Associated Press April 27, 2015 | 7:19 p.m. EDT + More

Steve

Judge: Law that could make 

Vermont 1st state to require 

genetically modified food label 

stands

By DAVE GRAM, Associated Press

MONTPELIER, Vt. (AP) — A Vermont law that could make the state the first in the country 

to require labeling of genetically modified food has been allowed by a federal judge to 

stand for now despite opposition by food industry groups.

U.S. District Court Judge Christina Reiss in Burlington on Monday ruled against the 

Grocery Manufacturers' Association and other industry groups in their request for a 

preliminary order to block the law from going into effect as scheduled on July 1, 2016.

The judge partially granted and partially denied the state's motion to dismiss the industry 

lawsuit, meaning the case is likely to go to trial.

Vermont Attorney General William Sorrell, whose office finalized rules to implement the law

 on April 17, said in an interview, "There's a lot of good news in this decision for us and for 

the heart and soul of the labeling law."

The Grocery Manufacturers Association said it was pleased the court "found us likely to 

succeed on several of our claims" but was disappointed at the denial of its request for a 

preliminary injunction.

"Manufacturers are being harmed, and they are being harmed now," the association said in

 a statement. "Act 120 is unconstitutional and imposes burdensome new speech 

requirements on food manufacturers and retailers."

The ruling comes nearly a year after Democratic Gov. Peter Shumlin signed the law, under

 which Vermont is expected to become the first state to require genetically modified 

organism, or GMO, food labeling. Connecticut and Maine passed laws earlier but required 

that neighboring states follow suit before they would take effect.

The Grocery Manufacturers Association was joined by the Snack Foods Association, the 

International Dairy Foods Association and the National Association of Manufacturers as 

plaintiffs in the lawsuit, seeking to have Vermont's law declared unconstitutional.
Throughout the legislative and legal debate on GMO labeling, industry groups have argued

 that the First Amendment gives them broad discretion about what to include on their labels

 and that there's no compelling state interest to offset that.

Supporters of the law have included consumer and environmental groups. Muslims and 

some Jews avoid pork, and concerns have been raised about pork genes being introduced

 into other foods.

The judge found that the concerns embedded in Vermont's law were well within the state's 

purview.

"The safety of food products, the protection of the environment, and the accommodation of 

religious beliefs and practices are all quintessential governmental interests, as is the 

State's desire 'to promote informed consumer decision-making,'" she wrote, quoting from 

the state's court filings.

The court dismissed the industry groups' request that it apply a legal standard of strict 

scrutiny to the free-speech issues in the case, making it easier at trial for the state to rebut 

the companies' First Amendment claims. It also dismissed the plaintiffs' request that the 

law be found to violate the Commerce Clause of the U.S. Constitution.

Conversely, Sorrell said the court made it clear the state would face "an uphill battle" in 

defending a ban in the law on food companies labeling genetically modified food as 

"natural."

Copyright 2015 The Associated Press. All rights reserved. This material may not be 

published, broadcast, rewritten or redistributed.
Associated Press April 27, 2015 | 7:19 p.m. EDT + More

From: Jean Richardson

To: McEvoy Miles - AMS; Zea Sonnabend

Subject: [Caution: Suspicious Link]Fwd: Law that could make Vermont 1st state to require genetically modified food label stands

Date: Saturday, May 02, 2015 10:44:35 AM

Assume you both saw this which came out this week

Jean

Judge: Law that could make 

Vermont 1st state to require 

genetically modified food label 

stands

By DAVE GRAM, Associated Press

MONTPELIER, Vt. (AP) — A Vermont law that could make the state the first in the country 

to require labeling of genetically modified food has been allowed by a federal judge to 

stand for now despite opposition by food industry groups.

U.S. District Court Judge Christina Reiss in Burlington on Monday ruled against the 

Grocery Manufacturers' Association and other industry groups in their request for a 

preliminary order to block the law from going into effect as scheduled on July 1, 2016.

The judge partially granted and partially denied the state's motion to dismiss the industry 

lawsuit, meaning the case is likely to go to trial.

Vermont Attorney General William Sorrell, whose office finalized rules to implement the law

 on April 17, said in an interview, "There's a lot of good news in this decision for us and for 

the heart and soul of the labeling law."

The Grocery Manufacturers Association said it was pleased the court "found us likely to 

succeed on several of our claims" but was disappointed at the denial of its request for a 

preliminary injunction.

"Manufacturers are being harmed, and they are being harmed now," the association said in

 a statement. "Act 120 is unconstitutional and imposes burdensome new speech 

requirements on food manufacturers and retailers."

The ruling comes nearly a year after Democratic Gov. Peter Shumlin signed the law, under

 which Vermont is expected to become the first state to require genetically modified 
organism, or GMO, food labeling. Connecticut and Maine passed laws earlier but required 

that neighboring states follow suit before they would take effect.

The Grocery Manufacturers Association was joined by the Snack Foods Association, the 

International Dairy Foods Association and the National Association of Manufacturers as 

plaintiffs in the lawsuit, seeking to have Vermont's law declared unconstitutional.

Throughout the legislative and legal debate on GMO labeling, industry groups have argued

 that the First Amendment gives them broad discretion about what to include on their labels

 and that there's no compelling state interest to offset that.

Supporters of the law have included consumer and environmental groups. Muslims and 

some Jews avoid pork, and concerns have been raised about pork genes being introduced

 into other foods.

The judge found that the concerns embedded in Vermont's law were well within the state's 

purview.

"The safety of food products, the protection of the environment, and the accommodation of 

religious beliefs and practices are all quintessential governmental interests, as is the 

State's desire 'to promote informed consumer decision-making,'" she wrote, quoting from 

the state's court filings.

The court dismissed the industry groups' request that it apply a legal standard of strict 

scrutiny to the free-speech issues in the case, making it easier at trial for the state to rebut 

the companies' First Amendment claims. It also dismissed the plaintiffs' request that the 

law be found to violate the Commerce Clause of the U.S. Constitution.

Conversely, Sorrell said the court made it clear the state would face "an uphill battle" in 

defending a ban in the law on food companies labeling genetically modified food as 

"natural."

Copyright 2015 The Associated Press. All rights reserved. This material may not be 

published, broadcast, rewritten or redistributed.
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Automatic reply: [Caution: Suspicious Link]Fwd: Law that could make Vermont 1st state to require genetically

 modified food label stands

Date: Saturday, May 02, 2015 10:44:36 AM

I am out of the office. Please contact Joan Avila at 202-720-3252, joan.avila@ams.usda.gov if

 you need immediate assistance.
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: Automatic reply: FYI: Jim Riddle letter

Date: Sunday, October 13, 2013 4:13:12 PM

Hi miles

When you get a chance I would really appreciate your honest opinion on Jim Riddle's e-mail

Thank you

Jean

Sent from my iPad

On Oct 13, 2013, at 4:10 PM, "McEvoy, Miles - AMS" <Miles.McEvoy@ams.usda.gov>

 wrote:

Thank you for your message.

I am not in the office at this time. I am on furlough without access to email, due to

 the lapse in federal government funding. I will return your message as soon as

 possible once funding has been restored.

For information about available government services, visit USA.gov.

This electronic message contains information generated by the USDA solely for

 the intended recipients. Any unauthorized interception of this message or the use

 or disclosure of the information it contains may violate the law and subject the

 violator to civil or criminal penalties. If you believe you have received this

 message in error, please notify the sender and delete the email immediately.
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: Arrival

Date: Wednesday, February 11, 2015 6:12:49 PM

Ok!

Sent from my iPad

> On Feb 11, 2015, at 4:03 PM, "McEvoy, Miles - AMS" <Miles.McEvoy@ams.usda.gov> wrote:

>

> My travel plans have changed. New arrival is 11:57 from dc

>

> Miles V McEvoy

> Deputy Administrator

> USDA National Organic Program

>

>

>

>

> This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: aquaculture

Date: Monday, July 21, 2014 4:38:55 PM

hi Miles

I am going to attend the October IOIA training and note that George Lockwood is on the agenda listing the Working

 Group as an NOSB Working Group? Is that the technically correct title?

Correct attributions are sometimes pretty critical!

Thank you

Jean
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: annotations

Date: Monday, February 02, 2015 5:50:38 PM

Ok yes let's discuss some species so we can start petitions if necessary early

I am on the snow delayed plane for DC

Jean

Sent from my iPhone

> On Feb 2, 2015, at 5:25 PM, McEvoy, Miles - AMS <Miles.McEvoy@ams.usda.gov> wrote:

>

> You can't annotate during the sunset process. You can recommend annotation through a separate process. Let's

 discuss while you are here.

>

> -----Original Message-----

> From: Jean Richardson [

> Sent: Thursday, January 29, 2015 6:07 PM

> To: McEvoy, Miles - AMS

> Subject: annotations

>

> So for example, if we had a proposal to annotate " iodine-for external use only ; not to be made using xxx

 excipient or whatever" , and at the October meeting we voted on the annotation proposal BEFORE we voted on the

 Sunset "motion to remove" (meeting 2 of Sunset) would that work?

>

> We would then vote to keep "iodine" (presently with no annotation) on the List but the NOSB's intent for this in

 reality would be demonstrated to be tied to the proposed annotation previously voted on.

>

> Otherwise, in good conscience we can't vote in favor of keeping "iodine" knowing what we are now learning. 

 And iodine in its molecular form is critical and we need it.

>

> This is just one example for us to think about. There will be a few others.

>

> Thank you for talking with me.

> Jean

>

>

>

>

> This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

(b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Annotation note

Date: Tuesday, July 15, 2014 11:19:54 AM

Found this in a 2012 FR notice...

Prior to the October 2010 meeting,

NOSB policy specified that

recommendations for substances under

sunset review were limited to two

options: (1) Renewal, or continuation of

each exemption or prohibition as

codified in the NOP regulations; or (2)

removal, allowing the exemption or

prohibition to expire. In October 2010,

the NOSB changed their sunset policy to

allow a third option for issuing a

recommendation.2 The third option

enables the Board to add or change

annotations (restrictions) on National

List substances under sunset review.

This change in policy ensures that the

Board can address new use patterns and

scientific information on substances

allowed or prohibited in organic

production. The policy limits such

annotation changes under sunset to

those which clarify an existing

annotation or make the annotation more

restrictive. The new policy does not

authorize an annotation change during

the sunset review process that would

result in expanded use of an exempted

substance.
From: McEvoy, Miles - AMS

To: Jean Richardson

Cc: Dave Chapman; nicole dehne; Wonnacott Enid; Zea Sonnabend (zea@well.com); Brown Rosen, Emily - AMS

Subject: Re: An update on "organic hydroponic"

Date: Thursday, March 12, 2015 6:46:20 AM

We are looking for all perspectives to be represented on the task force. As I mentioned to

 Dave in Vermont, he would make an excellent candidate.

