Amber Lippon

November 2024 Policy Update

By Lily Hawkins, Policy Director

Republicans Win White House, Senate

Republicans fared well in the November 5 election with former President Donald Trump winning another term in the White House and a new majority in the Senate. (At the time of writing, control of the House was still undecided.)

With Republican control of the Senate, Senator Boozman (R-AR) is expected to take leadership of the Senate Agriculture Committee. Other committee changes are assured, with Senate Ag Committee member Sherrod Brown (D-OH), and House Ag Committee member Marc Molinaro (R-NY) failing to win reelection, and several House races still undecided.

OFA will be tracking further election results and watching for news of possible cabinet nominees in the coming weeks. 

With the election behind them, members of congress will have time to return to work on the currently expired Farm Bill. While most Farm Bill programs will continue to operate until the end of the year, there is a growing urgency to pass a new Farm Bill or another extension as soon as possible. 

Organic Cost-Share Must Be Protected

The organic certification cost-share program (OCCSP), a vital resource for organic farmers, relies on the Farm Bill for authorization every five years. Because OCCSP is a very small program, cost-share does not have “permanent baseline” funding status. When the 2018 Farm Bill was extended last November, the extension was crafted in a way that preserved funding for cost-share and other so-called “orphan” programs, programs without mandatory baseline funding. If the current Farm Bill is again extended, provisions must be included so that cost share funding is maintained.

Click here to take action today and urge your Senators and Representatives to fight for organic certification cost-share.

Urge Your U.S. Senators to Support the WEATHER Act

This season has brought unprecedented extreme weather events. Current federal crop insurance options do not cover many small, diversified, and organic farms impacted by disasters such as Hurricanes Helene and Milton.

The Withstanding Extreme Agricultural Threats by Harvesting Economic Resilience (WEATHER) Act of 2023 (S. 3401) is a bill that calls for the development of an index-based insurance policy that would better support farmers facing income losses after extreme weather events by reducing administrative hurdles and ensuring that insurance payouts are based on agricultural income losses. The policy would likely function similarly to the Pasture, Rangeland, and Forage Insurance program which provides financial payments to farmers quickly after a disaster.

Send a message to your Senators asking them to include the WEATHER Act in the upcoming Farm Bill!

USDA Provides Funding to Assist Organic Dairy Producers

The USDA recently announced two programs to support organic dairy producers. The USDA announced the availability of $58 million in funding for organic dairy producers through the Organic Dairy Marketing Assistance Program (ODMAP) on September 26. This program aims to help producers offset marketing costs incurred in 2024.

The ODMAP program was first launched in 2023 with $104 million allocated, but less than half of those funds were distributed in the first round of disbursements. This was partially due to a lack of data collection about organic dairy marketing by USDA.  

Improvements to the program for 2024 include an increased the payment rate to $1.68 per hundredweight (from $1.10) and raised the eligible production level to nine million pounds (from five million). These improvements address the needs of organic dairy producers and provide much-needed relief.

Producers can apply for ODMAP until November 29 at their local USDA Service Center. To be eligible, applicants must provide documentation of 2023 production, proof of organic certification, and complete an application form.

On October 28, the USDA announced a new program, the Organic Dairy Product Promotion (ODPP), allocating $15 million to expand access to organic dairy products in educational institutions and youth programs. Funded by the Commodity Credit Corporation (CCC), the program will help children and young adults access organic dairy products while also creating new markets for small and mid-sized organic dairy farmers. The program will be administered nationally through the four regional Dairy Business Innovation Initiative (DBI) regions. These regional centers may subaward these funds directly to organic dairy businesses, educational institutions including K-12 schools and colleges/universities, and other organizations able to implement the program.

OFA will continue to work for policies that support organic dairy producers in the upcoming Farm Bill.

by Amber Lippon

October 2024 Policy Update

By Lily Hawkins, Policy Director

Congress Passes Short-Term Funding Patch But Lets Farm Bill Extension Expire

Lawmakers returned to Washington, D.C. after their August recess with expiration dates looming for both the Farm Bill and annual spending bills.

