Biden Administration Transition Letter

November 23, 2020

The Honorable Joseph R. Biden
President-Elect
威尔明顿,德

Dear President-Elect Biden,

乐动体育英超赞助品牌有机农民协会祝贺您最近的大选,我们期待与您的政府密切合作,对有机农民批评。

OFA是代表美国认证的有机农民的会员组织。我们的组织是由经过认证的有机农民控制的,只有国内认证的有机农民投票对OFA的政策和领导。

Organic is a growing sector of the U.S. agriculture system, with tremendous potential to address climate change, help family farms flourish, revive rural communities and protect public health. But for organic agriculture to meet its potential, we need the U.S. Department of Agriculture (USDA) to take several steps to protect the integrity of the USDA certified organic label.

The USDA sets the regulations and standards that must be met by products that bear the organic label. Certified organic farmers rely on this label to accurately convey information about their products in the marketplace. Because consumers believe in the integrity of the organic label, the organic sector has enjoyed tremendous growth and provided a path to economic viability for many family farms. But the USDA has considerable work to do to maintain the standing of the organic label with consumers and ensure a level playing field for organic farmers, including finishing long-delayed updates to regulations and increasing the agency’s focus on enforcement.

在短期内,经过多年不必要的延迟和对有机体界不利的特朗普管理决定,有几个关键措施需要在终点线上获得终结线。乐动体育app下载

Strengthening Organic Enforcement Rule:有机市场已经发展得迅速,即美国农业部的国家有机计划(NOP)在建立负责监督500亿美元的行业的执法能力后面落后于建立了全球供应链所需的行动。U.S有机粮食农民报告了对他们在几年前突然开始抵达美国的有机谷物的增加后,他们可以获得负面影响。从那以后,从具有可疑监督的地区进口,似乎缺乏足够的有机面积来生产出口的有机产品的数量持续,而几个高调的调查也揭示了美国的大规模计划,以出售欺诈有机产品。经过多年的宣传引起了注意the impacts of fraud on domestic markets, organic farmers need full and consistent enforcement of the USDA organic standards and increased capacity at the NOP to detect and prevent fraud in organic supply chains.

A critical step for the new Administration is to finalize and implement the “Strengthening Organic Enforcement” proposed rule as quickly as possible. This rule is required by the 2018 Farm Bill and the organic community weighed in during a公众评论期此秋季早些时候。As well as putting the rule into effect as soon as possible, the NOP must continue to coordinate with other USDA agencies as well as U.S. Customs and Border Protection (CBP) to increase awareness of organic commodities that are likely to be imported (and the potential for fraud) and to leverage other agencies’ inspection resources at ports of entry.

牲畜统治的起源:The NOP’s failure to strengthen the standards for organic livestock has allowed large-scale organic dairies to undermine those organic farms that comply with the intent of the organic label. Organic dairy farmers need a level playing field. Years of delay in closing loopholes in the organic standards for livestock have caused ongoing economic harm. We need the NOP to finalize an enforceable rule on Origin of Livestock as quickly as possible.

The agency has failed to address this problem for years. In 2015, the NOP published a proposed rule to clarify that, after completion of a one-time transition from a conventional dairy farm, all new dairy animals milked on an organic dairy farm would need to be managed organically from the last third of gestation. The 2015 proposed rule garnered strong public support from the entire organic community, but has never been finalized. In the FY 2020 appropriations bill, Congress gave the NOP 180 days to finalize the rule, but the agency missed this deadline.

NOP必须尽可能快地努力尽快完成这一重要规则,这些规则可以一致地执行,这要求整个一次过渡在一个有机认证机构监督下的十二个月内发生了一系列the producer’s Organic System Plan. Cycling dairy animals in and out of organic production must be prohibited, and once a distinct herd is transitioned to organic, all animals must be raised organically from the last third of gestation.