Miles V McEvoy

Deputy Administrator

USDA National Organic Program

On Mar 11, 2015, at 3:11 PM, "Jean Richardson" < wrote:

Hi Miles

Here is an e-mail from Dave Chapman, organic green house tomato producer. I

 am sure you recall your conversations with him at the NOFA Winter Conference

 in Vermont last month. His lengthy e-mail is probably a good reflection of the

 scope of concerns held by a sizeable group of stakeholders.

I believe that the AMS is genuinely seeking a comprehensive, up to date

 understanding of the scope of hydroponic and aquaponic agriculture within the

 context of certified organic agriculture, including soil based greenhouse

 producers. However, Dave's quotation from the Task Force notice in the Federal

 Register (FR Monday March 9, 12422) .... "Minimum skills" .... does appear to

 preclude non-hydroponic/aquaponic producers from being nominated or

 appointed. " Candidates for the hydroponics and aquaponics task force should

 have 3 years of demonstrable work experience in hydroponic or aeroponic (sic)

 production in any of the following roles:......"

Is a clarification called for?

Thank you

Jean Richardson, Chair NOSB

Begin forwarded message:

From: 

Date: March 11, 2015 2:10:08 PM EDT

To: undisclosed-recipients:;

Bcc: 

Subject: An update on "organic hydroponic"

Hello all,

It has been a year since I last sent an update. I was swept away by the

 farm last March, and it left me little time for working on this issue.

 Since then the petitions have slowly grown in numbers with no help

 from us, and are presently hovering around 1200 signatures. Clearly

(b) (6) (b) (6) (b) (6)
 we have barely touched the organic customers yet. I confess that I

 was discouraged about petitions after talking with Mark Kastel from

 Cornucopia last Winter. He said that no number of signatures would

 move the NOP, and that our only real hope was political pressure

 from our Senators and Representatives. Our Vermont delegation has

 given us their support, but so far to no avail. I have heard that

 Cornucopia is planning to have a front page article on the

 hydroponic issue in their Spring newsletter.

There has been some other progress since I last wrote. The National

 Organic Coalition passed a resolution of support for the NOSB

 recommendation last year. The NOC is a broad coalition of

 organizations, and getting the members to agree on anything is a

 major victory. I have posted their resolution on the website.

I have also posted the open letter to Miles from the Agrarian Elders.

 Last year we managed to reach all but two of them to sign a letter of

 support.

I was approached by a reporter from the Wall Street Journal recently.

 He is interested in pursuing a story on this issue. He needs to find a

 good hook to sell it to his editors. Any ideas?

As many of you know, Miles MacEvoy came to Vermont in February

 to speak at the NOFA Winter Conference. I attended two sessions

 with him, plus we had a chance to talk together afterwards. The take

 home story from it all was that Miles is NOT going to act on the

 NOSB recommendation. There is no change there. Miles' story is

 that the NOSB recommendation is too vague to make a rule. He also

 said several times that he is helpless to effect a change or to offer

 real leadership on this issue. He kept insisting that he did not have

 the power to block hydroponic growing from certification.

When I asked Miles for an example of how the NOSB

 recommendation is too vague, he said that one example is that it

 didn't define soil, so how would the new rule come up with that

 definition? I suggested that most of Europe, England, Canada,

 Mexico, and Japan have all successfully addressed that challenge,

 and that it wouldn't be too difficult to examine their language and

 come up with good wording. That hadn't occurred to him.

Miles acknowledged that there is a lot of opposition to "organic

 hydroponic" in Vermont, but he doubted that people in the rest of the

 country cared. What about the National Organic Coalition? What

 about the many people from all over the country who signed the

 petitions? What about the organic standards from rest of the world?

 What about the recommendation from the NOSB? The USDA still

 stands virtually alone in the world in their redefinition of organic.

 Perhaps Miles has been spending too much time in Washington, and

 has lost touch with the rest of the organic community?
Miles' solution to the dissent of so many of us in the organic farming

 community is to form a "task force" to come up with clear language

 for rule making. Apparently going back to the NOSB isn't good

 enough. But when I pressed him on the mission of the task force, he

 said it was simply to look at the issue with fresh eyes, getting strong

 input from all interested parties. As it turns out, the actual

 announcement in the Federal Register for the task force states clearly

 that "Candidates for the hydroponics and aquaponics task force

 should have 3 years of demonstrable work experience in

 hydroponic and aquaponic production in any of the following

 roles: Producer; researcher or scientist, consumer

 representative; conservationist; systems designer; organic

 inspector; or accredited certifying agent. Candidates with

 demonstrable knowledge of organic production or certification

 procedures are preferred." Good heavens! It seems that they only

 want people with at least three years experience in hydroponic

 growing to be part of the task force. Even if they make an exception

 for someone like me, I will be a lonely minority voice on the task

 force, when if fact, hydroponic growing is a very minor and highly

 controversial part of the organic community. This is like forming a

 task force to consider the issue of GMOs in organic growing, and

 then limiting participation to Monsanto employees.

The truth is that the NOP does not agree with the NOSB

 recommendation, so they are creating a NEW advisory board to

 come up with a more acceptable answer. If the real issue was that the

 NOSB recommendation was too vague, Miles could simply send it

 back to the NOSB for clarification. The NOSB has already spent

 years of work on their recommendation, including a long period of

 public comment. The intent of their recommendation is quite clear.

 It is also clear that the NOP does not agree with the NOSB intent. So

 their solution is to create an advisory board that will come up with a

 more agreeable recommendation!

Having said all that, I am coming to the sad truth that we are losing

 the organic standards. Organic as redefined by the USDA is

 changing into something new. The new definition is driven by

 money rather than beliefs. And most sadly, this weakening of

 organic integrity is coming under a Democratic president (whom I

 have contributed to and campaigned for). I hate to say it, but we

 really were doing better with the NOP organic standards under Bush!

So what to do? Our farm is forced to be involved with USDA organic

 certification, regardless of my beliefs. But rather than it being

 something that I am proud of, certification is turning into another

 task to be completed in order to satisfy the requirements of the

 supermarket chains, much like GAP certification. I will continue to

 work to reform the organic standards, but I think that the term

 organic will no longer serve as a way of letting our customers know
 how we farm. We are NOT growing in the same way as the

 hydroponic growers in Mexico. And our customers want to know

 that. If "Certified Organic" no longer shows the difference, do we

 will need to find another way of identifying what we do. Believe me

 when I say that this is not a direction that I wish to go in.

When I began farming organically in 1981, there really wasn't any

 economic incentive. Very few people cared about organic, even

 though it had been around for 35 years. The first two years at the

 farmer's market, I got as much grief from customers as support. Back

 then organic was a way of farming that was intertwined with a way

 of living. Now, at the same time that organic farming succeeds

 wildly in the marketplace, it is abandoning some of the core

 principles that made it so popular. I am seeing a growing movement

 of farmers who are organic, but not certified. They are mostly

 smaller farms that are selling locally. Many of them have signed the

 petition. Perhaps it is time for some of us to find a new name for old

 practices. "Organic" is just a word. Sir Albert Howard's first two

 books never used the word, but the principles were already clearly

 established. We can keep the principles and find a new word.

 Certainly no matter what we do, "certified organic" is an economic

 powerhouse that will continue to grow.

I met a nice young guy at the conference who worked for the Organic

 Trade Association. He was trying to bring some of the many smaller

 organic farms in the country into the OTA to join in their"Got

 Organic" marketing campaign. But I am struck by the growing

 distance between my farming practices and the organic standards. If

 the organic standards no longer represent how we farm, why would

 we help promote "organic" farming to our customers? After a

 lifetime of believing in and supporting organic farming, I find myself

 wondering how I can find a new term to signify how I farm.

 "Organic farming" is now the property of the USDA, and it looks

 like they really don't care what we think about that. Have we turned

 the henhouse over to the foxes for supervision?

I will probably volunteer to join Miles' "task force" even though I

 don't meet the requirements. Based on the notice, I will not be

 permitted to join. Even if I AM permitted, who else has been

 blocked from participation? All the other organic growers. Probably

 the best we can hope for is some kind of identifying word on the

 organic label for "Hydroponic Organic". I think the deck is pretty

 well stacked against us, but I urge all of you to volunteer for the

 "task force" as well, even though none of you qualify as having

 enough "organic hydroponic" experience! This is a thankless task. I

 would also like to hear back from any of you with your thoughts

 about this (rather lengthy) letter.

Best to all,
(b) (6)
From: Jean Richardson

To: Mac Stone; McEvoy, Miles - AMS

Subject: All aquaculture materials done!

Date: Tuesday, February 18, 2014 4:28:16 PM

Hi Mac and Miles

Tracy did a great job and despite certain roadblock efforts we finished approving all the last of the aquaculture

 (crops) materials this afternoon.

Mac, be sure to touch base with Tracy if you want your vote added.

Have a good time in San Diego

Jean
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: Agenda Items for LS

Date: Wednesday, July 01, 2015 11:12:04 AM

Ok

Sent from my iPhone

On Jul 1, 2015, at 8:35 AM, McEvoy, Miles - AMS <Miles.McEvoy@ams.usda.gov> wrote:

Hi Jean –

Please put on agenda for next Executive SC.

Miles

From: Jean Richardson [

Sent: Tuesday, June 02, 2015 2:50 PM

To: McEvoy, Miles - AMS

Cc: Brown Rosen, Emily - AMS; Tracy Favre (tfavre@favrehouse.com)

Subject: Agenda Items for LS

Hi Miles

I wish to request addition of two items to the LS agenda for us to work on this summer with

 the the aim of having at least Lidocaine/Procaine being on the October NOSB.

Both of these are Sunset 17 materials. The first one is fairly simple and relates to an annotation

 change for the two pain killers Lidocaine and Procaine, and the second one is more complex

 relating to Parasiticides.

1. Lidocaine and Procaine.

These are listed separately.

Our Sunset 17 Template 2 is pretty simple and indicates we will be proposing to shorten the

 Withholding period. Below is the Lidocaine template, and the Procaine is the same.

 Reference: §205.603(b) As topical treatment, external parasiticide or local

 anesthetic as applicable

 (4) Lidocaine—as a local anesthetic. Use requires a withdrawal period of 90 days

 after administering to livestock intended for slaughter and 7 days after

 administering to dairy animals

Technical Report: None

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 sunset recommendation;

10/2010 sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR

 33290)

Sunset Date: 6/27/2017

Subcommittee Review

(b) (6)
Lidocaine is a local anesthetic. It numbs ONLY the area to be worked on.

The NOSB in its initial request for public comment asked:

1. Since this material was last reviewed have alternative materials emerged?

2. What is the scientific rational for what appears to be an excessively long withdrawal

 period?

3. Is there research to indicate that a shorter withdrawal period would be appropriate?

Public comment did not provide any alternatives, did not provide any scientific rationale

 for the lengthy withholding period and recommendations were received suggesting that

 a very short withholding period would be scientifically acceptable. The LS cannot make

 an annotation at Sunset review but will consider introducing a proposal to change the

 withholding period to 5 days for all livestock, slaughter and dairy.

