Thanks to Will Easton for opening the door thru which I can drive my
rant, upon which I have been sitting, as though it were a
disgruntled porcupine, since December 16, 1997:
> My question to the list is, what happened between the time that
> the NOSB made it's recommendations and the USDA's issuing of
> something entirely different? Who got to whom? Were political
> contributions involved? Any investigative journalists out there
> feel like taking this up? There's got to be a juicy story in it
The question I hear in this is: what is the general process by which
this executive branch, federalist rulemaking procedure is operating,
and what are the historical specifics of the NOP issue as regards
I've been waiting for someone to ask this since December. And have
been asking it myself at the local level.
I gave the welcome at this year's Upper Midwest Organic Farming
Conference, and the largest issue this year was the draft organic
rules. I have been following this issue for about two years, more
intensely in the past year, since Mike Hankin of the NOP drafting
team came to UMOFC in '97 to learn what he could from the citizens
and farmers there. I knew there was massive irritation and fury afoot
in the land, and I was concerned, for reasons I'll get into in a bit.
So my welcome message was pretty simple:
For the love of lefse, quit glitching, stop guessing at motives
and conspiracies, find out what the political game is...and PLAY IT.
Change the rules of the game if desired. Life is not chess; you make
it up as you go.
Be calm. All is well.
And let's have some fun while we're at it, since we're all going to
be dead soon anyway (well, as individual egos, probably).
I spoke to the NOP staff in late January and again in early Feb.
about the rulemaking process. I did this because I wanted to know
more about who these people are and what they thought they were
doing. By that time I had heard or read comments including:
--This is war.
--If we don't beat the [let's say tar] out of them first, there will
be nothing left to fight for.
--These rules are rape. I have been violated and I want to get
even. They think they can get away with this.
--These are simply [let's say portholes] and offer them [sic] no
quarter till they cease and desist.
--Let's not let the feds run us over.
--They have been paid to destroy organic farmers.
--This is political warfare...I knew from the day I walked out on the
street and got the [let's say tar] beat out of me by someone much
bigger than me that there wsa only one thing to do--hit and don't
talk until they are down and out.
--I feel betrayed, and I want to see heads roll in the NOP.
I thought I'd stumbled into discussions of US military activity in
War, rape, fighting, offering no quarter, getting run over, warfare,
betrayal, decapitation. I thought, is this what we in the organic
community are about? These values? These metaphors? Is this as far
as we've come in our thinking, when moments of disagreement come up?
We're sitting on a multibillion dollar industry...we are being asked
by people in the executive branch of the federal government to
assist them--in an unprecedented fashion--by giving them input and
organizing input from citizens. And the best we can come up with is
the Voice of G.I. Joe?
I compared this to the conversations I'd had with the NOP staff...and
I reflected that, no, I didn't know any single one of them well
enough to have built major trust in them as individuals, but I pay
their salary, so let's see what they have to say. I mean, do they
talk like marauders from a Mad Max movie? do they hate us in the
organics industry? are they driving Lexuses (Lexi?) supplied to them
by Sandoz and ADM?
One of the staff said to me, "I kinda wish we had the imperial power
people in the organic community are ascribing to us. I'd use it to
get a few more square feet of office space."
I've studied (and lectured on) gender differences in communication
since the mid-80s, so I feel comfortable observing to you: the
above speakers were all men. Nothing personal, we're just at this
really awkward point in the history and culture of communications,
where all kinds of power configurations are changing, and people
default to the old patterns in times of stress.
In local conversations about the NOP, I found two trends, and this
may be a purely Upper Midwest perspective, though I'm guessing not:
1) Womenfolk were willing to put their feelings on hold and talk
about the process and how best to approach it strategically.
2) Some menfolk were willing to do this, but the loudest and most
energetic voices in the discussion around the NOP sounded like they
were angling for a spot in the next Van Damme movie--/Kung Fu
Government USDA Conspiracy/ (I would cast Jackie Chan as Grace
Gershuny *and* Mike Hankin). Some of them don't know the difference
between e-mail and a Web site--the communication tools of this
response process. (Eh, communication--that's touchy-feely stuff.)
But, no matter.
I know there is a definite contrarian thread in organic farming. I
admire that. Stepping away from the herd o lemmings requires a
certain flair for the contrary. Whether it should become a habit
(never mind an addiction), to the detriment of getting things done,
I don't think so.
I'm a womanfolk. I also started out as a journalist. My very first
question when I went to read the rule on 12/16 was: "Draft" rule
implies a revision process; what does it mean, and where are the
places that influence can be brought to bear? How do we analyze this
process? How do we organize response?
