first, the national organic standards legislation mandates that usda develop
a national program of standards setting and certification . . . if one has
disagreements with those two objectives, then one's disagreements are with
the legislation as passed by congress and signed by the president, not with
the usda-ams implementation of the legislation
second, when the first draft of the proposed implementation was released for
review last year, one of the major criticisms was that the cost of
certification would be unduly burdensome for small organic farmers . . . it
seems to me that a cost-share arrangement addresses that criticism . . . if
one is going to be critical of the cost-sharing proposals, i think one has
to suggest ways in which they can be revised (or alternatives implemented)
which at the same time mitigate the undue cost burden
cheers,
craig
craig k harris
department of sociology
michigan state university
429b berkey hall
east lansing michigan 48824-1111
tel: 517-355-5048
fax: 517-432-2856
> ----------
> From: Bluestem Associates[SMTP:bluestem@webserf.net]
> Reply To: Bluestem Associates
> Sent: Saturday 30 October 1999 10:34 AM
> To: sanet-mg@ces.ncsu.edu
> Subject: Proposed organic cost share program
>
> On Sat, 30 Oct 1999 08:53:36 EDT, Erorganic@aol.com wrote:
>
> >Before signing on to letters to the Agricultural Marketing Service of
> USDA
> >supporting an organic cost share program for certification, it appears to
> me
> >members of the organic community should supply some thoughtful analysis
> of
> >its implications and possible effects on certified organic farmers and
> >handlers.
>
> >My concerns are gargantuan.
>
> Eric and I frequently disagree. Not this time.
>
> He who pays the piper, calls the tune. It would be entirely consistent
> with past bureaucratic motives if the purpose of this was simply to
> make certified farmers more dependent on bureaucrats, thereby
> securinging the bureaucrats' jobs in this little developing empire at
> the National Organic Program.
>
> >The Agricultural Marketing Service appears to
> >have proposed the organic certification cost share program.
>
> The cynical side of me sees this as a means of gaining more control
> over FVO and OCIA particularly, as these are both "high standards"
> programs, neither of which (to my knowledge) has ever taken a nickel of
> government money. We can't have such important programs so immune to
> our control, now, can we ...?
>
> In a private message to Anita Graf answering her question to me about
> how it is that Canada --- with its rather tight controls on election
> expenditures, PACs and such --- can still have so much of the same
> problems of favoritism, croneyism, special deals and so on, I said,
>
> ++Same shenanigans, same waste, same corruption as in the US. Most of
> the
> ++dirty work is done within the bureaucracy, as it is in the US.
>
> Bureaucrats are generally invisible, unavailable, and unaccountable.
> They can do a lot of good, and many are unsung heroes. More often they
> do an amazing amount of anonymous harm.
>
> >The money ultimately ends up going
> >first to certified farmers [snip] and then is passed
> >back to the Agricultural Marketing Service as fees for accreditation by
> them.
> > In fact the proposed organic cost share program is another way to use
> tax
> >money to support the Agricultural Marketing Service National Organic
> Program.
>
> In a time of tight budgets, bureaucrats are as nervous as a long-tailed
> cat in a room full of rocking chairs... the most effective way to
> raise taxes is through all sorts of hidden fees, especially if they
> come direct to your little domain.
>
>
> >In the Midwest at least we have large numbers of farmers coming to
> >certification agency meetings wanting to sell crops as "organically
> produced"
> >for the increased income earning potential. This is a trend that has
> >increased markedly every year for 4 years now. Almost none of these
> farmers
> >have become really familiar with the principals, practices or system of
> >organic farming. There main objective is increase farm income. Such a
> >proposed organic cost share program will only increase the number of
> farmer
> >applicants with very little increase in applicant knowledge of organic
> >farming.
>
> Very sadly, Eric, you understate the case. I see these guys all the
> time as an inspector. Just one example, from your state of Iowa...
