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Re: SMALLFARM-MG> Organic Produce



Hello Sal,

Now we are getting done to brass tacks.  Sounds like a story (and contrast it
with Texas for the Organic Food Business News, ACRES or the Wall Street
Journal) for a publication.

Can you document the cost you are paying to whom for what period of time?
 Please document the inspections and paperwork that you as a grower are
called on to perform.  Let me inform you Sal that one of the reasons the
Proposed Organic Rule was returned from Office of Management and Budget to
USDA and did not get passed on for a final rule is USDA staff had requested
too much paperwork from farmers and handlers.  If duplication of inspections,
paperwork and fees are being charged in California now, bringing it out now
will acquaint the USDA staff and the Secretary with an unacceptable State
program.  I will point out to you as long as two years ago I was told by the
director of the California Organic Program under CDFA, California Department
of Food and Agriculture, that county Ag Commissioners were asking for the
kind of enforcement powers you indicate receiving notice about in the letter.
 I think one can document that it was not CDFA who initiated this county
level program.  What does that mean?  Is someone influencing the county Ag
Commissioners to put pressure on organic farmers?  Are certified organic
handling operations in California being treated the same?  Who would want to
put such pressure on organic farmers in Santa Barbara county?  Maybe, there
lies the answers?  A letter from CDFA Organic Program telling you about the
program does not mean they are doing anything but following the Ag
Commissioners desires.  I think when you investigate you will find the letter
has only been sent out to a limited number of counties in California.  That
alone is illegimate--discriminatory action.  I encourage you to find the
facts and tell the LA Times and the San Francisco newspapers in a coherent
and well written fashion.  Another question is where are CCOF and Organic
Farming Research Foundation on this matter.  Speak up to the right folks.


Lastly, as I spoke before the USDA/NOP is the potential permanent remedy for
such burdens being placed on organic farmers and handlers.  The time is now
upon us, the public comment period, in the next months to clearly prevent
such miscarriages of regulatory authority, whether on the State or Federal
level, as you indicate.  

Best,  Eric