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Re: comments on UDSA/NOP cost and benefits to organic farmers and handlers



At 10:06 AM 10/3/97 -0400, Erorganic@aol.com wrote:
>In a message dated 97-09-30 11:24:49 EDT, sals@rain.org writes:
>
><< Subj:	 
> Recent proposals by both the State and Federal governments are threatening
> to require that we spend more and more time filling out forms,paying
> fees,and handling the requirements of an ever growing bureaucracy
> established to regulate "Organic".  there is something wrong when those who
> are trying to straighten out agriculture are being taxed and burdened with
> inspections and paperwork while those who continue to pollute and deplete
> are subsidized and allowed to continue,
>
>eak: I cannot speak for California's CDFA, but the USDA National Organic
>Program can and will, if organic farmers and others actively participate in
>the public comment period on the Proposed Organic Rule, streamline all the
>forms and the time necessary to be certified organic.   All of California's
>existing statutes and the operative polices, standards and guidelines of all
>private and State certifiers will be null and void upon implementation of the
>USDA's National Organic Program.  To me that means Californians or others who
>have felt afflicted by past and added on state laws that apply to organic
>production and certification have a whole new lease to redesign those laws.
> The Organic Foods Production Act supersedes all private and State
>certification programs.  Under OFPA private certification organizations (as
>well as States) may apply for USDA accrediation.  That means that accredited
>organic certifiers will certify that a farm or handling operation applicant
>is utilizing a system of organic farming or handling as defined by OFPA, its
>Rules and Policies.  Under OFPA there is only  one standard for organic
>farming and handling in the US.   Only States (not private certifiers) can
>apply to the Secretary of Agriculture for approval of a state organic
>certification program which must not conflict with OFPA in any way, but may
>contain more restrictive requirements and standards than OFPA, must further
>the purposes of OFPA and only applies to organic farmers and handlers within
>the state.  It seems absurd that any state would want to place an undue
>burdan on its own farmers and handlers that farmers and handlers in other
>states do not have to follow to market in that particuliar state.   If a
>state does secure approval from the Secretary for a State Organic Program,
>all private accredited organic certifiers in the State have to conform to the
>State Program as well as the USDA/NOP program.  So, implementation of OFPA
>will open the door to re-evaluate all existing State organic programs, their
>standards and policies.
>
This is just sweet talk saying that the certifier,inspector,local
certifier,state and fed. gov. can tax organic farmers .  No organic farmer
I know of thinks this is to help the farmer it is to protect the comsumer.
So they have to sweeten it up and con farmers into thinking it is for them
because they need the organic farmer to pay for them to enforce it.  They
need someone to tax so they act like it is to help farmers but it is really
an attempt to suck money out of them.Bottom line-- it is a tax on organic
farming. And the poor organic farmers that cannot afford it must get out of
business .  These bully boys are going to suck money out of every organic
farmer in the US if he sells $5000 in a whole year of crops . Look at the
energy they are sucking out of the organic movement.  The state of Ca. has
suck hundred of thousands of dollars out of us already.  The USDA  are
going to suck money from hard working farmers (carry boxes,plant
fields,weeders,prunders,handlers,packers etc you get the idea ) and give
that money to pencils pushers that produce no product  and must get their
income from hard working people.  yes they will let you actively
participate in the public comment which is a big act .  I have been in
these public comments before and check it out.  They had a public comment
when they allowed cows to be injected with a lab made genetically
engendered growth hormone.  I heard the public comments and most were
against the part were the USDA would not label  their handy work. the
comments went on for days with people telling how it was bad for the poorer
farmers and bad for the cows etc. for days and day but the USDA did what
they wanted too and I was there when they had a public comment on BHT DNA
in plants and the public  told them about resistance and so forth but the
USDA did what they wanted to anyway .  this public comment time is a way to
pacify the people while they frame their mischief and call it law.  In the
public comment time the only thing the poor organic farmer will find out it
that truly they have made a political football out of their lively hood.
We were sold out 