Late last month, Congressional leaders were able to reach a bipartisan deal to keep the Government running on 2024 levels through December 20, with a short-term funding patch called a continuing resolution (CR). There had been some speculation that they would extend the Farm Bill as part of that CR, but they did not include that in the measure.

Since most Farm Bill programs will not expire until the end of the calendar year, there is still time to pass a new Farm Bill after the election this fall. However, there is reportedly some interest among Farm Bill negotiators in passing some sort of emergency assistance package along with a Farm Bill extension if compromise can’t be reached on a new bill.

Any Farm Bill Extension Must Protect Organic Certification Cost Share Program

The organic certification cost-share program is authorized every 5 years through the Farm Bill. 

After reductions in 2020, USDA’s Farm Service Agency (FSA) announced in 2023 that they would restore reimbursement rates for the Organic Certification Cost Share Program (OCCSP) to 75% of the certified organic operation’s eligible expenses, up to a maximum of $750 per scope. This brought the amount of funding back up to the maximum allowed by the 2018 Farm Bill.

Because OCCSP is a very small program, cost-share does not have “permanent baseline” funding status. When the 2018 Farm Bill was extended last November, the extension was crafted in a way that preserved funding for cost-share and other so-called “orphan” programs, programs without mandatory baseline funding. If the current Farm Bill is again extended, provisions must be included so that cost share funding is maintained. OFA has been told that funding for 2024 is secure. However provisions in any extension are needed so that organic farmers who use the program can plan ahead for their 2025 certification costs.

Take action: Please visit usa.gov to find contact information for your members of Congress and urge them to renew funding for the organic certification cost share program in any Farm Bill extension and modernize cost-share by supporting the Opportunities in Organic Act in the next Farm Bill. 

USDA Announces Funding to Assist Organic Dairy Producers

On Thursday, September 26, USDA announced the availability of $58 million through the Organic Dairy Marketing Assistance Program (ODMAP), which will provide certified organic dairy producers with funding to help cover projected marketing costs for 2024. 

The ODMAP program was first launched in 2023 with $104 million allocated. With less than half of those funds distributed in the first round of disbursements, OFA and allies are pleased to see this effort to get much needed relief to organic dairy producers. 

Improvements to the program for 2024 include an increase in the payment rate to $1.68 per hundredweight from the previous $1.10 per cwt. The production level eligible for marketing cost-share assistance has also increased from 5 million pounds to 9 million pounds. 

OFA will continue to work for policies that support organic dairy producers in the upcoming Farm Bill.

Producers can apply for the program from September 30 to November 29 by contacting their local USDA Service Center. To apply you will need to provide documentation showing 2023 production, proof of organic certification, and complete an application form.

Watch the National Organic Standards Board’s Fall Meeting

The NOSB meets twice a year to work on recommendations to the USDA about organic standards and the National List of materials that are allowed or prohibited in organic production. 

This fall, the NOSB will convene an online Public Comment Webinar in mid-October followed by an in-person meeting in Portland, Oregon the following week.

• Public Comment Webinar Day 1: Tuesday, October 15 from Noon - 5:00 pm Eastern
• Public Comment Webinar Day 2: Thursday, October 17 from Noon - 5:00 pm Eastern

• In- Person Meeting Day 1: Tuesday, October 22 from 8:30 am - 6:00 pm Pacific
• In- Person Meeting Day 2: Wednesday, October 23 from 8:30 am - 6:00 pm Pacific
• In- Person Meeting Day 3: Thursday, October 24 from 8:30 am - 6:00 pm Pacific

For more details on the meeting, including the agenda and materials, visit the USDA webpage here, and read OFA’s written comments here.

by Amber Lippon

September 2024 Policy Update

By Lily Hawkins, Policy Director

Appropriations Continuing Resolution and Farm Bill Extension Likely

Lawmakers are returning to Washington, D.C. after their August recess with expiration dates looming for both the Farm Bill and annual spending bills.