There was widespread stakeholder support for continuing to list lidocaine.

This material meets the OFPA criteria.

 I do not have a specific number of days yet which I would propose for Withholding, but I

 believe this annotation change should be fairly easy and meet with general support

 from a broad range of stakeholders.

2. Parasiticides.

Parasiticides are covered in both 205.603 and also 205.238, so changes will be more complex

 than for Lidocaine and Procaine above. But changes are needed, and we now have the

 scientific data to support our proposal. These changes will have a positive impact on

 Livestock production. If we can get the proposal out and get comments for October we can

 wait and vote next April if Comment indicates we are asking for too much.

The general language at 205.603 treats all parasiticides the same, but they are not all the same.

There are three parasiticides on the list: Ivermectin, Moxidectin and Fenbenzadole.

We will most likely be voting to Remove Ivermectin from the list for many reasons

We may or may not be recommending removal of Moxidectin

We will be likely to keep Fenbenzadole on the list.

Here are some of the notes from our Sunset template showing some of the issues with our

 present language:

1. Fenbendazole, which is considered the most environmentally benign, is

 annotated to require the “written order of a licensed veterinarian".

 Ivermectin and Moxidectin have no such requirement. That may lead

 producers to choose a more environmentally detrimental parasiticide
 for convenience.

2. Moxidectin is annotated “for control of internal parasites only.” However,

 Moxidectin is widely used as a pour-on, and when used in that form for

 control of internal parasites it is also a de facto control for external

 parasites. Moreover the annotation “for control of internal parasites

 only": was apparently written based on incorrect information on the halflife of Moxidectin in the soil.

3. §205.603(a)(18) requires a 90-day withholding period for milk or milk

 products from a treated animal. There seems to be wide consensus

 that 90 days is much too long of a withholding period, because 1) it

 may motivate a producer to withhold needed treatment of an animal

 because of the severe consequences of a 90-day withdrawal, and 2)

 that is considered an excessive withdrawal time for food safety.

 Fenbendazole and Moxidectin have no milk withdrawal time for use in

 conventional production.

4. Ivermectin is not allowed for use in slaughter stock under the NOP, and

 it is not allowed for use in dairy animals of breeding age by the FDA,

 leaving the only legal use of Ivermectin to be on breeder stock before

 the last third of gestation for progeny to be sold as organic.

The newest addition to the list, Fenbenzadole, functions quite differently from the other 2 and

 the research, new TR and public comment over several years indicates that the manner in

 which it is used should be modified in terms of a much shorter withholding time and other

 aspects of parasite management.

We also have public comment and research which would indicate that sheep wool could be

 sold as Organic after the withholding period.

I have a working draft proposal of the proposed changes for both 205.603 and 205.238, but I

 am not quite ready to circulate it, but if necessary I can provide you with more detail so we

 can move forward and get this added to our LSAgenda.

Please let us know if we can add these to the LS Agenda right away.

Thank you

Jean
From: Jean Richardson

To: McEvoy, Miles - AMS; Miles McEvoy

Subject: advice on doing an interview

Date: Thursday, May 16, 2013 8:35:01 AM

Hi Miles

I have an e-mail request from Mark Keating of Acres to interview me, without attributions, regards the NOSB vote

 on Tetracycline

He says he used to work at NOP

Could you give me a quick phone call about this please

 (home office)

 (mobile)

Thank you,

Jean

(b) (6) (b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: Abu Dhabi?

Date: Sunday, December 14, 2014 7:28:56 AM

Hi Miles,

Thank you

now I wont feel guilty saying no.!

Jean

On Dec 13, 2014, at 6:07 PM, McEvoy, Miles - AMS wrote:

> Hi Jean,

> It is really far and of limited value. It would take a lot of time and effort to pull it off well. I'm not seeing how this

 conference would really move organics forward. I'm sure we'll be as busy next year as this one. There are many

 other efforts that would be more impactful than this conference.

>

> It's exciting to be invited to such a world conference but I think we have more important work to do.

>

> Miles

>

> -----Original Message-----

> From: Jean Richardson [

> Sent: Saturday, December 13, 2014 8:06 AM

> To: McEvoy, Miles - AMS

> Subject: Abu Dhabi?

>

> Hi Miles

> I am looking for your guidance.

> I talked with Raymond Chaves on Friday for quite a while. He seems pretty keen on my going to Abu Dhabi for

 the GFIA conference in March, to do a "TED" type talk or workshop. And I could do that, But I could tell he did

 not really understand my role in USDA/NOP/organics, just knew that if you recommended me that was good

 enough for him. Poor guy says he has been trying to get an organics USDA group to go since June!

> It is a long way to go from the US (15 hours on the plane non- stop from NY with 9 hours time difference ) for a

 huge gathering, without a "team" of us and a specific message we want to share.

> If it is really worthwhile I think we should do some advance planning and get it on our calendars for March 2016

 (same place) and do some careful preparation.

> What do you think?

> Jean

>

>

>

>

> This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

(b) (6)
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: RE: 5 pm ET call today

Date: Friday, August 07, 2015 2:18:16 PM

Ok - let's wait until next week then. I have you down for 12 noon eastern time on the 14th. Talk with you then.

Best, Miles

-----Original Message-----

From: Jean Richardson [

Sent: Friday, August 07, 2015 10:27 AM

To: McEvoy, Miles - AMS

Subject: Re: 5 pm ET call today

OK - I will be in Stowe meeting with the chef at the place possibly for the Board dinner and eating an early dinner

 there (just me). And then I will do a short hike. So you could reach me any time after 5.00 pm ET on my mobile if

 you need to. But no serious issues that cant wait till next week. I talk with Michelle most days!

At my desk right now doing Inspection Reports Jean

On Aug 7, 2015, at 9:53 AM, McEvoy, Miles - AMS wrote:

> Sorry. Just checking email this morning. Nice to disconnect for a few days. I have meetings this morning but

 could check in late afternoon for you.

>

> Miles V McEvoy

> Deputy Administrator

> USDA National Organic Program

>

>> On Aug 6, 2015, at 1:02 PM, "Jean Richardson" < wrote:

>>

>> Hi Miles

>> I have you on my calendar for 5 pm ET today, Thursday Please call me

>> on my cell- Thank you jean

(b) (6) (b) (6) (b) (6)
From: McEvoy, Miles - AMS

To: Jay Feldman

Cc: Nick Maravell; John Foster; Zea Sonnabend (zea@well.com); Carmela Beck (carmela.beck@driscolls.com); Jean

 Richardson ( Colehour Bondera (colemel@kanalanifarm.org);

joe.dickson@wholefoods.com; Harold Austin; Wendy Fulwider; Barry Flamm; Jennifer Taylor

; Arsenault, Michelle - AMS

Subject: FW: Biodegradable Mulch

Date: Tuesday, October 16, 2012 4:26:42 PM

I don’t seem to have Calvin or Tracy’s email. Please forward to them. Thanks

Miles

From: Michel Saumur [mailto:Michel.Saumur@inspection.gc.ca] 

Sent: Monday, October 01, 2012 2:54 PM

To: McEvoy, Miles - AMS

Cc: Courtney, Cheri - AMS; Kuhn, Meg - AMS; Valeriya Staykova

Subject: Re: Biodegradable Mulch

Hi Miles,

This is what we have gathered from the Canadian Organic Standards regarding mulches. We have also

 included some questions on mulches that are currently being discussed within the Standard Interpretation

 Committee.

Thank you, If you require more information please let know.

Michel

Table 4.3 of the PSL lists Mulches with certain origin and usage restrictions.

Organic plant residue: permitted for mulching. Where organic materials are not readily available, nonorganic straw, leaves, grass clippings or hay that are not the products of genetic engineering may be used.

 Substances prohibited by par. 1.4.1 of CAN/CGSB-32.310, Organic Production Systems – General

 Principles and Management Standards, shall not have been used on these materials for at least 60 days

 before harvest

Sawdust, wood chips and shavings: permitted for mulching if they are from natural sources or derive from

 natural substances and if they are from wood, trees or logs that have not been treated with paint or

 substances prohibited by par. 1.4.1 of CAN/CGSB-32.310, Organic Production Systems – General

 Principles and Management Standards.

Newspaper mulch: glossy paper and coloured ink are prohibited.

Paper: glossy paper and coloured ink are prohibited.

Plastic mulches: non-biodegradable and semi-biodegradable materials shall not be incorporated into the

 soil or left in field to decompose; shall be removed at the end of the growing season. Plastic mulches in

 perennial crops may be left for more than one season but shall be removed before the plastic

 decomposes. Use of polyvinyl chloride as plastic mulch or row cover is prohibited.

Fully biodegradable films: permitted without removal if they do not contain substances prohibited by par.

 1.4.1 of CAN/CGSB-32.310, Organic Production Systems – General Principles and Management Standards.

In addition there are a number of Standards Interpretation Committee Q and As that I have listed below.

Can you clarify the requirements fir removal of plastic mulch films?

(b) (6) (b) (6)
The annotation for plastic mulches, in table 4.3 PSL, is clearly intended to prohibit the incorporation into

 the soil for any material other than fully biodegradable films compliant with section 1.4.1 (32.310). Where

 there is any risk of contamination, plastic mulch must be removed from the soil. The distinction between

 annual and perennial crops is made on the premise that following an annual crop, tillage will occur in

 preparation for the next year, but this distinction is not essential to fulfilling the intent of the standard,

 which is to avoid contamination of the soil. In situations where the mulch will not be incorporated into the

 soil then it may be left on.

Are bioplastic mulches, made from corn, accepted as “fully biodegradable films” as the term is used in the

 annotation for mulches, table 4.3 of PSL? 

A bioplastic mulch could be accepted as fully biodegradable provided that;

1) The mulch is not made using GMO plant material;

2) There are no substances prohibited under 1.4.1 present.

Does the listing of “fully biodegradable films” in table 4.3 PSL under mulches include films made from

 petroleum products? No. Mulches made using petroleum are not considered to be “fully biodegradable”

 and must be removed from the field and may not be incorporated into the soil.

>>> "McEvoy, Miles - AMS" <Miles.McEvoy@ams.usda.gov> 9/29/2012 7:48 am >>>

Does the Canadian organic standards allow the use of biodegradable plastic mulch? The NOSB will be

 discussing this material in a few weeks and I want to make sure we understand the Canadian

 perspective on the allowance of these materials. Thanks.

Miles V McEvoy

Deputy Administrator

National Organic Program

202-720-3252

This electronic message contains information generated by the USDA solely for the intended recipients.

 Any unauthorized interception of this message or the use or disclosure of the information it contains may

 violate the law and subject the violator to civil or criminal penalties. If you believe you have received this

 message in error, please notify the sender and delete the email immediately.