> Many of those who supported the move to have the state and federal
> governments police our movement and those who sought approval from Uncle
> Sam have quickly realized that they made the proverbial deal with the
> devil. Unfortunately it is too late to stop the weels of bureaucracy, we
> will need to gather together (in the way that this movement was originally
> built) and ask ourselves some difficult questions.
> 
> The undersigned invite you to a meeting at 7:00 pm Monday October 6, in the
> Music Room of the Montessori school located at 401N. fairview ave.  (across
> the street from the Goleta Public Library and Fairview Gardens). Please
> park in the back parking lot, walk through the gate in the middle of the
> fence.  there is a map on the gate showing the location of the Music Room.
> 
> Please come join us to both educate ourselves on how the new legislation
> will effect us and to seek ways that we can help each other through the
> mire this will create.,
> 
> 
> ------Hey Hey whats that sound every one look whats going down!---------
> I grow organic and am certified by CCOF and also have to pay the state of 
> >>>Ca. to sell organic soon the feds will also tax us to sell organic and
> >>this is way too much regulation.
> <snip>
>
>eak: Regulation is not going to go away.  In fact, we organic farmers and
>handlers developed it.  CCOF, QAI, OCIA have attempted to be regulatory
>agencies without any teeth.  Under OFPA they will have teeth, and in turn
>will have to tow the line of meeting consistent and uniform national
>standards for how they carry on their certification activities.  Again, the
>questions that remains are does implementation of OFPA impinge on the ability
>of certified organic farmers and handlers to develop markets and maintain a
>decent income and way of life?  The answer is clear and simple.  The US is a
>democracy.  A democracy demands active participation, especially if some
>activity of the governing or regulatory process effects an individuals life
>and income.  The major opportunity for each of us to actively participate is
>coming shortly before or after Thanksgiving--the beginning of the public
>comment period on the Proposed Rule.  Informed public comment via email or
>writing is in order for the next 3 to 4 months after this date.  Three public
>meetings are planned to be held possibly in Richmond, VA or Pittsburg, PA,
>St. Louis, MO and Sacramento, CA or Eugene, OR.  where USDA will answer
>questions on the content of the Proposed Rule.  Further it has been suggested
>that a National Organic Standards Board meeting will be held where further
>public input may be made on the Proposed Rule.  Date and location unspecified
>as of now.  


it is true that we organic farmers created CCOF, QAI, OCIA  and organic
rules but we have been sold out to the  control freaks.  kiss all the work
we did good by.  CCOF,QAI and all the others will be taking their orders
from USDA and they also will have to pay and bow down because they are no
longer ours they belong to the USDA and the USDA has a different agenda
then organic growers. .   organic farmer is now a political football left
to the whims ,pack money,back door deals and wild hairs of the folks that
have nothing better to do than set around a room and vote .And believe me
they are good at this part of the game because that is  were they get their
moneys.  


   >eak: On cost to be certified organic under the USDA/NOP: actual cost of
>certification including inspection fees are up to the USDA accredited
>certifying agent.  However, OFPA does say that the USDA Organic Program will
>provide for the collection of reasonable fees from producers, certifying
>agents and handlers.  Under OFPA, every farmer or handler can shop around for
>whom they feel is most reasonable and that they find most satisfactory to be
>their certifier.  There will be a new fee, the fee for accreditation, that
>will be charged to certifying agents.  In fact, we know this will be passed
>on along to the farm or handling operation applicant by the certifier.
> Nonetheless, the additional fee should meet the criteria of resonableness.
> Numerous times over the last 5 years, the actual additional cost for the
>USDA/NOP as it is outlined in OFPA has been calculated.  The results are
>always the same.  $15 to $25 per year, per organic farmer will finance the
>program.  This does not even count handlers.  There is no reason the fee
>charged first to the certifier, then to the farmer and handler needs to
>exceed $20 for each farm.  The fees could be pro rated by acres or a general
>category of amount of sales that the farmer or handler pays on an honesty
>system.  The question is can I afford to pay say $20 a year for the benefits
>of a consistent, uniform standard of organic farming, handling and
>certification--for all organic imports into the US having to meet the
>equivalent standards US farmers and handlers have to meet--for the option of
>each certified organic farmer and handler being able to use a national seal
>identifying my product as meeting the USDA National Organic Program
>standards?  And there are a lot more benefits.  