With progress well behind schedule on both efforts, it is nearly impossible that they will complete either process before the end of the federal fiscal year on September 30. If they do not pass a FY2025 budget by that date, Congress will likely pass a Continuing Resolution (CR) to extend the current federal spending levels to avoid an October government shutdown. The programs funded by the Farm Bill are separate from the annual appropriations bills, and expire more gradually. However, lawmakers could choose to include a Farm Bill extension as part of a CR.

Any Farm Bill Extension Must Protect Organic Certification Cost Share Program

The organic certification cost-share program is authorized every 5 years through the Farm Bill. 

After reductions in 2020, USDA’s Farm Service Agency (FSA) announced in 2023 that they would restore reimbursement rates for the Organic Certification Cost Share Program (OCCSP) to 75% of the certified organic operation’s eligible expenses, up to a maximum of $750 per scope. This brought the amount of funding back up to the maximum allowed by the 2018 Farm Bill.

Because OCCSP is a very small program, cost-share does not have “permanent baseline” funding status. When the 2018 Farm Bill was extended last November, the extension was crafted in a way that preserved funding for cost-share and other so-called ‘orphan’ programs, programs without mandatory baseline funding. If the current Farm Bill is again extended, provisions must be included so that cost share funding is maintained. OFA has been told that funding for 2024 is secure. However provisions in any extension are needed so that organic farmers who use the program can plan ahead for their 2025 certification costs.

Take action: Please visit usa.gov to find contact information for your members of Congress and urge them to renew funding for the organic certification cost share program in any Farm Bill extension and modernize cost-share by supporting the Opportunities in Organic Act in the next Farm Bill.

Participate in the National Organic Standards Board’s Fall Meeting

The NOSB meets twice a year to work on recommendations to the USDA about organic standards and the National List of materials that are allowed or prohibited in organic production. 

This fall, the NOSB will convene an online Public Comment Webinar in mid-October followed by an in-person meeting in Portland, Oregon the next week.

• Public Comment Webinar Day 1: Tuesday, October 15 from 12pm - 5pm ET
• Public Comment Webinar Day 2: Thursday, October 17 from 12pm - 5pm ET
  

• In- Person Meeting Day 1: Tuesday, October 22 from 8:30am - 6pm PT
• In- Person Meeting Day 2: Wednesday, October 23 from 8:30am - 6pm PT
• In- Person Meeting Day 3: Thursday, October 24 from 8:30am - 6pm PT

For more details on the meeting, including the agenda and materials, and to register for virtual testimony visit the USDA webpage here.  

OFA will be focusing our comments on the materials Meloxicam and Methionine, plastics in compost, and residue testing for organic imports.

If you would like to register to provide oral testimony or need help with written comments please call our Farmer Helpline at (833) 724-3834, or contact OFA Farmer Services Director Julia Barton at julia@organicfarmersassociation.org.

by Amber Lippon

August 2024 Policy Update

By Lily Hawkins, Policy Director

Farm Bill Progress Stalls

This spring we at last saw encouraging progress towards a new Farm Bill with either proposals or full bill text released in both the House and Senate Ag committees. However, as we enter August progress has slowed, even as the September 30 deadline approaches. The House Agriculture Farm Bill must still pass on the House Floor—this was always going to be difficult due to the inclusion of several policies Democrats view as red-lines. Recently the Congressional Budget Office stated that the House Agriculture Committee’s Farm Bill would raise the federal budget deficit by $33 billion over the next decade, making a way forward even more challenging.

Meanwhile in the Senate, the Republican response to the Majority Senate Farm Bill Framework closely resembled the House Bill, and the Senate Agriculture Committee will need to work to pass a consolidated Senate version. Once both chambers have passed their own version of the bill, leaders from the House and Senate will work to combine the two bills into one bill, which can then be voted on by the full Congress.

