Cornucopia President’s Message for the NOSB: Don’t Rubberstamp the USDA/Corporate Takeover

April 20th, 2016

Yesterday, the National Organic Standards Board held a webinar to gather public comments in advance of their three-day Spring meeting that begins on April 25.  Cornucopia’s board president, Helen Kees, presented testimony during the webinar.  That testimony appears below.  Below Helen’s testimony you will find a link to a summary of other comments made by individuals during the webinar.


Helen Kees, Board President

Helen Kees, Board President

Good afternoon.

My name is Helen Kees, and I am president of The Cornucopia Institute. I am speaking to you from our diversified family farm in west central Wisconsin.

Our farm is named Wheatfield Hill Organics in honor of the crop my grandfather grew on a “bluff” field that was heavy enough to raise wheat. I stand on the shoulders of my fore parents with an awesome responsibility. I was formed in my mother’s womb from this very soil and am now entrusted with keeping it sacred enough to raise food fit to nourish other life.

My grandchildren are the fifth generation to live and work on our farm. We are farmers. We have chosen to be certified organic farmers for the past 20 years. We have no full-time employees. Family members constitute the labor for our farm outside of some seasonal help.

Our “home farm” consists of 320 acres with 100 acres tillable and 100 acres of pasture.  We have also leased another 345 acres.

Year round, we husband a 40 to 50 cow–calf, rotationally grazed beef herd, operate a farmstead processing kitchen where much of our blueberry and raspberry crops are processed, and sell dairy quality alfalfa forage to other certified organic producers.

In addition to our beef herd we grow two acres of asparagus, 20-25 acres of corn and melons.

One of your newly seated board members, Harriet Behar, has visited our farm as an organic inspector. Harriet is highly respected by our family and the extended organic community. I am thrilled that a sister Wisconsinite is sitting on the NOSB.

Cornucopia board member Dr. Barry Flamm was originally scheduled to speak in this slot. However, due to a critical medical appointment, Dr. Flamm is not able to interface with you today. Barry felt an obligation to address you because of his deep concern over your loss of authority due to the USDA unilaterally changing your policies and procedures.

Not only as the past chair of your policy committee, but also as the chairman of the NOSB, Barry is uniquely qualified to make this judgment. He was intimately involved with the authorship of the Policy and Procedure Manual. To say that Dr. Flamm is alarmed at the possibility that you may actually vote to codify this hijacking of your authority into your PPM is an understatement.

To draw a parallel, can you imagine your outrage if the executive branch of our federal government, possibly by executive order, rewrote The Constitution of The United States of America without any input or scrutiny from the legislative branch? Do you think the states would ratify such a change? Of course not!

The United States Constitution, itself, contains the “instructions” to guide any change or adaptation to the document. Likewise, in the past, when your PPM needed to be updated the process laid out in the manual itself guided and directed the process of the update.

Your PPM, originally released in 2002, was developed by you, for you, of you, in a transparent process with input from the organic community, BEFORE any “ratification” by the USDA. Likewise, your 2012 update was conducted in the same manner.

Personally, and I believe Dr. Flamm would agree, the USDA policy and procedure changes of 2015 is one of the largest cases of identity theft I have seen. Just because someone has stolen your identity does not mean that you should not fight to get it back.

And for farmer’s sake, surely not vote to condone it.

Please keep in mind that in 1990, through OFPA, Congress gave YOU the leadership role, NOT the USDA or any other body.

If you review page 2 of the Cornucopia Institute’s submitted comments regarding the rewrite of the PPM you will see that federal legislation mandates that federal bureaucrats NOT interfere with the decision-making by an independent advisory committee.

Please, do not allow this to happen. Your marching orders and authority were given to you by Congress and that has not changed.

Read a summary of the April 19 webinar comments for the spring 2016 NOSB meeting.

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