Please name the benefits because I can sure name the costs .  I feel the
cost the benefits are in your mind. Please don't fool the people we know
it will cost a lot more that $ 20 a year that is just the what the USDA
expects to get from every organic grower in the whole US. every year for
the rest of time.  This is an added tax on top of what we are already
paying. This guy is sure good at sweet talking us and making us think it
will only be $20 but most of us know it will cost us lots lots more and a
organic grower should not have to pay 1 cent in extra tax because he grows
and sells organic.  They want to make a law let them pay for it.  you give
this guy $20 and that guy 75 for the state and this other guy 200 to the
inspector and 25 for the local chapter and 125 to the main chapter plus a
percent of your crop.  Tell it like it is :  It is an extra tax of those
that grow and sell organic that have done nothing wrong.  
>
> >Do you think organic certification should be eliminated completely? 
> 
> Obviously I can't speak for Sal, but he is one of the people who pays
> my salary in working for the organization that certifies him. Our
> members believe in certification, otherwise they wouldn't join. And
> most are painfully aware of the fraud of which you speak. Our members
> overwhelmingly supported the state and federal law under the
> assumption that fraud would be sharply reduced, benefitting both
> consumers and legitimate organic producers. 
> 
> However, at this point certification in California and most of the
> rest of the country is optional for those who label their product as
> organic. Registration fees did not go to enforcement the first year or
> two ('91-'92) and were instead commingled with the general fund in the
> state at the time of fiscal gridlock. This led to growing discontent
> among our members toward the law. While the funds were restored to the
> program, and things improved, many of our members are still
> disappointed with what they are getting for the hundreds of thousands
> of dollars they contribute to the California registration program on
> top of what we charge them to be certified. 
>
>
>eak: These are good points.  The problem rests in Sacramento, not the
>USDA/NOP.
No your right the USDA/NOP is a brand new tax  on those good folks that
work hard growing organic.  It is the USDA/NOP/mafia move on our money.  If
the USDA think organic farmers are not following the law let the USDA pay
for the enforcement that is their job mine is growing organic not paying
for organic gastopo.. I did not do anything wrong and I don't need a
expensive baby sitter that I  am being forced to take  and there is
something wrong when those who
 are trying to straighten out agriculture are being taxed and burdened with
 inspections and paperwork while those who continue to pollute and deplete
are subsidized and allowed to continue, I should be free to chose to grow
organic and free to sell my crop as organic if it is.  I should not have to
pay the Mafia bully boys to stay in bussiness.  

> Even when certification becomes mandatory for producers who sell more
> than $5,000 worth of product, people will still have the choice of
> whether to label their product as organic or not. However, the
> prospect of the Federal government collecting user fees from growers,
> and from certifiers who will have no choice but to pass those fees on
> to the growers,
> 
> The question then becomes who should bear the cost, and are organic
> farmers paying their fair share or more than their fair share for
> doing what they believe is the right thing. 
>
>eak: Some details of cost above.  Complete analysis of USDA/NOP cost is
>available.
Yea they all have the costs available.  yeah joe needed a new computer and
you farmers will have to pay for it.  yeah pet needed a new car you organic
growers will have to pay for it.yeah jim needs a motel room and you organic
farmers will have to pay for it.  yeah all these folks have to eat too so
you organic growers will have to pay for them after all they are not
producing anything and you are so you poor small farmers should  give it up
because you grow organic. here it is in black and white the cost and here
is the bill and guess what you are force to pay it.  
> <snip>
> >Who should pay for this? 
> 
> Here's an idea. How about a tax on pesticides? Unfair, you say?
> Robbing Peter to pay Paul? Not if you consider .... and hold on to
> your chair 'cause i'll say it only once .... that organic farmers use
> pesticides. That's right. Only a small handful of the vast array of
> pesticides that are out there, and really never as the only means of
> crop protection. Most of them are relatively innocuous,  like soap,
> Bt, garlic. Yet in California, the mil tax on a pound of any of those
> products is the same as the tax on, say, aldicarb, methyl bromide or
> parathion. 
> 
> Even in simplistic terms, why should farmers pay the same tax on
> Category III pesticide (the least acutely toxic) as they do on those
> in Category I (the most toxic)? If a given pesticide causes relatively
> few injuries, is not persistant on food or in the environment, and
> causes relatively little collateral damage, pound for pound, where is
> the justice in taxing that the same as a product that contaminates
> groundwater, depletes ozone or inhibits cholinesterase in nearby
> schoolchildren? 
> 
> Our members wanted to see the mil tax applied to funding the
> enforcement of the organic act, but the legislature received enormous
> pressure from the agrichemical complex to lower the mil tax during the
> last legislative session.  We were one of the few voices among
> agricultural producers who favored maintaining the mil tax and fought
> the efforts to cut it about 25%. 
>
>eak: Sounds like a 10 year project.  I support it, others might.  USDA/NOP is
>now at hand.