It is increasingly unlikely that this process will be completed before the deadline at the end of September. It’s possible that a bill could be passed this fall, but the closer we creep to the 2024 election process the greater the likelihood that the Farm Bill will be extended again until 2025.  There are lots of unknowns, and the future path of the bill rides on election outcomes and how a possible extension might be drafted.

Meanwhile, new marker bills continue to be introduced with the hope that the policies in them will be included in the final Farm Bill. You can read more about them in our Farm Bill Marker Bill Tracker.

Appropriations Progress at a Stand-Still

OFA has been tracking work on annual government spending bills in Washington. In June, the House Appropriations Agriculture-FDA Subcommittee approved a draft version of its fiscal 2025 Agriculture-FDA spending bill on a party-line vote. The bill would provide $25.9 billion in funding across USDA and FDA, with approximately $22 billion going to USDA, representing a more than 1% cut from current funding levels. The Senate Appropriations Committee has also passed a bill, however House lawmakers left early for their August Recess without bringing the bill to the floor for a vote as originally planned.

This leaves only three weeks in September for legislators to push through final spending bills before the start of the 2025 fiscal year on October 1, making it very likely that the legislation will have to be extended until after the election and dealt with by the next Congress. 

Opportunity to Submit Content Request for the 2027 Census of Agriculture

The National Agricultural Statistics Service (NASS) is currently accepting stakeholder feedback in the form of content requests for the 2027 Census of Agriculture. The deadline for comments is August 19, 2024. For more information and to comment visit the Federal Register here.

OFA will be drafting comments in the coming weeks. If you have a new question that you would like to see added to the 2027 Census of Agriculture, contact OFA Policy Director Lily Hawkins at lily@organicfarmersassociation.org.

by Amber Lippon

July 2024 Policy Update

By Lily Hawkins, Policy Director

New and Upcoming Marker Bills

The past few months have shown encouraging progress towards a new Farm Bill with either proposals or full bill text released in both the House and Senate Ag committees. However, there is still a long way to go to pass a final bill by the September 30 deadline. The House Agriculture Farm Bill must still pass on the House  Floor—sure to be  difficult due to the inclusion of Democrat’s red line components. With the Senate Republican response to the Majority Senate Farm Bill Framework closely resembling the House bill, the Senate Agriculture Committee will have to pass a consolidated Senate version. Once both chambers have passed their own version of the bill, leaders from the House and Senate will work to combine the two bills into one bill, which can then be voted on by the full Congress.

It is possible that this process will be completed before the deadline at the end of September. However, the closer we creep to the 2024 election process the greater the likelihood that the Farm Bill may be extended again until 2025.  There are lots of unknowns, and the future path of the bill rides on election outcomes and how a possible extension might be drafted.

Meanwhile, new marker bills continue to be introduced with the hope that the policies in them will be included in the final Farm Bill. 

OFA is supporting several of these:

The Organic Imports Verification Act (not yet introduced) would promote organic integrity and a level playing field for domestic organic producers by requiring USDA to test high-risk bulk imports of organic feedstuffs for residues of substances that are prohibited in organic production.

The Save our Small Farms Act includes improvements to the Non-Insured Disaster Assistance Program (NAP), as well as the full text of the Whole Farm Revenue Program Protection Act and the Withstanding Extreme Agricultural Threats by Harvesting Economic Resilience Act.

The Capital for Beginning Farmers and Ranchers Act directs the Farm Service Agency (FSA) to develop a multi-year operating loan pilot for beginning farmers to finance initial assets and the development of production and management systems. These expenditures can include intangible business infrastructure for crop records, payroll, and regulatory compliance, investments to increase soil fertility, and more.

To read more about these and the other marker bills OFA supports, check out our Farm Bill Marker Bill Tracker. 

