Having spent four decades in organic vegetable, grain, seed and livestock production and a five-year term on the National Organic Standards Boards, I do not support holding a referendum on the proposed Organic Research and Promotion Program. I am also a certified organic handler for feed and poultry.
A Tax, Not a Check-Off
Commonly referred to as the Organic Check-off, this program is a tax on organic producers and handlers; it is not a “check-off.” A check-off program is voluntary, hence the need to “check off” the box to make a contribution. I oppose adding to the direct cost of organic production and handling.
Proposed Referendum Is Not Democratic
The proposed referendum discourages over three quarters of organic farmers from participating. Farmers grossing less than $250,000—estimated to be 76% of all organic farmers––are exempted from the assessment. They are ineligible to vote in the referendum unless they agree to a four-year assessment.
Proposed Referendum Process Is Contrary to the Spirit of the Constitution
The 24th amendment to the US Constitution prohibits poll taxes in Federal elections for Presidency and Congress because they are a form of disenfranchising voters and historically were used to rig elections. Requiring a four-year assessment to be eligible to vote in the referendum is a poll tax. I am opposed to this poll tax because it is being used to suppress farmer participation in the referendum.
Proposed Referendum Process Is Contrary to the Spirit of Federal Law
Ironically, Federal law requires a referendum to ensure that USDA research and promotion programs were democratic and did not imposed mandatory fees or programs without farmers’ consent. This proposal is clearly an attempt to circumvent that intent as it discourages over three-fourths of farmers from participating.
If this proposal goes forward, which I do not advocate, I support having all organic farmers participate in any referendum without an imposed assessment, poll tax, or other form of tax. I do not understand the rationale for discouraging farmers from participating. Furthermore, it is my belief that a majority of organic farmers would not approve this current proposal.
Non-Certified and Non-American Importers Can Vote
Importers can vote in the referendum. Importers are not required to be certified organic, and are not required to be incorporated in America. This is supposed to be a Research and Promotion program for American certified organic producers and handlers. Those groups should decide the fate of this proposal. I oppose giving a vote to or allowing board membership by non-certified or non-American entities.
No Demonstrated Need For The Program
There is no need for a program to support the growth of organics—its is already the fastest growing sector of the food industry, and has been for the past two decades—growing most years at double digit levels. I oppose creation of another government program for which there is no critical need.
Private Alternative Programs Already Exist
This proposal is not needed for organic research and promotion. Substantial voluntary private programs already exist to encourage research and promotion of organics, such as the Organic Farming Research Foundation, Farmers Advocating for Organic, and the Organic Center. While these groups stand to benefit financially from the check-off’s captive source of grant funds, they will have to conform to the goals of the Promotion Board, which will not benefit smaller organic farms. I oppose the creation of a government sponsored Organic Check-off program because the private sector has already dedicated resources to this area.
Government Alternative Programs Already Exist
Popular USDA organic research programs with a proven track record already exist, such as OREI and ORG—the Organic Research and Extension Initiative, and the Organic Transition research program. These programs have the support of and serve the needs of organic farms of all sizes. In addition, these programs are subject to a peer review process and Congressional oversight. I oppose the Organic Check-off because it creates another layer of government bureaucracy and a duplicative program.
Could Reduce Funding for Organic Research
Using a zero sum rationale in times of government austerity, check-off funds could put pressure against maintaining or increasing funding for OREI and ORG. These two programs make grants to operations in a manner that is size neutral, subject to a peer review process and public Congressional scrutiny. I support the OREI and ORG programs, and I oppose the Organic Check-off program because it could endanger the funding for these other more desirable and more accountable programs.
Creates More Paperwork––Even For Those Farmers Not Assessed
Certified organic farmers already are subject to more paperwork and record keeping than any other farmers. If this proposal is adopted, farmers with gross sales under $250,000 will still need to report their level of gross sales every year and also apply every year to be exempted from the assessment. I am opposed to creating more paperwork burden for organic farmers, especially for a program from which they are exempt.
Nothing in this proposal requires or encourages an “America First” policy. If this research and promotion program increases demand for organic products, the increased demand is most likely to be filled from abroad by imported supplies. This trend is already evident to America’s organic grain farmers who have seen imports take over 70% of the organic soybean market and 40% of the organic corn market. I oppose allowing imports to displace American organic products. I support an America First policy for organic agriculture.
American Farmers Are Paying A Tax to Benefit Foreign Farmers
If this proposal is implemented and it increases demand for imported products, as current trends suggest it would, then America’s organic farmers are paying a tax to benefit farmers abroad. I oppose an assessment that benefits foreign organic farmers, especially since they are not assessed the tax.
More American Jobs?
In the absence of any stated goal to increase the number of American organic farmers and farms, and in the absence of any prohibition or restriction on benefiting imported organic products, there is nothing in this proposal that would encourage the creation of more American jobs. I support the revitalization of our rural farming communities and creating more American organic jobs. I oppose this proposal because it does not have any emphasis on creating more jobs in the American organic industry.
Double Tax On Value Added Operations
Production farmers who are also value added processors should not be assessed twice. I am both a producer and a value added handler (processor) with direct sales to consumers. I oppose any assessment method that would double tax my operation, once as a producer and once again as a processor.
Penalizes Low Input And Grass Based Farmers
The definition of Net Organic Sales means that cost conscious farmers who grow their own feed and improve fertility with cover crops are being penalized compared with farms that purchase all their inputs. I am a grass based livestock farmer producing my own feed and fertility, and I will have to pay a higher assessment than livestock farms that purchase fertilizer, grain and hay. I oppose this definition of Net Organic Sales because it treats self-sustaining livestock farms at a financial disadvantage for no apparent public policy benefit.
Program Is Slanted Towards Largest Producers
A structural problem with this proposal is that the image of organic farming was formed in the consumer’s mind by smaller family sized organic farms motivated primarily to protect the environment and human health. These are exactly the producers who are being discouraged from participating and serving on the Board.
This proposal will turn control of that image over to larger, more corporate, industrial style farms mainly concerned with increasing their market share and profits with imported organic products.
Historically, family sized organic farmers have seen larger corporate organic operations consistently press to weaken the organic standards: to lessen the requirements for crop production (e.g. without soil), to allow undue confinement of livestock, and to amend the law to permit synthetic chemicals in organic processed food. As a family sized farmer, my customers and I support strong organic standards. I oppose this proposal because it would give USDA and larger corporate entities undue advantage to conduct government-sanctioned speech that could weaken the image of organic agriculture.
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