This electronic message contains information generated by the USDA solely for the intended

recipients. Any unauthorized interception of this message or the use or disclosure of the

information it contains may violate the law and subject the violator to civil or criminal

penalties. If you believe you have received this message in error, please notify the sender and

delete the email immediately.
From: McEvoy, Miles - AMS

To: "Jean Richardson"

Subject: RE: Bio mulch

Date: Wednesday, April 22, 2015 9:26:39 AM

sure

-----Original Message-----

From: Jean Richardson [mailto

Sent: Tuesday, April 21, 2015 2:28 PM

To: McEvoy, Miles - AMS

Subject: Bio mulch

Hi Miles

FYI

Crops subcommittee hopes you will make brief comment on Biomulch in you comments next week Jean

(b) (6)
<image003.gif>

From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Re: BIO and photo

Date: Monday, May 12, 2014 1:43:13 PM

Nice

Miles V McEvoy

Deputy Administrator

USDA National Organic Program

On May 12, 2014, at 9:56 AM, "Jean Richardson" < wrote:

How about

Miles says; " Dr Richardson brings an unusually broad range of expertise and

 experience to the NOSB...." or some such

Jean says "I feel privileged to have been elected by such a diverse group of

 incredibly hard working professional people. We all believe passionately in the

 integrity of the organic label and yet we have different ideas on how to adapt to

 the changing face of organic agriculture, processing and handling as the industry

 expands and the NOP faces changing demands on its resources. My leadership

 style is to build consensus whenever possible and work collaboratively with all

 stakeholder groups and with the NOP in order to ensure sustainable organic

 systems".

On May 12, 2014, at 8:09 AM, McEvoy, Miles - AMS wrote:

Thanks – great photo!

Did you want to include a statement about the NOSB – your goals as the

 incoming chair?

Miles

From: Jean Richardson [mailto:

Sent: Saturday, May 10, 2014 11:05 AM

To: McEvoy, Miles - AMS

Subject: BIO and photo

Hi Miles

The Bio on the NOP website is fine - see below

and here is a recent photo

Hope the photo has enough pixels

Cheers

Jean

<image001.jpg>

(b) (6) (b) (6)
<image004.gif>Be an

Organic

Insider!

<image004.gif>NOP

Homepage

<image004.gif>Consumer

Information

<image004.gif>National

Organic

Standards

Board

<image004.gif>Organic

Standards

<image004.gif>Organic

Certification

&

Accreditation

<image004.gif>Compliance

&

Enforcement

<image004.gif>Conference

Call

Summaries

<image004.gif>Charter

(PDF)

 <image004.gif>Task Forces

 <image004.gif>Archive

<image004.gif>About the

National List

<image004.gif>Current

National List

(eCFR)

<image004.gif>How to File a

Petition

<image004.gif>Petitioned

Substances

List

<image005.gif>

<image006.gif>

<image005.gif>

<image007.gif>

<image005.gif>

<image008.gif>

<image005.gif>

NOSB Members: Jean

 Richardson 

<image002.gif>

Jean Richardson

Consultant and Maple Syrup

Producer | North Ferrisburgh,

VT

Consumer/Public Interest |

January, 2012 – January,

2017

Jean is Professor Emerita,

University of Vermont, where

she taught Environmental

Studies and Environmental

Law. She currently works with

her family to produce certified

organic maple syrup, and is

an independent inspector of

organic farms and processors,

as well as providing

consultation on rural land use

planning and serving as a

Justice of the Peace.

Dr. Richardson’s research

included work on the impact

of long distance transportation

of air pollution on dioxin

uptake in dairy feeds and

milk, and a major rural

development project,

Environmental Partnerships in

Communities (EPIC) which

included considerable

research on pasture

management. The ten year

EPIC project which Jean

directed also provided

extensive technical assistance

to farmers on pasture

management and on

sustainable livestock systems,

encouraging new farmer-run

organizations which continue

today. Lessons learned can be

found in her book

“Partnerships in Communities,

reweaving the fabric of rural

America”, Island Press, 2000.

She also taught as an Adjunct

Professor at the Vermont Law

School, Environmental Law

Center, and in the 1970’s and

80’s she and her first husband

ran an electric fence

franchise, and sheep farm.

Jean has extensive state,

national and international

experience over several

decades, including:

Environmental planning and

policy in the Lake Baikal

region of Russia; A founding

Director of the Institute for

Sustainable Communities,

providing former Soviet Bloc

countries with templates for

environmental policy and law;
Founding Director of the New

England Environmental Policy

Center which now provides

Agricultural Mediation;

Appointed by President

Clinton to the Joint Public

Advisory Committee in the

Commission on Environmental

Cooperation (CEC) in NAFTA

where she took a leadership

role in developing the

language and policy for

Citizen Submissions;

Facilitated establishment of

the Forest Stewardship

Council (FSC) in North

America, and negotiated the

certification standards for the

New England forests;

Appointed by Governor Dean

of Vermont to the State

Environmental Appeals Board

and by Governor Shumlin to

the District Environmental

Commission on which she

currently serves; Provided

expert testimony to the State

Legislature on numerous

occasions, including the

definition of soils which

provides language facilitating

soil protection and

conservation when tracts of

land are being developed.

Education: B.S University of

Newcastle-upon-Tyne,

England, Geography,

Dissertation on agriculture in

the Somerset Lowlands; M.S.

and Ph.D. in Biogeography,

University of Wisconsin,

Madison, Dissertation on the

Domestication of Pecans;

Post- Doctoral Law Clerkship,

State of Vermont.

Jean lives in an old house on a

trout stream surrounded by

sugar maple trees, a small

orchard, berries, vegetable

gardens, perennial beds, and

thousands of daffodils in

spring.

Last Modified

Date: 07/24/2013

This electronic message contains information generated by

 the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or

 disclosure of the information it contains may violate the
 law and subject the violator to civil or criminal penalties.

 If you believe you have received this message in error,

 please notify the sender and delete the email immediately.
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: check in

Date: Thursday, July 16, 2015 9:13:28 AM

8 am OK tomorrow

October 13 and 20 OK with me although it reduces ability of subcommittees to discuss materials pre meeting.

There is still opposition to any webinars - I'll explain tomorrow

Glad you are getting trained!

Cheers

jean

On Jul 16, 2015, at 8:46 AM, McEvoy, Miles - AMS wrote:

> Can we chat at 8 tomorrow rather than 8:30?

> Also - we need to push the public comment webinars into October. I'll explain tomorrow but we are looking at

 Oct. 13 and 20 as the two webinar dates.

> I'm in training today and tomorrow so I apologize in advance if I'm slow at responding.

>

> Best,

>

> Miles V McEvoy

> Deputy Administrator

> USDA National Organic Program
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Automatic reply: check in

Date: Thursday, July 16, 2015 9:13:29 AM

I am out of the office. Please contact Joan Avila at 202-720-3252, joan.avila@ams.usda.gov if

 you need immediate assistance.
From: McEvoy, Miles - AMS

To: Jean Richardson (

Subject: charter amendment

Date: Wednesday, September 24, 2014 5:19:43 PM

The amendment to the NOSB charter is being announced tomorrow. It changes the termination

 clause to state that the committee charter terminates rather than the committee terminates.

Look forward to seeing you tomorrow evening.

Miles

Miles McEvoy

Deputy Administrator

National Organic Program

This electronic message contains information generated by the USDA solely for the intended

 recipients. Any unauthorized interception of this message or the use or disclosure of the

 information it contains may violate the law and subject the violator to civil or criminal

 penalties. If you believe you have received this message in error, please notify the sender and

 delete the email immediately.

(b) (6)
From: Jean Richardson

To: Arsenault, Michelle - AMS; Tracy Favre; Zea Sonnabend; Carmela Beck; Calvin Walker

Cc: McEvoy, Miles - AMS; Brown Rosen, Emily - AMS

Subject: Changes in Subcommittees

Date: Saturday, June 27, 2015 5:03:50 PM

Hi Michelle, Tracy, Zea, Carmela, Emily and Calvin

, please

 remove Nick and Paula from all subcommittees as follows:

Nick: CACS and Materials. Nick is not available for SC calls and will not be attending the September Webinar for

 Public Comments, but he will be attending the October meeting in Vermont.

Paula: Crops, Livestock, Inerts. Paula will most likely not be at the October meeting, and not be available for any

 SC calls.

Zea and Tracy, please reassign all Paula's Sunset and any other materials.

If you would like to discuss this with me just give me a call:

( - land line, -mobile/Text)

Thank you for all your hard work. 

.

Cheers

Jean

(b) (6) (b) (6) (b) (6)

(b) (6)
From: Jean Richardson

To: John Foster; Stone Mac; McEvoy, Miles - AMS

Cc: Arsenault, Michelle - AMS

Subject: Chairs opening comments

Date: Tuesday, October 21, 2014 1:59:32 PM

Hi guys

I am planning on using the Introductions section on Tuesday morning agenda as just that, Introductions of

 members. (especially as we assume a protest).

I would like to make my Chair's very brief Opening Comments before we start the real NOSB part of the week at

 10.50 am after Lisa and before first public comments start. This will be my invocation for civility and working

 together for the good of the whole etc.

Thank you

Jean
From: Jean Richardson

To: Jones Samuel - AMS

Cc: Gregg Stevens; McEvoy Miles - AMS

Subject: Fwd: Certified Organic on VMX

Date: Sunday, August 03, 2014 9:14:05 AM

Hi Sam

The "kitchen table talk" about organics is getting some good coverage. Thought you might enjoy the below e-mail string.

Best Regards,

Jean

Begin forwarded message:

From: Gregg Stevens <gregg@nofavt.org>

Date: July 29, 2014 9:38:01 AM EDT

To: Barbara Richardson <info@nofavt.org>, Caitlin Gildrien <caitlin@nofavt.org>, Enid Wonnacott <enid@nofavt.org>

Cc: "Dave Rogers (uvm)" Jean Richardson <

Subject: FW: Certified Organic on VMX

FYI – We’re racking up the numbers and reaching all the way to North Dakota!

Gregg Stevens

Vermont Organic Farmers

Certification Specialist (Vegetable Fruit Maple and Diversified Operations)

From: Jim.Hering [mailto:jim.hering@comcast.net]

Sent: Tuesday, July 29, 2014 9:28 AM

To: Gregg Stevens

Cc: mmc-tv

Subject: Re: Certified Organic on VMX

Hey Gregg, Congratulations! - Policy Update: Certified Organic has 15 affiliate downloads on the Vermont Media Exchange and 

TelvueConnect Media Exchange (National). Along with Organic Matters, that makes it our most-downloaded program (for MMCTV),

 and is a big number compared to most programs available on the Exchange.

Thanks for all your work on the production, and please pass along our congratulations and thanks also to Dave Rodgers and Dr. 

Richardson.

Here is the affiliate list as of today:

PolicyUpdateCertifiedOrganic "What Does Certified Organic Mean?" 

