PETITION

TO SECRETARY OF AGRICULTURE DAN GLICKMAN

from members of the

NORTHEAST ORGANIC FARMING ASSOCIATION OF VERMONT

to be hand delivered by

VERMONT SENATOR PATRICK J. LEAHY TO SECRETARY GLICKMAN

and submitted to Docket Number TMD94002

Vermont farmers have pioneered organic agriculture and it is a vital economic sector in our state. Just a decade ago, Vermont had only 17 certified farms covering 138 acres with gross annual sales under ½ million dollars. Today, 170 certified producers have 13,900 acres in organic production and generate more than $25 million in gross annual sales. Alarmingly, the National Organic Program as proposed by the U.S. Department of Agriculture threatens to undermine the Vermont organic sector by disregarding industry norms and establishing standards that differ dramatically from consumer expectations.

We, the undersigned, urge the Secretary of Agriculture to rewrite the proposed rule so that it better reflects the dictates of the Organic Foods Production Act of 1990 and the National Organic Standards Board (NOSB) recommendations. Specifically, we urge the Secretary to:

Adhere to the NOSB National List recommendations!

We do not support nor find legal justification for the Secretary's additions of synthetic materials to the National List. In the rare cases when synthetic materials are allowed, they must first be approved by the NOSB. This decisionmaking process will ensure that our national standards live up to industry and consumer expectations.

Prohibit unwanted materials from organic production!

We do not want sludge or ionizing radiation used in organic production. Nor do we want transgenic crops and other genetically engineered organisms and ask that, as a class, they be defined as prohibited synthetic materials. If sludge, ionizing radiation, and GEOs are allowed, it will cripple our industry.

Require higher standards for livestock!

We want tough livestock standards that require 100% organic feed, severely limit antibiotic and paraciticide use, and require humane living space for animals. The NOSB recommendations should be upheld as they reflect an industry consensus, international standards, and environmental and consumer group input.

Protect small operations!

Vermont NOFA is a small nonprofit organization that certifies small farm and processing operations. The fees proposed by USDA will put us, and our clients, out of business. USDA should invest in this industry and develop a progressive fee structure that takes into account the size and financial ability of those it seeks to regulate.

Stick to organic labeling!

This is not the time or the place to prohibit a variety of ecolabels as discussed in the proposed rule. The National Organic Program should only regulate the term "organic" as required by the Organic Foods Production Act.

We appreciate your consideration of the needs of Vermont.

Respectfully submitted,