Thanks for sharing your thoughts - very interesting!
I agree with much of what you say here, including the voice to be cautious
about assigning unproven motives and falling too quickly into a war model
of dealing with issues.
I would, however, find a different balance point than you would on certain
--- (1) You call these standards "draft" standards and thus ridicule those who call for opposing them - for instance you say
<<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.>>
First, my understanding is that these are not accurately called "draft" standards but are "proposed" standards (actually "Proposed Rule", I believe, for those keeping track of such details). My understanding is that these were proposed as the standards THAT WOULD EXIST, unless they decided to change them. That's pretty close to final to me, and therefore not at the draft "sketch out" level you seem to suggest (and which, of course, the USDA has started suggest, after seeing the uproar and outrage about them - but that doesn't mean that was the notion of them when they first were presented).
Second, these rules are so far different from what they were supposed to be - per the 1990 Organic Foods Production Act (OFPA) and per the existing standards of the organic industry that they were directed to put into law - after many long years and many human-hours of work - that it is reasonable to question the current process - to question whether another round can get it right - whethere there is any amending that can possibly make it right.
If you put out a design specification for a house and got a blueprint for a boat back - even if it was a PROPOSED blueprint for a boat - it would be reasonable to question if this person would be able to provide you with the house you desire. And if you spent 7 years working out the details in a country-wide consensus process and got a really good working blueprint of the house you wanted and gave it to that person and they still came back with the blueprint for a boat - and they had the power to make that the place you had to live for the rest of your life - I think it's reasonable to start thinking outside the process, to seriously question whether another round of comments, after 7 years of them, was really going to educate them on what a house looks like. And I think it's reasonable to oppose both the blueprints that would become law, as well as opposing allowing this entity any authority over where you live.
There is consensus in the organic industry that the flaws in these proposed standards go very deep, at the basis of its thinking and structure, and with the introduction of a wide range of new non-organic concepts that violate the gift and value of organic - incidental addititives, etc.
The value of organic is in its purity. It stands in contrast to the mainstream ag system which is based on Risk Assessment - allowing a little poisoning, because (on scant evidence that ignores basic notions of drift, synergism, cumulative effects, etc.) it believes that only "a few" will get hurt (logic and evidence to the contrary). I certainly think one should consider and try to work within existing systems. But many people have spent decades negotiating with this pesticide system and, while they've had successes - every one hard-earned with low funding - there are still lots of toxics in our food and our agriculture.
In contrast, organic agriculture got us right to the goal line. Instead of waiting for the agribusiness-greased wheels of our federal government to stand for a non-toxic food supply and ag, they went ahead and created it. Thinking outside the system. Going straight to the consumer.
Those who extoll the free market postulate that innovation and serving customer needs are the benefits that make it worth putting up with the downsides. This is an example of the success of that thesis. The market has demonstrated that the purity ideas in organic ag are valuable to a strong and growing set of the population.
>> But now these proposed organic rules have a thousand backdoors that allow toxics and synthetics into organic food. This isn't a little disagreement we're having. This is a proposal to create a definition of organic that would violate the core value of organic, and without cause take that option from the marketplace. This is a definition of a house that became a blueprint for a boat.
Now, I'm perfectly willing to see the people in the USDA as human beings, and I think it's important to do so. So I agree in the value of refraining from ungrounded villification and unproven assumption of motives.
However, I also think there are times for strong truthful statements, and this certainly counts as one of them. Sometimes one's desire to be "reasonable" can in fact disempower truth-telling. Sometimes working within the system can cause us to be disempowered pawns in someone else's game. Some cases do call for outrage and strong stands. And I strongly question how the USDA is ever going to be able to come up with real organic standards if they got so far off the mark this time. If they think they can edit those rules to get organic, I think they're sorely mistaken. That's why so many are calling for the rules to be withdrawn entirely, and to not buy the premise that if we just tell them where to edit it'll all come out ok. I also question whether the USDA is the right body to have responsibility for the national organic standard at all.
=== (2) As to other motives that might be at play, you write:
<<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 its played.>>
I like the quote. And I agree strongly that we should be very cautious about assuming other people's motives, and that it's not always necessary or useful in calling for effective action. Sometimes you can just state the goal and the action and get on from there.
However I also feel strongly that in trying to do effective action - especially in challenging circumstances such as these - it's vital to understand the true forces one is dealing with. Sometimes this is how we GET, not GIVE AWAY, power - by understanding what we're truly up against.
Organic has always been an affront to some people chemical agriculture, even for those organic folks who didn't mean it to be, just in its existence. I am not alone in witnessing those in chemical agriculture who've attacked organic agriculture just as a way of defending their own practices.