NOFA-VT policy advisor Dave Rogers 

discusses what it means for a product to be 

"certified organic" with Dr. Jean Richardson,

 National Organic Standards Board Chair.

15

BCTV, RETN,NEAT, LPCTV,ORCA Media,Hudson

Community Television, BEK Communications

Cooperative,CLAREMONT COMMUNITY

TELEVISION INC,GNAT-TV, CATV,Kingdom

Access TV "KATV",GMATV, CVTV,NEKTV,Hardwick TV

Also, you had mentioned you might want to get in touch with the out-of-state affiliates to gauge their interest, let them know about

NOFA and your program offerings, and perhaps ask them to spread the word on their respective local networks

these are the profile listings for the out-of-state affiliates that took it :

Hudson Community Television

Full PEG station and Access Center with a new state of the art facility

19 Kimball Hill Rd

Hudson, NEW HAMPSHIRE 03051

http://www.hudsonctv.com

jmcintosh@hudsonctv.com

BEK Communications Cooperative

(b) (6) (b) (6) (b) (6)
Service provider

200 East Broadway

Steele, ND 58482

http://www.bektel.com

joshh@bektel.coop

CLAREMONT COMMUNITY TELEVISION INC

Claremont Community Television Inc (CCTV)operates PEG access channels 8 and 10 on Claremont Comcast cable. CCTV is a 

501(c)3 non-profit founded in 1999.

111 SOUTH STREET

CLAREMONT, NH 03766

http://claremontv.org

These last two are from Organic Matters, which also pulled a 15:

Littleton Area Television

Governmental - Educational Towns served: Littleton, Lisbon, Bethlehem, Carroll, Monroe, Franconia

159 Oak Hill Ave

Littleton, NH 03561

http://latvchannel2.com

latvchannel2@roadrunner.com

Brookdale Television

Welcome to Brookdale Television

Brookdale Television (BTV) is a non-profit Educational Access Channel operating on the campus of Brookdale Community College,

 Lincroft, NJ. BTV can be viewed on Comcast channel 21 and Verizon FIOS channel 46 throughout central New Jersey, 24 hours a 

day 7 days a week. BTV's mission is to present quality educational programs,that informs and inspires its viewing audience.

BTV is your local station for diverse local programming and so much more. During our program breaks learn about the happenings 

at Brookdale Community College . On "Brookdale Newsmakers", take just five minutes to learn about news and events on 

Brookdale's campus and in the Monmouth County community. Brookdale students interview Brookdale adminstrators and faculty 

about up-coming events or new additions to the Brookdale academic line-up. Throughout our broadcast day you can listen to 

personal and compelling testmonies from students, alumni and faculty reflecting on why they made Brookdale Community College 

their first choice.

765 Newman Springs Road

Lincroft, NJ 07738

http://www.brookdalecc.edu/community/brookdale-television/

lconcar@brookdalecc.edu

(b) (6)
Jim Hering

Channel Manager

MMCTV-15

Richmond, Jericho and

Underhill, VT

From: gregg@nofavt.org

To: "mmc-tv" 

Cc: "jim hering" 

Sent: Monday, July 28, 2014 1:59:48 PM

Subject: RE: New Vermont Farmers Market video on VMX

Thanks!

We’ve got our “Google analytics” monitoring the farmers market directory website – we’ll see if it has an effect!

Any updates on the # of out-of-state downloads for the Organic Certification Policy Update?

Gregg Stevens

Vermont Organic Farmers

Certification Specialist (Vegetable Fruit Maple and Diversified Operations)

From:

Sent: Monday, July 28, 2014 1:57 PM

To: Gregg Stevens

Subject: Re: New Vermont Farmers Market video on VMX

It's a really great video, Gregg, we are very proud.

From: "Stevens, Gregg" <gregg@nofavt.org>

To: "Stevens, Gregg" <gregg@nofavt.org>

Sent: Monday, July 28, 2014 1:55:58 PM

Subject: New Vermont Farmers Market video on VMX

Hello!

A new short video (2:45) from the Vermont Farmers' Market Association shows how to find and use an online farmers' market directory that

allows shoppers to search over 70 Vermont farmers' markets by season, county, day of the week, and whether they accept debit or EBT cards.

The various benefits of shopping at farmers markets, such as the diversity of goods available and the benefits to the local economy are also

discussed.

This video has no “kill date” and is relevant year round as there are farmers markets throughout Vermont in all seasons.

Look for:

“FindYourVTFarmersMarket.mpg”

Thanks!

Gregg Stevens

Vermont Organic Farmers

Certification Specialist (Vegetable Fruit Maple and Diversified Operations)

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Automatic reply: Certified Organic on VMX

Date: Sunday, August 03, 2014 9:14:06 AM

I am on leave through August 8. Please contact Desiree Lee at 202-720-3252,

 desiree.lee@ams.usda.gov if you need immediate assistance.

This electronic message contains information generated by the USDA solely for the intended

 recipients. Any unauthorized interception of this message or the use or disclosure of the

 information it contains may violate the law and subject the violator to civil or criminal

 penalties. If you believe you have received this message in error, please notify the sender and

 delete the email immediately.
From: Jean Richardson

To: Tracy Favre; Tom Chapman; Colehour Bondera; Mac Stone (mac@elmwoodstockfarm.com); Nick Maravell;

Jennifer Taylor; Francis Thicke; Carmela Beck; Lisa de Lima; Paula Daniels; Ashely Swaffar; Calvin Walker; Zea

 Sonnabend

Cc: Arsenault, Michelle - AMS; Brown Rosen, Emily - AMS; McEvoy, Miles - AMS

Subject: Candi Austin address

Date: Monday, May 04, 2015 12:37:06 PM

(b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: call this am?

Date: Monday, March 02, 2015 8:13:57 AM

Hi Miles

I had us down for a call at 8 am this morning?

I am around if you want to call.

Jean

(b) (6)
From: Jean Richardson

To: Tucker, Jennifer - AMS

Cc: John Foster (JFoster@ebfarm.com); Mac Stone; McEvoy, Miles - AMS; Bailey, Melissa - AMS

Subject: Re: Call Next Week?

Date: Thursday, January 23, 2014 9:20:16 AM

Hi Jenny

I can take a conference call on Tuesday Jan 28 any time between 10.30 and noon.

Thursday I am doing an all day processing inspection and am not available at all..

20 below here again!

Jean

On Jan 22, 2014, at 6:23 PM, Tucker, Jennifer - AMS wrote:

Hi Mac and John and Jean – We were hoping to have a call with you three next week to

 talk about the NOSB training – Mac and John and Chair and Vice Chair, and Jean as PDS

 Chair. Is there any way to make sometime next Tues between 1030-Noon, or Thurs 

1030-1230 work?

Hope you are all well -

Jenny

---------------------------------------

Jennifer Tucker, Ph.D.

Associate Deputy Administrator

USDA National Organic Program

1400 Independence Ave SW; Room 2642 (Stop 0268)

Washington, DC 20250-0268

Phone: (202) 720-3252

Jennifer.Tucker@ams.usda.gov

This electronic message contains information generated by the USDA 

solely for the intended recipients. Any unauthorized interception of 

this message or the use or disclosure of the information it contains 

may violate the law and subject the violator to civil or criminal 

penalties. If you believe you have received this message in error, 

please notify the sender and delete the email immediately.
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: Call Monday

Date: Friday, February 20, 2015 8:13:18 AM

yes Monday at 8 works for me.

On Feb 20, 2015, at 6:58 AM, McEvoy, Miles - AMS wrote:

> I'm on a plane this morning to the aquaculture conference. Can we talk Monday morning at 8?

>

> Miles V McEvoy

> Deputy Administrator

> USDA National Organic Program

>

>

>

>

> This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.
From: McEvoy, Miles - AMS

To: "Jean Richardson"

Subject: RE: Call at 8.30?

Date: Friday, June 26, 2015 7:56:21 AM

Yes, talk with you at 8:30.

Miles

-----Original Message-----

From: Jean Richardson [mailto

Sent: Friday, June 26, 2015 6:15 AM

To: McEvoy, Miles - AMS

Subject: Call at 8.30?

Hi Miles

can you call me on my cell phone this morning? I will be at the University to give a talk to a group

 from Ukraine interested in NOP Organic Certification.

NOC -Abby Youngblood- called me last night at 9 pm! all wound up over the webinars for early public comment.

 Wants a conference call between you me and Anne Alonzo and her and Steve Etka about it! We talked for a long

 while last night.

and we should chat about a couple of other items Thank you jean

(b) (6) (b) (6)
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: call

Date: Friday, July 11, 2014 8:20:44 AM

I’m not able to call you this morning. Talk to you this afternoon.

Best,

Miles McEvoy

Deputy Administrator

National Organic Program

This electronic message contains information generated by the USDA solely for the intended

 recipients. Any unauthorized interception of this message or the use or disclosure of the

 information it contains may violate the law and subject the violator to civil or criminal

 penalties. If you believe you have received this message in error, please notify the sender and

 delete the email immediately.
From: Jean Richardson

To: McEvoy, Miles - AMS; Carmela Beck; John Foster

Cc: Arsenault, Michelle - AMS

Subject: CACS-Peer review

Date: Tuesday, December 16, 2014 10:34:32 AM

Hi Miles

Has the peer review document been added officially to the CACS Work Agenda list? I do not see it there.

Will this be voted on?

Thanks Jean
From: Jean Richardson

To: Lisa deLima

Cc: Carmela Beck; Nick Maravell; Mac Stone; Jennifer Taylor; Tom Chapman; Brown Rosen, Emily - AMS; McEvoy,

 Miles - AMS; Arsenault, Michelle - AMS; Tracy Favre; Francis Thicke

Subject: Re: CACS Soils Document

Date: Wednesday, July 22, 2015 1:02:18 PM

Hi Lisa

I was talking with Tracy about this yesterday, and she agreed that she had really wanted to provide input to this soils

 work based on her considerable experience with soils an other monitoring programs while at Holistic Resource

 Management, and Francis, who has a strong soils background, really wants to give input. Sunset has dominated out

 work in recent months, so if we just accumulate what we have to date, as you and Carmela stated, and you give a

 simple report for the Fall meeting, that would save us time at the meeting and by Fall both Francis and Tracy will

 have time to provide input.

Does that seem to make sense?

Thank you Jean

On Jul 22, 2015, at 12:51 PM, Lisa deLima wrote:

> Hi,

>

> I’m open to going in either direction. After the last call, Carmela and I spoke about me updating the document

 before our meeting on 8/11 to reflect some of the main points that Lindsay raised on the call:

>

> 1) Finding a more appropriate tool to recommend in place of our recommendation of Section Two of Cap 138

> 2) Recommend compliance with Tolerable levels instead of HELC, so that we don’t have two groups within

 USDA using different standards.

