NOSB c/oKatherine Benham Room 4008-South Building 1400 and Independence Avenue, SW Washington, D.C. 20250-0001
Dear Katherine, There is much in the NOSB approach that is worrysome to a small, 7 acre researcher/producer such as myself. So far it looks like 2002 will be the last year we will be certified organic and thus allowed to use the term "organic" even though we have for 27 years pioneered in this field. Seems like we should have been grandfathered in as far as the use of the word organic goes instead of having our terminology taken away in what seems a power grab from our point of view. Nevertheless, I could not have voiced my position better than Jeff Herman of Washington TILTH. So I submit his thoughts for your consideration. Sincerely, Hugh M. S. Lovel, Director Union Agricultural Institute 8475 Dockery Road Blairsville, Georgia 30512 Comment Sent by Tilth Producers President Jeff Herman: To the National Organic Standards Board, My name is Jeff Herman and I represent Tilth Producers of Washington State. We are a 400-member organization of organic farmers, processors, handlers, and consumers. We have reviewed the draft Organic Farm Plan and Organic Farm Plan Update and would like to take this opportunity to comment on them. Our concerns regard the detail needed in Sec.2: Farm Plan Info, Sec.3: Seeds and seed treatment, and Sec.6: Crop management, A. Crop rotation plan. There are many direct market farmers in this state that farm by the foot row or by the square foot, not acres. They grow small amounts of many varieties of crops. They change varieties and crops to accommodate the market as it develops throughout the season, adapting to the changing market needs. We feel the draft plan is a one size fits all plan, and does not take into account small farms that do not have the resources to provide the documentation required. We believe the NOP should consider making a category for small direct marketers. They could then list their crops generally, submit their invoices from the purchases of their seeds, and submit a general farm plan or farm philosophy thereby meeting the requirements on the plan and update without the copious amounts of paperwork that is now required to enter amendments and treatments. There is a lot of worry among small organic farmers that the paper work is going to push them out of being certified. Certification is of less value to direct market farmers who promote their produce directly by word of mouth. Many of these farmers have been organic for fifteen, twenty years or more and are so because it is a philosophy of living, not of income. They have been integral to building the foundation of organic agriculture and we believe the NOP should work to keep small farmers in the certification process for the future. Their point of view and ideas are invaluable to the future organic agriculture in this country. We recognize and appreciate the hard work the NOSB has put into bringing us a fair national program. Nevertheless, there seems to be a tendency to make policy work for the concerns of large farms and industrial agriculture. Creating two farm plans would enable certifying agents to monitor larger farms and to allow small acreage/direct market farms to continue and still fulfill the requirements of the program. We urge the NOP and the NOSB to keep the interest of small farms a priority. Thank you, Jeff Herman, President Tilth Producers P.O.Box 85056 Seattle,Wa 98145-1056 >From or Forwarded by: Chrys Ostrander 33495 Mill Canyon Rd. Davenport, WA 99122 Phone: (509) 725-0610 Email: <mailto:[EMAIL PROTECTED]> URL: http://www.thefutureisorganic.net Visit our website at: www.unionag.org