House Subcommittee Approves Draft Ag/FDA Spending Bill

In June, the House Appropriations Agriculture-FDA Subcommittee approved a draft version of its fiscal 2025 Agriculture-FDA spending bill on a party-line vote.

The bill would provide $25.9 billion in funding across USDA and FDA, with approximately $22 billion going to USDA, representing a more than 1 percent cut from current funding levels.

Report language for the bill, which will detail how specific programs will be funded, has yet to be released.  We do know that House Republican leaders are not pursuing the abortion pill rider that would restrict access to abortion pills in the Ag-FDA spending bill. This represents a major concession to swing-district Republicans facing competitive elections this fall, and could make it easier for Republicans to pass the bill on the floor this summer.

by Amber Lippon

June 2024 Policy Update

by Amber Lippon

May 2024 Policy Update

By Lily Hawkins, Policy Director

Farm Bill Framework

On May 1st, Senate Agriculture Committee Chair Debbie Stabenow released a Farm Bill proposal, titled the Rural Prosperity and Food Security Act, which includes policies that can help move more U.S. agriculture to organic methods and make a positive impact for organic producers, providing authorization of funding that will allow the National Organic Program (NOP) to keep pace with the growth in the organic sector and will advance OFA’s Farm Bill priorities in numerous ways including:

• Directs the National Organic Program to solicit public input on the prioritization of organic regulations to be promulgated or revised
• Directs the Secretary to publish an annual report regarding recommendations received from the National Organic Standards Board, all regulatory and administrative actions taken, and justifications on why actions were or were not taken on those recommendations
• Directs the Government Accountability Office to conduct a study on the efforts of the NOP to improve organic standards and provide recommendations on how the NOP can ensure that organic program standards evolve in a timely manner to meet consumer expectations and benefit organic producers
• Directs the Department of Agriculture to improve collection of organic dairy market data

• Clarifies the calculation of Conservation Stewardship Program payments for income forgone by a producer transitioning to an organic resource-conserving system
• Continues funding for the Organic Agriculture Research and Extension Initiative  

• Provides enhanced coordination of organic agriculture research within USDA
• Provides mandatory funding for organic production and market data initiatives

• Provides stable funding for the Certification Cost-Share Program and increases the maximum payment to a producer or handler to $1,000
• Directs research and development on ways to increase participation of organic producers in Federal crop insurance
• Authorizes an Organic Market Development Grant program 
• Increases the EQIP payment cap for organic producers, making the organic cap equal to the conventional payment cap

The House Agriculture Committee is expected to unveil their Farm Bill proposal soon after Chair G.T. Thompson holds a markup later this month. Once each Agriculture Committee has passed its own version of the bill, leaders from the House and Senate will work to combine the two bills, which will then be voted on by the full chambers.

OFA will continue to advocate for the inclusion of the important policies from the Senate proposal and key marker bills in the final Farm Bill.

In-District Meeting with Representative Max Miller in Partnership with OEFFA 

On Earth Day OFA and Ohio Ecological Food and Farm Association welcomed Congressman Max Miller for in-district farm visits at Woodlyn Acres Farm, LLC and County Line Family Farm to discuss organic agriculture, the Farm Bill, and leveling the playing field for organic.

Read more about it here!

Spring NOSB Recap

The National Organic Standards Board met the last week of April in Milwaukee Wisconsin.  The spring meeting reviews various National List materials on a five year cycle.  The NOSB discussion and public comments seek to verify that each material is still essential, there are no contamination issues, and there are no natural alternatives found since the last discussion.  At the fall NOSB meeting, they vote to retain or remove the discussed materials.  

At this meeting, the National Organic Program gave an extensive report on the implementation of the Strengthening Organic Enforcement rule, with a focus on tracking imports (22,000 NOP import certificates issued since mid-March!) under the enhanced scrutiny of this rule.  Numerous loads were denied entry into the U.S. organic market due to not having the required documentation.  