>

> Our misunderstanding of HELC vs Tolerable levels was definitely an opener to the fact that if we are going to

 recommend specifics tools and levels, we want to be working very closely with NRCS. Also, if we decide to pursue

 a more technical and detailed document I would definitely like additional help from the subcommittee as this topic

 overall is not my realm of expertise :-)

>

> I’m on vacation starting tomorrow and will be back in the office on 8/3. I look forward to hearing other members

 thoughts on this and regardless I will update the document when I return and get it out before our next meeting.

>

> Thanks,

> Lisa

>

>

>> On Jul 19, 2015, at 11:16 AM, Jean Richardson < wrote:

>>

>> Hi CACS

>> Listening to the conversation on the call last week with the NRCS staff person I realized that I am still not sure

 we are asking the right questions or that we have enough public comment to put out a Proposal on Soils for this

 meeting.

>> We need a detailed document which would provide enough information and public comment from a wide range

 of stakeholders to allow the NOP to write useful Guidance.

>>

>> As Lisa and Carmela have stated the public comment we received was "all over the place".

>> Most of us have been too busy with Sunset to spend time on this really important topic and others on the

 subcommittee have not been able to provide any input, given their busy lives.

>>

>> I have no question that Certifiers need some NOP Guidance on how to assess soils, and erosion, especially in

 some areas of the country with high risk soils. It is also clear from the limited public comment we have received

 that there is not a consistent approach to soils or soil erosion potential amongst certifiers.

(b) (6)
>>

>> What is the implied or actual definition of Soil Erosion which NOP uses?

>>

>> On the NRCS side there is a desire not to have any " uncovered soil", which provides interesting challenges for

 crop producers!! NRCS has some excellent programs which producers could use to offset costs to manage and

 prevent soil erosion, control water flow or runoff, control livestock access to water, control erosion on livestock

 lanes between pastures, prevent or reduce erosion and environmental degredation etc. On the other hand we also

 know that the manner in which NRCS is interpreted and implemented varies between states and regions. Yet

 building a partnership with NRCS seems like a good idea.

>>

>> So I wonder if we should just do a "Report" at this Fall meeting. Say what we have been doing, and say that we

 may come back at the Spring meeting with a Proposal.

>>

>> Just a thought - What do you think?

>> Cheers

>> Jean

>>

>>

>>

>>

>
From: Jean Richardson

To: McEvoy, Miles - AMS; Carmela Beck; John Foster

Cc: Arsenault, Michelle - AMS

Subject: CACS Peer Review

Date: Tuesday, December 16, 2014 10:38:25 AM

Sorry, found it on the NOP website recent posting. Peer Review is listed. Jean
From: Jean Richardson

To: Arsenault, Michelle - AMS; McEvoy, Miles - AMS

Subject: Board Dinner Wednesday?

Date: Friday, April 10, 2015 1:54:14 PM

 Harolds suggestion to let Monday go late with comments and move dinner till Wednesday if at all possible makes

sense

Sorry to give you additional work Michelle.

.
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Biodiversity guidance

Date: Thursday, March 26, 2015 3:20:23 PM

Hi Miles

I am at IOIA and we had an excellent presentation on the need for songbird protection, with all the connected

 impacts on the associated food chain

Many noted that the proposed Rule does not reference birds. But time for response is over.

I am asked to ask that you add some songbird language - which of course links nicely with our work with NRCS and

 all their programs, like WHIP

Cheers

Jean
From: Jean Richardson

To: Zea Sonnabend; Tucker, Jennifer - AMS; McEvoy, Miles - AMS

Subject: Biodegradeable mulch

Date: Tuesday, January 14, 2014 10:44:52 AM

Hi folks

just another reminder that farmers are STILL waiting for the biodegradable mulch.

Below is a recent excerpt form a winter newsletter circulated via Verne Grubinger, University Extension. The

 comments cover all of New England and New York, from Maine to Rhode Island. Many farmers send in short

 reports. Here is one:

Jean

(Huntington) Winter wholesale and retail markets have been steady or up

slightly; the problem is we're running out of produce. After a few nights in

the -17F range, kale in high tunnel (double poly w/inflation, no row cover,

gable vent open except on very cold nights) still looks great, though most

the harvestable leaves have been picked at this point. Winter squash stored

better than expected, though not as well as in an ideal season. Overall I'm

pleased with how well things have kept, given the disease pressure that was

out in the fields this summer. We are expanding our climate-controlled

storage capacity this winter to help alleviate the fall space crunch and

improve packing house work flow. I'm a little disappointed that organic

producers are going to have to go through yet another season without

biodegradable plastic mulch; as much as I like having a dumpster, filling it

up weekly with plastic mulch during August and September is a chore I would

love to do without.
From: Jean Richardson

To: McEvoy, Miles - AMS; Brown Rosen, Emily - AMS

Subject: Fwd: Biodegradable mulch film

Date: Friday, October 10, 2014 12:06:40 PM

Hi Miles and Emily

Just an FYI on getting getting specificity of which biodegradable mulch will work.

Thanks Jean

Gregg Stevens

Vermont Organic Farmers

Certification Specialist (Vegetable, Fruit, Maple, and Diversified Operations)

From: Lindsay Fernandez-Salvador [mailto:lindsayfs@omri.org]

Sent: Friday, October 10, 2014 11:48 AM

To: Gregg Stevens

Subject: RE: Biodegradable mulch film

Hi Gregg,

We aren’t working on one but we are in conversations with the main supplier of them

to start reviewing them soon.  Just a heads up – these are going to be difficult to review

without some more clarification from the NOP.

Lindsay Fernandez-Salvador

Technical Director

Organic Materials Review Institute (OMRI)

P.O. Box 11558 • Eugene OR • 97440-3758

Office 541.343.7600 x117• Fax 541.343.8971

lindsayfs@omri.org • www.omri.org

OMRI now reviews products to the Canadian Organic Standards. Learn more at

www.omri.org/omri-canada.

CONFIDENTIALITY NOTICE

This email, including any attachment, may contain information that is confidential for the use of the

intended recipient only. Any review, reliance or distribution by others or forwarding without express

permission is strictly prohibited. If you are not the intended recipient, please contact the sender and

delete all copies. Information submitted to OMRI is considered confidential in accordance with the

OMRI Policy Manual §1.6.

From: Gregg Stevens [mailto:gregg@nofavt.org]

Sent: Friday, October 10, 2014 8:10 AM

To: Lindsay Fernandez-Salvador

Subject: Biodegradable mulch film

(b) (6)
Hello!

I assume you have gotten a lot of questions about this, but I’m wondering if OMRI is in

the process of reviewing any biodegradable biobased mulch films...I’d like to be able to

tell our growers if you are working on at least one so I don’t need to initiate one...

Thanks!

Gregg Stevens

Vermont Organic Farmers

Certification Specialist (Vegetable, Fruit, Maple, and Diversified Operations)

(b) (6)
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Automatic reply: Biodegradable mulch film

Date: Friday, October 10, 2014 12:06:41 PM

I am out of the office. Please contact Desiree Lee at 202-720-3252, desiree.lee@ams.usda.gov

 if you need immediate assistance.

This electronic message contains information generated by the USDA solely for the intended

 recipients. Any unauthorized interception of this message or the use or disclosure of the

 information it contains may violate the law and subject the violator to civil or criminal

 penalties. If you believe you have received this message in error, please notify the sender and

 delete the email immediately.
From: McEvoy, Miles - AMS

To:

Cc: Rakola, Betsy - OSEC; Lewis, Paul I - AMS; Jean Richardson

Subject: Re: Conference call

Date: Thursday, July 02, 2015 6:15:41 AM

No trouble at all and Happy 4th to you as well!

Miles V McEvoy

Deputy Administrator

USDA National Organic Program

On Jul 2, 2015, at 6:14 AM, "NODPA" < wrote:

I’ll let you know

Happy Independence Day from those troublesome Brits! J

From: McEvoy, Miles - AMS [mailto:Miles.McEvoy@ams.usda.gov] 

Sent: Thursday, July 2, 2015 6:13 AM

To:

Cc: Rakola, Betsy - OSEC; Lewis, Paul I - AMS; Jean Richardson

Subject: Re: Conference call

July 10

Miles V McEvoy

Deputy Administrator

USDA National Organic Program

On Jul 2, 2015, at 6:11 AM, "NODPA" < wrote:

Hi Miles

Is that tomorrow 7/3/15 or 7/10/15?

Ed

From: McEvoy, Miles - AMS [mailto:Miles.McEvoy@ams.usda.gov] 

Sent: Wednesday, July 1, 2015 7:37 PM

To:

Cc: Rakola, Betsy - OSEC; Lewis, Paul I - AMS; Jean Richardson

Subject: Conference call

Hi Ed,

Could we set up a conference call to discuss a few items? I’d like to

 discuss ideas for public comments at the fall NOSB meeting, ionizing

 radiation, and introduce NOP’s new Standards Director, Dr. Paul Lewis.

 I’m available next Friday afternoon at 3 pm Eastern time. Is there any

 other NODPA folks you’d like to invite?

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Miles McEvoy

Deputy Administrator

National Organic Program

Could we set up a conference call to discuss a few items? I’d like to discuss ideas for public

 comments at the fall NOSB meeting, ionizing radiation, and introduce NOP’s new Standards

 Director, Dr. Paul Lewis. I’m available next Friday afternoon at 3 pm Eastern time. Is there any other

 NODPA folks you’d like to invite?

Miles McEvoy

Deputy Administrator

National Organic Program
From: McEvoy, Miles - AMS

To:

Cc: Rakola, Betsy - OSEC; Lewis, Paul I - AMS; "Jean Richardson"

Subject: RE: Conference call

Date: Sunday, July 12, 2015 6:16:15 PM

Thanks Ed and thanks for all you do.

Organic milk, cheese, and milk powder could be imported if it meets the terms of the arrangement –

 Swiss organic producers would have to use no antibiotics in their production system to be eligible

 for their milk and milk products to be traded under the arrangement. The Swiss certifier would have

 to verify that no antibiotics were used by any of the organic producers in the pool. My

 understanding is there are no current producers or organic milk pools that comply with that

 requirement but there are Swiss organic cheese producers that may stop using antibiotics so they

 can participate in trade with the U.S.

Miles

Miles V McEvoy

Deputy Administrator

Agricultural Marketing Service

National Organic Program

From: NODPA [mailto:

Sent: Saturday, July 11, 2015 11:01 AM

To: McEvoy, Miles - AMS

Cc: Rakola, Betsy - OSEC; Lewis, Paul I - AMS; 'Jean Richardson'

Subject: RE: Conference call

Thank you all for the opportunity to talk over the phone and for all your efforts to protect the

 integrity of the Organic label in the marketplace.

One question on the trade deal with Switzerland, you said that no dairy products could be imported

 as they use antibiotics. The OTA press release said the following:

However, the fact that Switzerland is not a part of the U.S.-EU equivalency agreement since it is not a

 member of the EU, has been a bottleneck in organic trade between the U.S, the EU and Switzerland.