Yes you are right this will be a whole new tax on organic growers. the
USDA/NOP is in a room right now making up the tax they are going to charge
me because I am organic.  The big move by the control freaks is now at
hand.  Get ready to bow down and kiss up.yes boss yeah boss should I just a
little higher.  oh thank you boss.

> >But do you think consumers would want to pay the same
> >price for your goods if they weren't certified organic? 
> >After all, isn't that what being
> >organic is really all about? People who truly care about the environment
>are
> >willing to make sacrifices. That's why many consumers of organic products
>are
> >willing to pay a higher price for those goods.
> 
> When people buy food produced by methods that pollute water and air,
> poison farmworkers, kill wildlife and leave higher residual levels of
> carcinogenic pesticides, they are getting more than what they pay for.
> They have this choice, and choose overwhelmingly to buy non-organic
> instead of organic food. Yet most consumers, when surveyed, don't want
> to cause this kind of destruction. 
> 
> To use economic jargon, organic farmers internalize many if not most
> of these internal costs. That makes their costs of production higher
> and therefore requires that they receive a higher price in order to
> remain economically viable. Organic food is not perfect, but IMHO it
> is our best alternative. It is not that organic food is too expensive,
> it is that conventional food doesn't reflect the full cost of
> production. 
>
>eak: Absolutely correct in the last sentence.

oh gee thanks eak .  
there is something wrong when those who
 are trying to straighten out agriculture are being taxed and burdened with
inspections and paperwork while those who continue to pollute and deplete
 are subsidized and allowed to continue, 
Not one cent extra that is reasonable to me.
> Production methods for all farmers will improve if we stop penalizing
> those who protect the environment and make the polluter pay.
> 
> 
> Sal said ---I don't think organic growers should have to pay one extra cent
> to grow and sell their organic food as organic.  
>
>eak: One point.  Under OFPA, no accredited certifier can charge a percent of
>gross sales to be USDA/NOP certified.  A private certifier can charge you a
>percent of gross sales to be a member of their private organization and use
>their private seal.  Under OFPA for a State to charge a USDA certified
>organic farmer or handler a fee, the Secretary of Agriculture will have to
>approve such. 
 
They force us to pay a certifier and then leave us to the mercy of those
certifiers .  The certifier don't have enough inspector now. inspectors are
few and far between and guess what the organic farmer get to pay the gas
,motel room,massgae girl  etc. all the cost no mater how far these
inspector have to travel.  the full cost will be on the backs of the
organic farmer and he is FORCED to Pay.  Those poor farmers that live in
out of the way places I feel sorry for you.  

 Poor farmers that cannot afford all this will be forced out of bussiness.
$5000 is too small  

 .  This is the small farms listserver does that mean that it is for folks
that sell under $5000.  What is a small farm?  is $5000 and under
considered a small farm.  I don't think so.  What is the average per annual
sells of farms in the US so I can get an idea of what is small.  
> 
> ----------------------- >>
>
>
>

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