Modification of the compost definition was discussed, based on a petition to allow “compostable plastics” to be included as a compost feedstock.  OFA spoke against this change, due to the contamination risks associated with these plastics. The NOSB will continue this conversation in the fall. 

Proposals for improvement to organic crop insurance, including organic as climate smart, organic research priorities and more will be finalized in the fall.  Two petitions for rye pollen extract as not available as organic and magnesium carbonate as an anti-caking agent in chicory were not accepted to the handling section of the National List.  

A full recap of the five days of public comment and in-person meeting will be in the upcoming Organic Farmers Association Organic Voice magazine.

USDA Requests Applications to Fill National Organic Standards Board Vacancies

The National Organic Standards Board works to develop and update standards for substances to be used in organic production and to advise the Secretary on the implementation of the Organic Foods Production Act of 1990. This year, the Agricultural Marketing Service (AMS) is requesting nominations to fill the following vacancies:   

• One individual who owns or operates an organic farming operation or employee of such individual; 
• Two individuals who own or operate an organic handling operation or employees of such individuals; 
• One individual who owns or operates a retail establishment with significant trade in organic products or employees of such individuals; and 
• One individual with expertise in areas of environmental protection and resource conservation. 

Board appointees will serve a five-year term beginning January 2025 and ending January 2030. Additionally, AMS is requesting applications for a pool of candidates that the Secretary of Agriculture can draw upon as replacement appointees if unexpected vacancies occur. 

Interested applicants can view more information about the NOSB, time commitments, workload, and how to apply, at the NOSB Nominations page. The deadline for applications is June 28th, 2024.

by Amber Lippon

Spring 2024 OFA Oral Comments to NOSB

Click here for OFA Submitted Written Comments: Spring 2024

Below: OFA Oral Comments to the NOSB: Spring 2024

Lily Hawkins, Policy Director

Spring 2024 NOSB Oral Comment

Thank you for the opportunity to speak to you today.  My name is Lily Hawkins, I am the Policy Director of the Organic Farmers Association. Today I’ll be speaking on a few big-picture issues and suggested agenda items that have been raised by our farmer-members.

First - RACIAL EQUITY 

OFA is grateful for the board’s efforts to address racial equity within organic.  We encourage the board to keep thinking about how the USDA Equity Commission’s report findings can become part of the NOSB and NOP’s processes, possibly by making this a work agenda item. Institutionalizing equity through strategic outreach, board trainings, and a racial equity lens incorporated into all committee work is necessary for organic to move forward.

Second - GLOBAL ORGANIC MOVEMENT CONSISTENCY

Organic is a global movement, and organic farmers deserve to be operating in an equitable marketplace under the organic label. OFA supports the idea of testing imports to verify organic integrity - covered in depth by other speakers today. Furthermore, as the U.S. organic regulatory system benefits from consistency of interpretation and application, the international organic movement benefits from increased consistency across national organic programs. There are a few materials in which there is a lack of consistent practice in the U.S. system, which conflicts with our trade partners, organic neighbors, IFOAM interpretations, and CODEX regulations. 

We appreciate the Board’s attention to this matter when reviewing each material, and OFA agrees that we should bring our standards into greater alignment with the global organic movement.  

Third - STRENGTHENING ORGANIC ENFORCEMENT IMPLEMENTATION

OFA is very grateful for the effort it took to bring the SOE rule to the point of implementation.  At the same time, we have concerns about low-risk organic operations being burdened by the increased scrutiny and oversight, and certifiers implementing the rule inconsistently across the nation. Our NOSB workgroup noted that the paperwork for feedstock for livestock, and for mixed vegetables were more burdensome this year.  In some cases, we have heard of the OSP length doubling from 2023 to 2024.  

We understand that the intention of the SOE was not to increase the paperwork burden for low-risk organic operations, and we request that the NOP, during their certifier accreditation audits, review the changes made to the OSP, with a critical eye to the enhanced paperwork and activities required of low-risk, small and mid-scale short supply chain operations.  We want SOE to focus where it was intended.