 Swiss organic food makers often source organic ingredients from the EU, which are then processed

 and sent to the United States, and food processors in the EU and the U.S. frequently use Swiss

 organic ingredients, such as organic chocolate, organic milk powder, or organic dried mustard. The

 new arrangement will facilitate those transactions and open new opportunities for organic farmers

 and processors on both sides of the Atlantic.

Is this correct as milk powder is originally milk

Thanks for any clarification

Ed

Ed Maltby

(b) (6) (b) (6)

Fax: 866-554-9483

Petition against Organic Check-off: https://nofa.wufoo.com/forms/online-petition-organiccheckoff-program/

The other side to the organic check-off: www.noorganiccheckoff.com

Website: www.nodpa.com or www.organicmilk.org

Please support NODPA's efforts! http://www.nodpa.com/donate.shtml

Find us on Facebook! www.facebook.com/pages/Organic-Dairy-Farmers/237021992104?

ref=hl#

From: McEvoy, Miles - AMS [mailto:Miles.McEvoy@ams.usda.gov] 

Sent: Wednesday, July 01, 2015 7:37 PM

To:

Cc: Rakola, Betsy - OSEC; Lewis, Paul I - AMS; Jean Richardson

Subject: Conference call

Hi Ed,

Could we set up a conference call to discuss a few items? I’d like to discuss ideas for public

 comments at the fall NOSB meeting, ionizing radiation, and introduce NOP’s new Standards

 Director, Dr. Paul Lewis. I’m available next Friday afternoon at 3 pm Eastern time. Is there any other

 NODPA folks you’d like to invite?

Miles McEvoy

Deputy Administrator

National Organic Program

(b) (6)
From: Jean Richardson

To: Brines, Lisa - AMS; McEvoy, Miles - AMS

Subject: decisive votes

Date: Sunday, October 26, 2014 5:35:58 PM

Hi Lisa and Miles

OFPA requires 2/3rds "for any motion" (OFPA Section 2119 or 6518 USC)

Roberts Rules of course varies

We do a combination?

Should we rule ALL at 2/3?

General practice appears to be a mix

Let me know ASAP

Thank you

Jean
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Automatic reply: DC next week

Date: Thursday, May 15, 2014 7:27:37 PM

I am out of the office. Please contact Joan Avila at 202-720-3252, joan.avila@ams.usda.gov if

 you need immediate assistance.

This electronic message contains information generated by the USDA solely for the intended

 recipients. Any unauthorized interception of this message or the use or disclosure of the

 information it contains may violate the law and subject the violator to civil or criminal

 penalties. If you believe you have received this message in error, please notify the sender and

 delete the email immediately.
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Re: DC next week

Date: Friday, May 16, 2014 6:58:02 AM

There may be an OFRF dinner on Tuesday as well - I'll see what I can find out.

Miles V McEvoy

Deputy Administrator

USDA National Organic Program

> On May 15, 2014, at 8:23 PM, "Jean Richardson" < wrote:

>

> OK, just booked my plane. Arriving DC at 7.pm on Tuesday May 20 - Staying at Phoenix Park hotel (I think that

 is where Gwendolyn booked me in). At OTA meeting Wednesday, including evening reception, on Capital Hill

 Thursday, meeting with Leahy, Sanders and Welch! (Think that is what is scheduled. I will verify it all tomorrow)

> Can we do light dinner at 7.30 pm Tuesday? If it would be helpful to meet with Anne let's do it if she can.

>

>

>> On May 15, 2014, at 7:33 PM, McEvoy, Miles - AMS wrote:

>>

>> Cool. Let's try to have dinner. Should I set something up with Anne?

>>

>> Miles V McEvoy

>> Deputy Administrator

>> USDA National Organic Program

>>

>>> On May 15, 2014, at 7:27 PM, "Jean Richardson" < wrote:

>>>

>>> Hi Miles

>>> OTA invited me to come to DC for their policy days, Wednesday and Thursday. Just booking hotel and planes

 now

>>> Jean

>>

>>

>>

>>

>> This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

>>

>

>

(b) (6) (b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: DC next week

Date: Friday, May 16, 2014 9:33:27 AM

Whatever you think most useful

Jean

On May 16, 2014, at 6:57 AM, McEvoy, Miles - AMS wrote:

> Yes, that should work. Somewhere near your hotel. I'll find a place. Others? Mark Lipson?

>

> Miles V McEvoy

> Deputy Administrator

> USDA National Organic Program

>

>> On May 15, 2014, at 8:23 PM, "Jean Richardson" < wrote:

>>

>> OK, just booked my plane. Arriving DC at 7.pm on Tuesday May 20 - Staying at Phoenix Park hotel (I think that

 is where Gwendolyn booked me in). At OTA meeting Wednesday, including evening reception, on Capital Hill

 Thursday, meeting with Leahy, Sanders and Welch! (Think that is what is scheduled. I will verify it all tomorrow)

>> Can we do light dinner at 7.30 pm Tuesday? If it would be helpful to meet with Anne let's do it if she can.

>>

>>

>>> On May 15, 2014, at 7:33 PM, McEvoy, Miles - AMS wrote:

>>>

>>> Cool. Let's try to have dinner. Should I set something up with Anne?

>>>

>>> Miles V McEvoy

>>> Deputy Administrator

>>> USDA National Organic Program

>>>

>>>> On May 15, 2014, at 7:27 PM, "Jean Richardson" < wrote:

>>>>

>>>> Hi Miles

>>>> OTA invited me to come to DC for their policy days, Wednesday and Thursday. Just booking hotel and planes

 now

>>>> Jean

>>>

>>>

>>>

>>>

>>> This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

>>>

>>

>>

>

(b) (6) (b) (6)
From: McEvoy, Miles - AMS

To: Tracy Favre; Richardson Jean; Stone Mac

Subject: RE: Dallas Prometheus Project - no gmo"s in usda organics

Date: Monday, May 12, 2014 5:20:56 PM

Short answer - There is no loophole. The video clip is an incorrect analysis of the USDA organic

 regulations.

GMO seeds are prohibited in organic production.

Some additional information here –

http://www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELPRDC5090396

http://www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELPRDC5103060

I’ll reach out to Deborah Murphy as well.

Miles V. McEvoy

Deputy Administrator

National Organic Program

1400 Independence Ave. SW

Washington, DC 20250-0268

202-720-3252

www.ams.usda.gov/nop

Organic Integrity from Farm to Table, Consumers Trust the Organic Label

From: Tracy Favre [mailto:tfavre@favrehouse.com] 

Sent: Monday, May 12, 2014 11:02 AM

To: McEvoy, Miles - AMS; Richardson Jean; Stone Mac

Subject: Fwd: Dallas Prometheus Project - no gmo's in usda organics

Hi folks,

I was at a cheese making class this weekend and at dinner one night a woman approached me

asking about "the loopholes" that allow GMO's into organics. She and I had a fairly lengthly

conversation and as a result, she forwarded to me the link for a YouTube video that's making

the rounds of the clean food advocacy groups... She's asked if I would be willing to attend one

of her group's meetings to discuss the issue. I watched the video today and you can see my

initial response to her below.

If you can find the time, I'd appreciate you giving me your feedback. My initial reaction is

that this is one guy twisting some things around, particularly with his basic premise that GMO

seeds could be used when organic seeds are not available. (just because a seed is not organic

does not mean it's then a GMO seed...)

Miles, you in particular would be in the position of saying whether GMO seeds would be

allowed as "a loophole". I know you're swamped with this kind of thing and if there's

someone else you'd rather I reach out to, let me know.
Thanks and appreciate your comments. Any questions, please call.

Tracy

Begin forwarded message:

From: Tracy Favre <tfavre@favrehouse.com>

Subject: Re: Dallas Prometheus Project - no gmo's in usda organics

Date: May 12, 2014 9:55:09 AM CDT

To: Deborah Murphy <

Hi Deb,

As I mentioned the other evening, we had seen some public comments that came in as a run up

to our recent board meeting in San Antonio that mentioned "no GMO's in organic foods" but I

didn't know where it was coming from, as we are all very clear that GMO's are not allowed as

part of the National Organic Program (NOP).

I watched the video today and had some consternation about some of his initial conclusions,

but before I offer any input, I'd like to forward this along to Miles McEvoy, Deputy

Administrator of the NOP and the current and recent past chairs of the National Organic

Standards Board (NOSB) for their feedback.

The current board chair is a certified organic inspector and is heavily involved with working to

provide updated definitions for "Excluded Methods" as we all agree the term is ambiguous.

 The outgoing board chair was until about 2 years ago, head of the Certified Organic Program

for the state of Kentucky and works closely with certifying agencies. Both should have some

unique insights into the comments the narrator of the video expresses.

I'll stay in touch and give some feedback after I talk with them. Thanks for passing this along!

Tracy Favre

On May 11, 2014, at 6:11 PM, Deborah Murphy wrote:

Hello Tracy -

It was very good to meet you at the dinner last night. I bet you guys are just finishing up your cheese

 making classes. Such a great group of people.

I could have talked with you all night about this! I want to thank you in advance for viewing this video -

 and giving your comments or opinions. There is no rush of course, it's about a half hour long. It could

 be this is a totally bogus document- or it could be a document from a different area of the USDA - I don't

 know but to use one of your words....the commentary is most certainly "inflammatory" and if you know for

 sure this is either misconstrued or otherwise, I will share that news with our team of educators. I

(b) (6) (b) (6)
 immediately wrote to USDA last week when I saw this, asking them for more transparency and to

 certainly "close the loopholes" and that it's bad enough that we don't have labeling in this country. Oh I

 do go on....

We all work in our paying jobs and it's hard to find time to uncover the backstory on "who is saying it, and

 why?" - but this is something important to us at Dallas Pro Pro. We need to get the facts straight and I

 feel like our meeting was kismet! The local person for GMO Free USA also joins our meetings (they did

 the Kellogg's boycott push which was somewhat successful in getting Kelloggs to make a few changes) -

 as well as the TX Honeybee Guild (Susan and Brandon Pollard) who educate on honeybees, including

 their perilous situation, exacerbated with GMO. If this idea meets with your approval, I'm happy to share

 your thoughts and concerns with these other groups. We would also love to have you attend one of our

 meetings. There is a bit of hiatus over the summer months (4th of July for instance is "first Saturday")-

 but so you know, we meet the "first Saturday" of every month, at 3pm at Park Cities Yoga which is on

 Royal Ln, between Dallas N. Tollway and Preston Rd. 

Jeffry Farrell (our founder and owner of Park Cities Yoga) has wanted to do something for over a year

 now and maybe we can make it happen in 2015. We'd like to create a "Food Freedom Picnic" - taking

 place around July 4th 2015. Hey maybe USDA Organics might be interested too!

here is the video in question. 

https://www.youtube.com/watch?v=2tNX6uDorVg&feature=youtu.be

Tracy - thank you in advance for your time and your thoughts!

