I am posting this at the request of Fred Kirschenmann.
Cross-posting is fine and encouraged.
Fred has completed a "Preliminary Draft" of comments on the organic
rule. They print 27 pages in Word (not sure how many off the web page).
These comments will eventually be submitted to USDA on behalf of Farm
Verified Organic, and possibly other signatories. Fred asked me to post his
draft comments on the PMAC page in order to facilitate widespread access to
them. He invites both groups and individuals to download the file off the
page and use it as a point of departure in your own comments.
He also welcomes comments and supporting documentation. He asks
that individuals provide specific alternative language and statements of
justification rather than general philosophical reactions.
If you would like a copy of the comments e-mailed to you in a Word,
Word Perfect, or Rich Text format, I will convert it and e-mail it to you as
an attachment. DO NOT REPLY TO THIS MESSAGE WITH SUCH A REQUEST; E-MAIL ME
PRIVATELY. IF YOU HIT REPLY, ALL OF SANET MAY BE BUGGED BY YOUR REQUEST, AS
THEY WERE WITH MY PANNUPS SURVEY (sorry everyone, my mistake). The
formatting will not be perfect, but better than having to re-type 27 pages.
The comments can be found at: http://www.pmac.net/nosfk9.htm
Comments to Fred can be e-mailed to Fred care of FVO at
Or, faxed to Fred via FVO at 701-486-3580, or mailed to Fred at FVO,
Rural Route 1, Box 40A, Medina, North Dakota 58467
I hope people find these comments useful. They address in detail
many of the very important problems with the proposed rules beyond the big
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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