We also encourage the NOP to support dialogue amongst certifiers to define low-risk and high-risk, and provide guidance so that certifiers can administer the standards with the security of NOP alignment on risk assessment.  And put the increased scrutiny where it is most needed and reducing burden on low-risk operations. 

Lastly - AGROFORESTRY AND 90/120 DAY RULE

In OFA’s annual policy survey, farmers noted the need for NOSB to review the 90/120 day rule as it applies to agroforestry production systems in which livestock graze under fruit and nut trees. Please consider creating an agenda item to address this request.

OFA In-Person Oral Comments

NOSB Meeting in Milwaukee, WI

April 29, 2024

Harriet Behar, Farmer Services Consultant, Organic Farmers Association

My name is Harriet Behar and I am the Farmer Services Consultant with the Organic Farmers Association.  My vegetable, herb and poultry farm has been certified organic since 1989.

SOE & Import Fraud- During the public comment webinars, farmers, buyers, and processors all spoke to the dire situation for domestic organic grain producers.  Jenny’s extensive overview of SOE was very encouraging, with a robust roll-out and a strong commitment.  U.S. farmers need oversight before the imported ships leave their ports, and at our own ports of entry, including overland shipments from Canada and Mexico. OFA asks the NOSB to show support for our domestic producers with a resolution to the NOP, asking for a speedy expansion of the residue testing pilot program to a much larger program.  We are playing a game of whack a mole, when we stop one source of fraudulent grain, a different one appears.   We need stronger enforcement to lessen this overwhelming flow of questionable organic products.  A special imported grain hot-line should be implemented and promoted by the NOP, offering a place for fraud concerns, broker activities denying entry and for those finding issues once they receive product, to report their findings.

Inerts- The National Organic Coalition has a workable proposal for dealing with this long unsolved issue.  With the changes coming to the NOSB next year, it is imperative this board come forward with a final proposal that addresses both the mandate that the board review all synthetics used in organic production, and provide a way forward to allow for future innovation in formulations, and provide certainty for those using current inerts. 

Use of organic seeds- In the EU, each country has developed a list of specific seed varieties that are available as organic.  If an organic grower does not use these organic varieties, they cannot sell that crop as organic.  OFA asks the NOSB to work with the NOP, to have either the NOP do the research or fund an outside organization to develop a list of equivalent varieties, so we can require organic seed use when available.  The stagnant nature of organic seed purchases in the U.S., affects the availability of organic seed, seed breeders will not continue to innovate and produce organic seed varieties when there are warehouses full of unsold organic seed.  The lack of transparency for gene-edited seed, makes the use of organic seed even more important.

Compost- The current definition produces high quality compost without the risk of unwanted and dangerous synthetics.  High nitrogen compost is immature compost, since nitrogen tends to leach easily. There is no reason to change our current definition.

Julia Barton, OFA

Spring 2024 NOSB Oral Comments

12:15 on 4/23/24

Good afternoon, my name is Julia Barton with the Organic Farmers Association. I’d like to share comments today on 3 topics.  

First: Farmer Participation in NOSB

Thank you for including both virtual and in-person comments in this meeting.  You have already heard from some OFA farmer members and you will continue to hear from more.  This way of handling comments offers an opportunity for various types of interactions, stakeholder input, and community building.  OFA farmers are very clear that we need both types of commenting.  More opportunities for communication are better.  Thank you for holding time and space for this important part of the public process.

I also wanted to note that Linda Halley, long-time organic farmer was going to be with you to comment in Milwaukee on Monday.  Linda was the most active member of our NOSB workgroup.  She has had some health issues come up that will prevent her from being with you that day, but we will get her comments to Michelle via email and will be sharing them on OFA social media, so please follow OFA to hear from Linda, organic farmer of over 30 years.  This will be her first comment to the board.

