constructive (or distructive) engagement.
Be as positive as possible, praising those portions of the rule that
are good -- there are some. Go for the maximum degree of fix with a minimum
number of word changes. Do not preface each change with language to the
effect -- "this is a major deviation"..."this is a change of monumental
significance." Sometimes just a few subtle changes in wording will totally
fix, and indeed actually strengthen a section.
Resist the temptation to comment in much detail on the first 2/3 of
the document where the USDA lays out its reasoning/logic in such
mind-numbing detail. The part that matters is the rule language itself.
Most if not all comments should be accompanied by specific suggested changes
in the language, i.e. replace passage X with the following language "in
quotes." Invest 2/3 to 3/4 (or more) of the supporting narrative to why
your suggested, alternative language is responsive to the language/intent of
the law, and NOSB guidance, and only 1/3 to 1/4 (or less) of the narrative
to why the USDA got it wrong in the proposed rule.
Focus on two things --
1. The big issues and the principles/themes that must be adhered to for the
final rule to hold together conceptually and legally, and advance the
ability of organic agriculture/food industries to thrive.
2. Provisions/features that you, or an organization you work with, have
specific, concrete experience with and/or data to share which provides
insights into the way the organic world actually works now and could, in the
future, work better. In the end solid facts and reasoned arguments on
specific, concrete matters will maximize the chance that USDA will revise
the rule in a constructive way.
Last, the final rule, when it comes out, will be neither perfect,
complete or set in stone. USDA is bound to punt on a few issues, just as
they punted in this round on the big three. Getting a major new program in
place in a growing industry takes years, patience, and ability to stay
focused and keep pushing in the directions you feel the program must go.
There will be no home-runs or knock-outs, just a lot of foul balls.
In the next 10 days or so I will post a synopsis of the major
points/recommended changes likely to appear in comments from Consumers
Union. I urge others to do the same; but I urge people to keep the posts
short and to the point, focused just on the proposed changes in language, so
we can get through them all and still have time to do our own.
Note New Address!!:
Charles Benbrook 208-263-5236 (voice)
Benbrook Consulting Services 208-263-7342 (fax)
5085 Upper Pack River Road email@example.com [e-mail]
Sandpoint, Idaho 83864 http://www.pmac.net
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