When people have claimed some conspiracy or attributed motives to the
NOP staff, the USDA, or others, the 18-year-old cub reporter in me
thought, and sometimes asked: "Can you provide me a source on that?
Can you show me your facts? Who wants to allow/destroy/control this?
Who is the 'them'? Who is the 'they'? Who wants to destroy organic
And I'm a former state government employee, who headed up an
unfunded mandate for a State of Wisconsin executive branch agency.
So I've got some personal empathy for Gershuny, Hankin, et al. Some
of the things that teachers and administrators said about me in my
tenure in that project and my workteam seared my nose hairs.
My understanding, all along, of the NOP draft rule has been based on
the very little I know about the federal executive rulemaking
process. For instance, and some of this may be factually wrong, and
some is pure interpretation on my part:
--The USDA is an executive branch agency and is responsible for
schlepping the process for executive rulemaking for issues coming
under its jurisdiction.
--The USDA is a damn big agency, with thousands of employees, and
some of them are good human beings.
--Not everybody who drops Dan Glickman's name could pick him out of a
herd of white buffalo.
--There are people coming to the table on this topic in the organics
industry with their own self-interest threatened, and projecting
onto others; when you need to do that, government is always a nice
--A rule starts by getting drafted (I'd like to learn more about that
process) by a team of people assigned to that topic and task.
--The draft goes to the Office of Management and Budget for their
comment and revisions (so they can ensure that one agency's draft
rule doesn't include anything way out of line with other agencies,
since we are talking about living with a unified federalist
government, and that implies some kind of consensus on various
--The draft is revised in line with OMB's
--The draft is submitted to the public for citizen comment (the NOP
program has done the unprecedented and the ambitious by opening up
this draft for comment via the World Wide Web--has anyone ever done
this before, in the history of federalism in the US?).
--These comments are build into a revised draft.
--Which goes back to OMB???? [This is where I get real fuzzy on the
--At some point, a finalized version of the rule is presented to
Congress for its approval. At this point there is some possibility
of changes by those who wish to lobby for them.
This is the process as I understand it. Parts of it may be
It is NOT a legislative (bill-making) process.
I don't see how an industry can organize response without
apprising its constituents, in a reasonable and proactive way, about
Now. It may well be that somebody inside the USDA is engaged in a
conspiracy to drive organic farmers out of business. I think of
something that Craig Cramer said to me once, as we were reflecting
on some other purported "conspiracy":
Never attribute to conspiracy that which can be explained by
incompetence, confusion, or an unfinished process.
I'm a fan of conspiracy theories--as entertainment and as mythos. I
go to the Disinformation Web site (http://www.disinfo.com) regularly.
But I don't think it makes a basis for very effective action. And
believing in conspiracies seems to me to hand over the game before
I've been deeply amused by some of the petitions I've seen people
circulating, with energy and bluster and adamant enthusiasm. One of
them I saw last week called in 48-point-bold type for "The USDA to
revise its draft organic standards." Now there's a good idea! I
guess all along the USDA has been turning unrevised drafts into the
law of the land. :^) I saw one that said, "I oppose the draft
rule." How can you oppose a draft? You *comment* on a draft, you
can disagree with its *contents*...you can ask the authors to alter
their perspectives or presentation...but a draft is an artefact of
thinking-in-progress. I was thinking of the times I've worked as a
book editor or a writing instructor and consultant, and imagining
myself saying to the author or student who submits a draft for my
review: "I oppose this." What could that mean?
I've wanted to grow organic small grains since I was a teenager.
I've been in the co-op movement since the 70s, in urban agriculture
for the past twelve years, and worked professionally in sustainable
ag since 1990. So when I talk about "our" industry, it's me talking,
Michele, not as a staffer of CIAS.
I have strong concerns, as a green businesswoman and consumer, about
what I've seen in our industry's response to the draft federal rule.
Our industry. Our agribusiness sector. Currently at about $3
billion a year in sales, likely to jump to $10 billion by 2002. The
industry I would like to see controlled by people whose values are
not primarily bottom-line-driven. (And from where I sit, large
corporations and multinationals can't afford those values, though
some people tell me I'm wrong about that.)
I don't see a lot of evidence of understanding in our industry about
how relationships are made and communication happens in a large,
bureacratic democracy. About how people reach people inside of big
institutions, and how people in those institutions reach out for
citizen input. We are going to need to INCREASINGLY work with people
in the USDA--we're past the point in history where we can just hope
the Big Boys will go away. You start generating sales in the
billions, somebody's going to notice. One of the prices of success.
Didn't we all always *want* that success? Or, at bottom, did we hope
we'd remain kinda outcasts, digging our carrots and shaking a fist at
power...rather than claiming our own?
