Talking Points for Comments (Due April 4, 2018)

I support The Cornucopia Institute’s comprehensive comments on the native ecosystem proposal and the comments on imports oversight and reform.

I am in favor of protecting native ecosystems.

I support the additions to §205.2 and §205.200(a) because they will help end the perverse incentive for organic producers to destroy valuable ecosystems. In particular:

  • The Organic Food Production Act of 1990 established that organic producers must conserve biodiversity and avoid any activities that would diminish it.
  • Sensitive ecosystems are being lost to agricultural development at an alarming rate.
  • The proposed regulatory change will de-incentivize conversion of native ecosystems into organic production—something that is urgently needed to stem this loss.
  • Consumers assume that when they are buying organic products they are more environmentally friendly and sustainable.
  • Farmers, human populations, wild animals, plants, and the environment in general benefit when native ecosystems are protected.
  • By eliminating the incentive to convert native ecosystems with a rule change, producers will be encouraged to transition land that needs the improvement: the 99% of U.S. agriculture that is still conventionally managed.

I am in favor of protecting domestic producers and consumers from fraudulent organic imports.

  • The regulations should require the certification of importers of agricultural products.
  • The regulations should require certification of brokers and traders who take ownership of an organic product, even if they do not take possession of the organic product—fraud can occur at any point during the chain of ownership/control.
  • The regulations should require testing for pesticide residues on shipments of imported organic commodities.
  • Farmers and consumers benefit when domestic markets are protected from fraud and organic integrity is protected.