Organic Livestock and Poultry Practices Rule:The Organic Livestock and Poultry Practices (OLPP) rule is another long-overdue measure to strengthen the organic standards, which was delayed and ultimately withdrawn by the Trump Administration. The OLPP final rule would allow the NOP to consistently enforce stronger animal welfare standards on organic farms and close loopholes being taken advantage of by some large operations. The rule was discussed and vetted in the organic community for more than a decade and has widespread support. Animal welfare is an issue of critical importance to organic consumers, and these standards must be tightened to retain consumers’ confidence in the organic label. We urge you to reinstate the final OLPP rule as quickly as possible.

Organic Certification Cost-Share Program:所有认证的有机业务必须完成年度检查和认证。联邦政府在历史上偿还了有机农场和企业支付的高达75%的有机认证费用,最长偿还每次运行每次认证范围(农作物,牲畜或处理)750美元。今年夏天,美国农业部的农场服务机构(FSA)将2020年认证成本的报销率降至50%,最高可达500美元。这一行动留下了有机作业 - 曾计划在前几年与其认证成本进行报销,以至于以前的级别与无计划的费用负担,在一个更高的成本和受到大流行造成的市场中断的时间。成本股份计划对小型和中型有机农场尤为重要,以及刚刚开始有机认证的人。

2018年农场账单为有机认证成本股计划提供了新的资金,并通过USDA使用的书面承诺使用2018年Farm Bill环节余额来资助当前方案需求的资金来计算2018年农场账单中提供的资金。但原子能机构一直在努力跟踪计划支出,该方案领导原子能机构向国会提供不准确的报告,因为2018年农场法案所提供的资金正在考虑,并导致该剩余计划的缺陷农场账单周期的多年。

We urge you to act quickly to restore the funding levels for this program mandated by Congress. While a relatively small amount in the scope of the USDA’s budget, restoring the reimbursement level could make a big difference to many small organic operations. We also hope that the FSA will examine the administrative problems that led to this year’s shortfall and swiftly develop a plan to ensure this does not happen again.

Pandemic Response:Since the passage of the CARES Act, the USDA has been making direct payments to some farmers, through the Coronavirus Food Assistance Program (CFAP). The payment formulas used in CFAP 1 to calculate the payments and the rigid delineation of funding for specific commodity and livestock categories shortchanged organic farmers, particularly small-and-medium-scale diversified operations that have been economically impacted by the pandemic. There were some improvements made in CFAP 2 that made the program somewhat more feasible for some organic and diversified operations. But there are still many challenges faced by organic farmers because of the pandemic that the USDA’s response fails to address, which we outlined in a今年夏天早些时候发送给USDA的信。

我们还鼓励新政府调查大流行透露了关于食品系统各部门的流行病。与在高度综合的常规供应链中发生的中断鲜明对比,有机农民迅速调整为公共卫生限制,这些公共卫生限制影响了他们的产品和劳动力所面临的员工的境地和挑战,提出了允许他们喂养的创造性解决方案他们的社区。您可以阅读更多关于有机农民改编的更多信息这里这里。For some farmers serving local and direct-to-consumer markets, sales have actually gone up as a result of the pandemic as consumers seek out local sources of food. However, in many cases, costs have also skyrocketed for these operations because of the additional investments in equipment, technology, sanitation, staffing, and transportation that must be made in order to meet social distancing and infection prevention protocols. A more detailed examination of how the various sectors of the food system responded to the pandemic should inform future USDA pandemic response efforts.

In addition to these specific regulatory actions that the USDA should take in the immediate future, we have other suggestions that would help organic farming realize its full potential.

国家有机标准委员会:The Organic Foods Production Act that created the NOP also established a unique federal advisory committee, the National Organic Standards Board. This volunteer board plays a critical role in the function of the organic program, not just in evaluating materials allowed for use by organic operations and making recommendations on changes to the organic standards, but also in providing a venue for all of the stakeholders in the organic community to work together. We urge your Administration to treat the NOSB as a key part of the organic process by:

  • Committing to fill farmer seats on the board with people who have direct agricultural experience and deep expertise in organic practices, and actively working to increase the diversity of board members.
  • Allowing the NOSB to have more input in setting their workplan.
  • Committing to move NOSB recommendations quickly through the rulemaking process to become enforceable regulations.