I haven't seen a single public information piece, by any of the major
organic players or organizations, on the details of the democratic
process at work: the process by which the executive branch of
federal government drafts, takes comment on, revises, publishes, and
makes law of a rule. Where the points of intervention are, where
it's possible for different players to affect the outcome (other
than just the comments). Nothing to put citizen comments in
context. In fact the context set has been one of outrage, of
reactivity, rather than proactive democratic action. I haven't yet
heard anyone say, "GREAT! The thing is finally out, now we can get
to the work of shaping it!"
I happen to feel strong emotion--STRONG emotion--over this draft
rule's content myself. Organic food is part of what saved my life
in the 1980s, when I got taken out by organophosphate pesticides. I
now know some of the people who grew the food I ate then, that helped
me get my health back. I take organics very seriously.
My fears, however, are in how we organize ourselves to respond to
this draft rule. I'm afraid mostly that we've got a tiger by the
tail...and you can't always carry something in a hand that's making
There are good reasons to be vigilant, suspicious, and even cynical
about things like engaging in democratic process. Remember where I
come from, and remember I spent nearly ten years in court against
Johns Manville and other asbestos companies responsible for the
willful deaths of tens of thousands of workers and their families,
including my father. I am no Pollyanna.
But the point where suspicion and cynicism turn into psychodrama,
where democratic action gives way to the theatre of Power (rather
than the housework of Empowerment), then energy is diverted from
action...and is no longer helpful, so far as I can tell.
I'll go neuron for neuron, cell for cell, with the most cynical,
suspicious, anti-democracy, gun-toting, flag-waving vigilante in
Michigan on not trusting people who claim to help me without my
input. I grew up in a deindustrializing city, like Flint, and I
came of age during Watergate, My Lai, and the years of FBI
surveillance of citizens. There's a lot to be cynical about. But I
*refuse* to give up democracy, and that's what I see happening in
many places in the organic movement. Democracy is, above all, a
communications process, a way of moving and negotiating power, and
the idea was to move human society toward shared empowerment, rather
than imposed power. Expecting a bureaucratic process or program to do
our work for us is closer to monarchy, isn't it?
Is the USDA the enemy? Is the NOP drafting team or any of its
members? Why are we in our industry making people who could make
strong and effective inside-the-system allies for us into enemies?
Why are we leading with our suspicions, rather than our interests in
the outcome? Why are we guessing at motivations, rather than
sussing out the power flows and getting in the middle of the game?
Why are we acting like victims?
One last thing.
Say you're riding along on a motorcycle, on a lovely Wisconsin rural
road, on a beautiful Friday in late March when the weather is
unusually warm, and you're doing about 55, and you see the road make
a sharp left up ahead to follow a plat line. If you were in a car,
you'd approach the turn, slow down, turn the steering wheel to the
left to point the front wheels to the left to go left.
You don't do that on a bike; if you pointed your front wheel to the
left, you'd jackknife and end up eating corn and gravel. What you do
is you press on your left handgrip, effectively steering right. And
the physics and Zen and Dao of motorcycling being what they are, you
go left. It's completely counterintuitive till you get it in your
body, and it's called "countersteering." Steer right to go left, and
vice versa. (And while we're on the topic of the spirituality of
biking, you may know there is no reverse gear on a
motorcycle--straight ahead is all you get help with from the engine.)
I've been thinking about this as regards the draft organic rule.
Which would I rather have seen--a draft rule that outlawed GMOs, and
irradiation, and sewage sludge? So that the comments that came in
could do only one thing: loosen those standards? (Because the
drafting team is, as I understand, required by law to incorporate
reasonable [legally defensible] citizen comments into their
To sum up, energy is as precious as topsoil and clean water--it's
another form of Life. Squandering it on fears, motivation-guessing,
dramas, name-calling, posturing, and bad juju is pointless...and
I echo Will's question about an investigative piece on the NOP, or
some kind of story that pulls it all together. I've been in touch
with about half a dozen journalists in the past three months, trying
to interest them. It's too complicated. It's not sexy enough. They
want to know beforehand that somebody got to somebody, payola,
I'm not saying none of this happened. I don't know. My point is,
democracy in action doesn't sell newspapers; a president with a
zipper problem does. And it's a lot more exciting to get cranked up
over metaphorical rapes than the mundane reality of actual ones.
Enough for now. Thank you for your forbearance.
Michele Gale-Sinex, communications manager
Center for Integrated Ag Systems
UW-Madison College of Ag and Life Sciences
Voice: (608) 262-8018 FAX: (608) 265-3020
In the end, they will lay their freedom at our feet
and say to us, 'Make us your slaves, but feed us.'
--the Grand Inquisitor, Dostoevsky
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