April 30, 1998

Dear Mr. Secretary:

We support the development of a strong National Organic Program and appreciate your efforts to implement the Organic Foods Production Act of 1990. We are writing, however, to express our concern that the Proposed Rules fail to conform with consumer expectations and, if implemented, would cause serious economic harm to the organic industry. We urge you to rewrite the Proposed Rules so that they reflect industry norms as represented by existing private, state, and international standards.

We ask that you return to the recommendations of the National Organic Standards Board (NOSB) as a model for your overhaul of the Proposed Rules. As you know, the NOSB was established by Congress to provide public participation and industry expertise in the development of standards and to determine the proposed National List of allowable synthetics in organic production. Regrettably, the Proposed Rules ignore many of the NOSB recommendations and specifically disregard the authority Congress granted to the NOSB to determine the narrow list of allowable synthetics. The result — a USDA proposal that is almost universally condemned by those it seeks to help.

Consumers expect organic products to be produced in the most environmentally sound manner possible. They also expect such products to be produced free of genetic engineering, biosolids, and ionizing radiation. We expect USDA to uphold these marketing distinctions so important to consumers, cultivated by organic farmers, and which profit American agriculture in so many ways.

Thank you for your attention to our concerns.

Sincerely,