We serve a diverse audience of readers engaged
in regenerative, organic and sustainable agriculture
at many levels for many reasons. We want to hear
from you about the issues that are important to
your life and work, and your vision for agriculture
that builds a strong future.
We run selected comments from readers in this
space. Please tell us who you are, with name,
address and phone number for verification. Sending
correspondence to us conveys a right to us to
publish it as is, or in a form edited for length
and/or style. Opinions expressed in this space
do not necessarily represent the perspective of
The New Farm® or The Rodale Institute®.
If you have something important to say about
agriculture in a sustainable global food system,
please -- speak
I have some remarks on the March 31 article by Dan Sullivan,
v. Veneman: Spectre
of unintended consequences roils organic waters.”
For my part, nothing "unintended" has occurred.
Of course, industry leaders who assumed that USDA could do
no wrong (legally speaking) are overwhelmed by surprise and
wonder at the changes they face. Such is the result of complacency.
They could instead have exercised due diligence and hired
competent attorneys to predict the unanimous verdict of the
How did it happen that organic heavies--inside and outside
USDA--pretended all along that the law allowed synthetics
in processing? And how did it happen that USDA staff lied
to the courts about whether .606 was administered to provide
blanket approval for "any agricultural product"
in violation of the law? Fortunately, the appeals court understood
the duplicity and required a declaratory judgment that the
violations must stop.
Your discussion of the 80/20 dairy feed conversion system
omits one crucial element: Under that system, cows can--and
for the most part will--be fed GMO corn, soybeans and other
products until 90 days prior to "organic" production.
Consumers are not being told of this. This was not the case
when 80/20 was adopted 10 or 15 years ago.
I am asking the court to provide 24 months to phase in the
reformed standards, after which no further non-confoming products
may enter the stream of commerce. USDA has so far indicated
a preference for 12 to 18 months. It might be worth making
some effort to persuade USDA to adopt the longer phase-in,
which would reduce the impact on farmers and allow manufacturers
to find more natural substitutes for the synthetics now in
The basis of the law is strict control of synthetics in farming
and a complete ban on synthetics added to processed foods
(except for health and safety requirement of other laws).
Those who wish to ask Congress to amend the law to legalize
the present system will have to undermine or abolish this
basic principle. Once that happens, there will be no checks
at all on the free hand that USDA will have to water down
organic standards. This is the issue on which I brought my