Oversight and Accreditation:NOP发挥的关键角色之一是提供检查和认证有机业务的认可的认证机构的监督。但是,许多在有机界长期以来一直在争论的争议,归结为不一致的解释或通过认证机构施加有机规定。乐动体育app下载我们敦促NOP认真对待其作为认证人的作用,并承认这一角色与其执法授权无可可见。确保证书经过一致地解释和应用标准,他们运作的任何地方都对有机标签的完整性至关重要。NOP是唯一可以确保这种情况发生的实体。

Organic as a Climate Solution:有机耕作can play a critical role in fighting climate change。有机规则要求通过禁止合成肥料,除草剂和其他作物保护化学品来消除化学土壤干扰来实现有机农民。标准要求有机农民采用“维持或改善”土壤条件的耕作和培养实践。我们敦促新的政府确定研究研究,以记录有机实践如何最大化碳封存,以及记录有机实践所产生的多个益处。我们还敦促NOP通过收紧有机标准将有机甚至更加有意义地成为气候友好惯例来遵守持续改进的目标。这些包括:

  • 牧场的优先执行标准for large-scale dairies.
  • 恢复和实施牲畜操作的OLPP规则,要求牲畜操作以提供有意义的牧场获取。
  • Prohibiting the certification of hydroponic operations as organic. For organic agriculture. to maximize its potential as climate-friendly agriculture, soil must be recognized as the cornerstone of organic production.

Support for Organic Research:Many of the challenges facing the organic sector can be addressed with increased research. Organic research often addresses challenges or identifies practices that are also relevant to farmers who are not certified organic or who farm conventionally. An increased focus on soil health, alternatives to chemical pest management and cover crops across all sectors of agriculture show that this kind of research can serve an audience that is wider than certified organic. We urge you to increase USDA’s support of organic research. And we hope that your Administration will address the devastating impact of the decision to move the Economic Research Service and the National Institute of Food and Agriculture out of Washington, DC. The move led to dramatic staffing shortages and low morale, and took these critical staff out of conversations happening at USDA headquarters.

USDA和联邦合作伙伴的有机外展:It is clear that, despite the rapid growth of the organic industry and the National Organic Program, many other divisions within the USDA are still not familiar with organic. In order to encourage other USDA divisions to make their programs more feasible for organic producers, we urge you to reinstate the position of organic policy advisor that was created during the Obama Administration.

我们还敦促您将NOP的Oup Outach和教育扩展到其他联邦合作伙伴,例如白宫的各种政策划分,包括科学和技术政策办公室。另一个关键的联邦合作伙伴是海关和边境保护。我们希望您能探索如何为CBP创建有机顾问职位,这是一种预防欺诈性有机产品的联邦努力的重要努力。我们敦促NOP增加其他美国农业部部门的外展和教育,如APHIS,以及环境保护局的联邦机构有关基因工程作物和相关除草剂对来自遗传和化学漂移的有机部门的影响。

Personnel:当您努力填补USDA和其他联邦机构的公开职位时,我们敦促您选择致力于在美国正在发生的全方位农业的人,包括有机,多样化,直接市场和其他类型的生产。以下列表是一个示例,绝不是一个详尽的清单,将为您的团队带来这种必要的视角的人的类型:

David Zuckerman, Lieutenant Governor of Vermont, organic farmer

Amanda Bal,缅因州农业专员

科罗拉多州农业委员凯特格林伯格

Elanor Starmer,前管理员农业营销服务

Jesse Buie,Mississippi的有机农民,国家有机标准委员会成员

Andrew Bahrenburg, staff, Senator Leahy

Kelliann Blazek, former staff, Representative Pingree

Hannah Smith-Brubaker, former Deputy Agriculture Secretary of Pennsylvania, executive director of Pasa

Michael Sligh,Alliance为有机完整性

We appreciate the opportunity to provide input as you develop your priorities and look forward to working with your Administration. We hope to be able to set up a time for OFA leadership to meet with your transition team and new USDA staff to further discuss these ideas. If you have any questions or need more information, please contact our Policy Director, Patty Lovera,patty@www.cnxdi.com., (202) 526-2726.

Sincerely,

Kate Mendenhall
Director