>
> Conventional farmer with many hundreds of acres in heavy duty corn
> (anhydrous, etc). He had 130 acres (55 ha) that had been in the federal
> Conservation Reserve Program (at a tidy annual rent) for ten years. The
> whole thing was planted to food soybeans for 1999, which he wanted
> certified. The entire 130 acres was going to go *back* into CRP in
> 2000. In the course walking the field it became obvious to me that he
> had used herbicide(s) --- probably Pinnacle and Pursuit --- on the
> whole field. He didn't get certified, but I'll bet there are a lot more
> out there like him, and some of them *do* get certified.
>
> The real weak link in the whole system right now is INSPECTION. Many
> inspectors do not have practical production experience or knowledge.
> Relatively few have any understanding of *conventional* production ---
> its methods, its materials, and (above all) its *attitudes.* Increasing
> the number of applicants by encouraging them with subsidies is
> potentially disastrous for the little credibility remaining in the
> industry.
>
> The organic industry has largely done this to itself, with its slavish
> and anal-retentive preoccupation with *materials* rather than farm
> systems. It simply doesn't take as much understanding of agriculture to
> haggle over materials as it does to codify the irreducible minimum of a
> healthy system management.
>
> Because it's easier for programs (and bureaucrats) to haggle over
> materials, we have ironically undermined the entire inspection process.
> Inspecting for materials use is *NOT* easy. In fact, it is probably the
> most difficult aspect of the entire system to monitor. There are farms
> I *know* got sprayed within hours of when I headed down the lane for my
> next inspection.
>
> What really matters is how the whole system is put together and
> managed. That is difficult to codify, but once codified is relatively
> easy to inspect, even for inspectors of modest ability. There is
> absolutely no way, for example, that I could determine whether or not
> an applicant as used 25 kg/ha of Chilean nitrate, or 125 kg/ha, other
> than to trust his answer. That standard, therefore, is un-inspectable,
> un-verifiable, and thereby useless.
>
> What is *easy* to inspect is whether or not there is at least 25%
> legume sod in the rotation, and whether or not the applicant has a
> *written* management protocol for standard materials and procedures
> used in that particular operation. Less than 2% of the farms I
> inspected in 1999 had a written protocol for mineral fertility
> management, even though it is clearly required in the standards. If you
> think that doesn't matter, go back to the archives and review my
> comments about soil minerals and crop quality from about 3 weeks ago.
>
> The key questions are:
>
> a) Is this system designed and managed so as maximise system health
> and crop quality;
>
> b) Is it designed and managed to minimise the need for chemical
> inputs;
>
> c) Is this management protocol documented and followed, and
>
> d) Is there a chain of custody guaranteeing that the harvest has not
> been contaminated or co-mingled.
>
>
> Having de-emphasised these most important managerial elements (which
> are the *easiest* to inspect), and having over-emphasised materials
> (which are very difficult to inspect), the organic business has left
> itself extremely vulnerable. Federal cost sharing and the resultant
> influx of desperate conventional growers may well be all that is needed
> to tip an already-unstable system into the abyss.
>
> >There is a question whether large numbers of new "cost share" applicants
> for
> >organic farming certification will not stimulate oversupply of organic
> >product. Every since passage of the Organic Foods Production Act, staff
> of
> >the Agricultural Marketing Service have been trying to expand organic
> markets
> >for us, expand organic supply for us. That is not their mandate under
> OFPA.
> >Let the markets and supply expand without, absolutely without, Federal
> >government intervention. All such intervention twist the internally,
> >continually re-balancing organic supply and demand system in directions
> that
> >are simply un-natural, not "organic."
>
> This is an additional cause for concern, but if the inspectability
> problem isn't resolved, it may not matter. There are inspectors (and
> certification committee members) out here with enough concrete examples
> to seriously damage the demand side of "organic" equation in the course
> of a single interview on '60-minutes.'
>
> Bart
>
>
>
>
>
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