Next: Hydroponics and Containers

OFA is part of a working group of certification, education, and policy organizations who agree that soil is the foundation of organic agriculture.

OFA farmer members are very clear that hydroponics is not settled issue.  We urge the board to call for a moratorium on the certification of new hydroponic operations, and crops grown to maturity in containers until we can utilize our existing NOSB and rulemaking process to move forward with greater consistency.  Please activate the latent agenda item “Field and Greenhouse Container Production.”

Finally: Crop Insurance 

OFA appreciates the board’s work on this important topic. OFA farmer-members have a wide range of experiences with crop insurance and are eager to make crop insurance more fair, functional, and informed for organic farmers and all farmers.  You’ve heard from two of our working group’s very active members and you’ll meet Noah Wendt, if you don’t already know him, in Milwaukee.  If you have any specific items our group can workshop, we’d be happy to help in that way, and we’d also be happy to respond to any questions you have on our comments.

Thank you for the opportunity to comment, for your time, and for your service.

April 29, 2024

Kate Mendenhall, Executive Director

RE: General Comments to the NOSB via In-Person Testimony

Thank you, NOSB members, for the opportunity to speak before you today.  My name is Kate Mendenhall, I am the Executive Director of the Organic Farmers Association.

OFA was created by farmers, for farmers.  They are the backbone of the organic movement and we owe today's strong market to their hard work and continued innovation.  Making sure that organic farmers have an equitable playing field has always been a top priority of OFA.  In fact in the 7 years we have been established, stopping import fraud has been a consistent #1 priority of organic farmers.  SOE has provided many new tools to certifiers and authorities to the NOP--together they must implement risk-based and sound & sensible decision making that will curb fraud in the marketplace. 

1. Having continued guidance from NOP around high-risk protocols that would support targeted increased scrutiny is incredibly important.  It’s important so low-risk operations are not overburdened with paperwork and processes and so that operations that present higher-risk to the market bear the appropriate enforcement and documentation to prove integrity is solid. Continued clarity and support from NOP is important so certifiers implement risk consistently and appropriately.  We appreciate NOP’s leadership on this and know this is an ongoing need for attention.
2. Hearing import grain fraud back at the top of the farmer testimony breaks my heart.  U.S. farmers do a great job, organic farming is hard, and they deserve an equitable market.  We also cannot encourage farmers to transition to organic if the market is not secure and stablized. The NOP has the authority to require testing of high-risk imports now, we are excited to hear about the pilot with Federal Grain Inspection Service and innovations like this should expand to secure organic integrity in the marketplace.  We all know it’s a problem-we need work together to fix it quickly. 

USDA programs play an important role in supporting farmer success and improvement. NRCS 823 has a lot of potential and rollout has been discouraging.  OFA encourages the NOSB to pass a resolution calling on the Secretary to fix the national roll-out of NRCS 823 so it is consistent among states and transparent in its process, so that the farmers who want it can easily apply and keep farming.  OFA will be starting a farmer work group on this topic in the fall- any farmers interested in working to improve 823 should get in contact with us.

Farmers need adequate safety nets so that they can survive to farm another season when they are consistently placed in the nexus of consolidation and climate change.  Dairy farmers continue to struggle, crop insurance continues to need significant improvements, and consolidation threatens to break fragile supply chains and infrastructure.  While the draft farm bill may offer some improvements, this is a moving target we need to stay on top of.  OFA has farmer-work groups on this topic as well and we’re always looking for more farmer experts.  

Diversity is a central tenet of organic and prioritizing equity at NOSB & NOP provides collective improvement for all farmers. OFA urges the NOP and NOSB to apply the USDA’s 2023 Equity Commission recommendations, and embed racial equity in NOSB processes, discussion documents, and public meetings. 

Thank you so much for the opportunity to speak before you today.

by Amber Lippon

April 2024 Policy Update

by Amber Lippon

March 2024 Policy Update

by Amber Lippon