And there's also strong evidence of the influence that chemical agriculture has on government, both through campaign contributions and the "revolving door" (people who used to work for Monsanto now making decisions about Monsanto products - or people who hope to work for Monsanto next).
So I don't think it's a stretch that some people in chemical agriculture might have some interest in organic not succeeding any more than it already has - or at least not in the pure form that it has been.
The phrase "conspiracy theory" is generally used by people wanting to ridicule someone who sees concerted combined efforts. But as has been shown - like by Ben Bandikian (sp?) in _Media Monopoly_ - you don't have to have intentional collusion to have the same effect. Sometimes just an agreed upon definition of reality built into the rules of the game is all that's needed. That's how you get phrases like "the dominant paradigm".
But what if a certain paradigm has a great deal of funding and intentionality behind it - like the chemical ag/GE paradigm - and its focus is so clearly individual profit, no matter how much they cloak it in "feeding the hungry", etc. What do you call that level of control of democratic and economic systems? I wouldn't say conspiracy, but I would say some kind of power manipulation that leaves other key values - such as health, environment, and true public participation - out of the game.
I don't think that most people within the agribusiness/government complex think about it this way, as most people trained to think a certain way won't. I think a certain amount of the people within the system believe the Risk Assessment process (or are afraid to question it, because it would crumble their world and make their path a lot harder). And I think they believe a lot of the other premises and promises of agribusiness and corporations, ignoring the evidence that disputes those assertions.
And, if we want to create change, I think it's important to see that - they're often just reflecting their training, seeing as fact what is really just certain assumptions about how to work with natural systems and how to ensure both their survival and our shared survival on this planet. Many are just within a paradigm that is reinforced with lots of money and is quite different from the organic/biodynamic/permaculture aligned-with-the-earth paradigm that I find brings such delight and clarity to my life and my being.
But even if they're just embedded in a paradign they can't see outside of, that would be enough of a reason to question if they were able to be responsible for the starkly different paradigm that's been sought to be reflected in the definition of organic.
>> But there is another wrinkle that concerns me. I believe from what I see that the USDA feels they have to "harmonize" organics with the rest of their policies. Here it gets a lot harder for me to see them as innocents. Because the USDA has chosen to be a strong proponent of genetically-engineered (GE) foods - in direct conflict with their ascribed role as REGULATOR. How can you be proponent and regulator of something at the same time? If you want a real story, ask that question. Ag Sec Glickman is flying to Japan and waiving his GATT stick and the power of the U.S. - using our tax dollars - to keep other countries from even insisting on LABELLING of GE foods. Glickman has asserted that there are NO downside risks to GE technology, when that statement is EASILY disproven.
So the USDA has chosen to boldly step out of its role as regulator and be proponent of a highly-risky technology it's responsible for regulating. Every time it does this, it casts aspersions both on its ability to be regulator and on its ability to be party to other related decisions. Seeing this, I can't imagine how it would allow ANY organic regulation that flat-out rejected GE in the way that the organic industry has.
It's a simple logic equation. (1) The USDA has embraced GE and strongly rejected any attempts ANYWHERE to label it and give the consumer informed choice. (2) The organic industry has rejected GE as the unproven untested risky technology that it is. (3) Therefore, it's reasonable to hear USDA folks saying to themselves and others "how can we say that GE is safe, the same as the original, and then have organic regulations that make any type of differentiation??" It busts open their whole "it's the same and no risk" approach. I would be highly doubtful if the USDA claimed this was never included in their discussions on the organic rules. (4) In fact, if the USDA did allow the organic standards to reject all GE, THAT WOULD BE DE FACTO LABELLING OF NON-GE, the thing they're using all their guns to prevent. This would be a total failure in that goal. (5) This makes it hard for me to accept that they innocently omitted a ban of GE in the proposed organic rules, pending our comments - why weren't the comments and the consensus of the industry enough, since it was the industry's rules they were supposed to be putting into law! Or the NOSB's conclusions enough, since that was the process defined by OFPA? (6) Seeing this, I don't expect to get a clear non-GE rejection from ANY USDA rules unless they do some serious self-assessment regarding all their actions regarding GE, which I seriously doubt they're going to do without some serious outraged prodding by the US public and its legislators (which I'd be delighted to see, by the way!)
=== In summary, I do believe in sticking with facts. I believe in trying to work within the system, when its operating fairly, and not assessing motives recklessly.
But I also believe that one needs to not be overly idealistic about either people or process, and take seriously past behavior and power dynamics as vital factors in predicting the outcome of a situation and thus the appropriate response to it. It's important to make a distinction between proven fact and reasoned assessment, and be cautious about the latter. But if we only trust official process and demonstrated fact - when so many important facts are hidden for decades into the future - we may find that we've been the suckers who let the Visigoths, irretrievably, into the gates.
Hope you find these thoughts useful-
Best regards -
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