Sincerely,

Deb Murphy

This electronic message contains information generated by the USDA solely for the intended

recipients. Any unauthorized interception of this message or the use or disclosure of the

information it contains may violate the law and subject the violator to civil or criminal

penalties. If you believe you have received this message in error, please notify the sender and

delete the email immediately.

(b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: couple of things

Date: Friday, August 22, 2014 10:13:31 AM

Yes we will need more time for handling I agree

And yes lets finish public comment on wednesday.

Having a great vacation!

best, Jean

On Aug 20, 2014, at 5:01 PM, McEvoy, Miles - AMS wrote:

Hi Jean – Hope you are enjoying your vacation. Couple of things -

1. I’ll be traveling Friday and you are on vacation. Let’s skip this week’s meeting. 

Talk next week.

2. I’d like to review proposed October agenda with you. I think we need more 

time for handling. Could we finish public comments on Wednesday and leave 

Thursday for SCs and finishing board work?

Best, Miles

Miles McEvoy

Deputy Administrator

National Organic Program

This electronic message contains information generated by the USDA 

solely for the intended recipients. Any unauthorized interception of this 

message or the use or disclosure of the information it contains may violate

 the law and subject the violator to civil or criminal penalties. If you believe 

you have received this message in error, please notify the sender and 

delete the email immediately.
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Automatic reply: couple of things

Date: Friday, August 22, 2014 10:13:31 AM

I am out of the office. Please contact Desiree Lee at 202-720-3252, desiree.lee@ams.usda.gov

 if you need immediate assistance.

This electronic message contains information generated by the USDA solely for the intended

 recipients. Any unauthorized interception of this message or the use or disclosure of the

 information it contains may violate the law and subject the violator to civil or criminal

 penalties. If you believe you have received this message in error, please notify the sender and

 delete the email immediately.
From: McEvoy, Miles - AMS

To: "Zea Sonnabend"

Cc: Brown Rosen, Emily - AMS; "Jean Richardson"; "Colehour Bondera (colemel@kanalanifarm.org)"

Subject: RE: Contaminated Input Plan report

Date: Tuesday, March 03, 2015 10:24:04 AM

Ok. It’s up to you and the Crops subcommittee. I’d request that the subcommittee take another look

 at the report and see if this is ready for prime time.

I think the report contains some important concepts. I’m just concerned that as written it is

 confusing and will not add value to this topic.

Miles

Miles McEvoy

Deputy Administrator

National Organic Program

From: Zea Sonnabend [mailto:zea@well.com] 

Sent: Monday, March 02, 2015 4:37 PM

To: McEvoy, Miles - AMS

Cc: Brown Rosen, Emily - AMS; 'Jean Richardson'; 'Colehour Bondera (colemel@kanalanifarm.org)'

Subject: Re: Contaminated Input Plan report

Hi Miles,

The subcommittee did approve this as a report, which is meant to mean that the points you

raise are being investigated but not necessarily avenues that will be pursued. The phrase about

commenting is only in there because we know people will comment on a report anyway.

We're not asking any special questions in there so it is not a discussion doc.

The table embedding thing is me not knowing how to do it right (get an Excel spreadsheet into

the word document) and I asked Michelle and Emily to fix it but I guess that was

misunderstood. The spreadsheet table should just be like an appendix to the report as an

example of structure, and then the attachment is not necessary.

I did not go through it with as fine a tooth comb as you seem to be doing, because as a report,

it is just meant to outline some work in progress. If you think the language is not sufficient at

this point, we can do as you suggest with Colehour giving an oral report while he and the

subcommittee proceed to flesh some of the details out more.

Regards,

Zea

On Mar 2, 2015, at 11:56 AM, McEvoy, Miles - AMS wrote:

Hi Zea - I just read the Contaminated Input Plan report. It is confusing. It's a report but it is asking for

 public comment? There are two tables - one attached and one embedded - that have the same
 information.

The report has some good concepts but doesn't hold together. Did the subcommittee approve this

 report? It suggests that there should be certification for avoiding contaminants but doesn’t explain

 what type of certification is needed? Is it referring to organic certification? For inputs? What does it

 mean when it says “ask farmer?” Ask the farmer what? Whether these substances were used or

 not? It seems to imply that the use of GMO grain for conventional dairy manure may be an issue.

 How would a veterinarian know whether drugs given to livestock were persistent in manure?

Seems like Colehour could provide an oral report in April and clean this report up for the fall meeting

 especially if the subcommittee wants to request public comments.

Miles McEvoy

Deputy Administrator

National Organic Program

This electronic message contains information generated by the USDA solely for the

 intended recipients. Any unauthorized interception of this message or the use or

 disclosure of the information it contains may violate the law and subject the

 violator to civil or criminal penalties. If you believe you have received this message

 in error, please notify the sender and delete the email immediately.
From: Jean Richardson

To: McEvoy, Miles - AMS

Cc: Carmela Beck

Subject: Re: Consistency amongst ACA"s

Date: Thursday, March 26, 2015 6:11:15 PM

Quite the response!

Yes, we have many specifics. This is not a new issue. But the CACS has never looked at this. If we took it up as a

 topic we could accumulate that information and thus educate as we worked on it.

Jean

On Mar 26, 2015, at 6:00 PM, McEvoy, Miles - AMS wrote:

> Sure - one rule to rule them all and in the darkness bind them.

> Try to get specific examples. We know we need more consistency on OSPs, inspection reports, certificates. What

 else?

>

> Miles

>

> -----Original Message-----

> From: Jean Richardson [mailto

> Sent: Thursday, March 26, 2015 5:58 PM

> To: McEvoy, Miles - AMS

> Cc: Carmela Beck

> Subject: Consistency amongst ACA's

>

> Hi Miles

> I am at IOIA advanced training and one of the issues coming up over and over again is the lack of consistency

 between certifiers.

> Many inspectors inspect for many certifiers.

> I am not allowed to attend ACA meetings or be on their list serv. But You attend their meetings .

> Do you think it is time to add this to the CACS Work Agenda as a topic?

> Thank you

> Jean

>

(b) (6)
From: Jean Richardson

To: Harold Austin

Cc: tchapman@clifbar.com; Nick Maravell; Carmela Beck; Mac Stone; Tracy Favre; Jennifer

Taylor; Francis Thicke; COLEHOUR BONDERA; lisa.delima@momsorganicmarket.com; 

Ashley.swaffar@vitalfarms.com; Zea Sonnabend; Brown Rosen, Emily - AMS; Arsenault, Michelle - AMS; McEvoy,

Miles - AMS

Subject: Re: Congrats

Date: Tuesday, August 25, 2015 3:03:08 PM

Yes indeed. Good job Tom for keeping us in line and on time. Great team work on the 

subcommittee. Now we just have to synthesize our year's work into 7 hours and 30 minutes on

 October 28 before dinner!

Jean

On Aug 25, 2015, at 2:49 PM, Harold Austin wrote:

Everyone,

Congratulations on a truly amazing accomplishment.....wrapping up the Sunset 2017 

Materials Review! Whew.....! What a tremendous sigh of relief we can now all have...well 

that is until it is time to prep this workload plus public comment recap for the meeting. But,

 why ruin the moment...lol.

I do want to say that one of the hardest things I have had to make myself do 

) is when I decided that I should step down as Handling Chair and 

asked that Tom take my place. My thoughts were that if I could not give it 100% then I 

should not be the chair and I will tell you that even now I can't give it a complete 100% (in 

a few more months, just not now). Having said all of this my point is: Tom has done an 

amazing job, first filling in for me in La Jolla and now as the recognized Handling 

Subcommittee Chair. Everyone please give Tom your best..because by God he truly has 

earned it, plus my full respect. Well done Tom well done!! (WELL DONE EVERYONE).

Harold

(b) (6)

(b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: conference travel and NOSB

Date: Friday, January 23, 2015 4:07:25 PM

Hi Miles

thank you

Our PPM in addition says "don't accept compensation for teaching, speaking and writing 

related to your board duties"......

So I will think about appearances.

Jean

On Jan 23, 2015, at 3:06 PM, McEvoy, Miles - AMS wrote:

NOSB members are not subject to Federal Ethics laws, AND, we encourage you to 

consider each event based on appearances of conflict down the road.... For example, if 

you were offered a free registration to a conference that is publically advocating on an 

issue you may have to vote on while on the NOSB, it could be perceived that the 

benefit you received from that organization could shape your vote..... Appearances are 

important – we wouldn’t want you to put yourself in an uncomfortable position by 

accepting a gift from an organization that will later be involved in a matter before the 

NOSB during your tenure. Besides keeping that in mind, you are not legally subject to 

any specific ethics laws. Here is the link to the NOP memo on conflict of interest to 

further support your thinking:http://www.ams.usda.gov/AMSv1.0/getfile?

dDocName=STELPRDC5103313

Miles McEvoy

Deputy Administrator

National Organic Program

This electronic message contains information generated by the USDA 

solely for the intended recipients. Any unauthorized interception of 

this message or the use or disclosure of the information it contains 

may violate the law and subject the violator to civil or criminal 

penalties. If you believe you have received this message in error, 

please notify the sender and delete the email immediately.
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: conference call pre-meeting

Date: Tuesday, September 16, 2014 2:08:13 PM

Hi Miles

I think it might be good if you and I, Mac, John, Jenny and maybe Carrie Ricci chat by phone prior to the meeting

 so we can have a team approach to addressing any potential legal or procedural issues which could arise.

Could we look for some dates?

Thanks

Jean
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: Declaration of a COI Determination

Date: Monday, May 11, 2015 8:42:59 AM

Wow! 

I would never have used such fund sources

Jean

Sent from my iPhone

On May 10, 2015, at 11:41 PM, wrote:

Hello Miles,

I am declaring an association with biotech companies such as Monsanto and

 Syngenta. I do not see it as a conflict of interest (COI). My association is no

 different than other land-grant 1862’s and 1890 universities. I do not see

 anything on the agenda or work plan for the fall of 2015 that would cause a COI.

As Chair of the Department of Agricultural Sciences, Urban Forestry, and Natural

 Resources. I am constantly seeking funding and other collaborations with entities

 that are in various agriculture spheres. Monsanto and Syngenta are just a few of

 these entities. Some of the associations are:

Monsanto

Monsanto has a Monsanto Fund/UNCF 1890’s Scholarship Program. Syngenta

 has a Syngenta Agricultural Scholarship Program. My students and university has

 benefited. These includes

<!--[if !supportLists]-->1. <!--[endif]-->At least five (5) my students have received

 over $50,000 in Monsanto Scholarship fund over the last three years.

<!--[if !supportLists]-->2. <!--[endif]-->On Wednesday, May 6, 2015, two (2) of

 my students were selected by Monsanto for summer internships and

 financial support for academic year of 2015-16. They sought more

 students, but other were already committed elsewhere.

<!--[if !supportLists]-->3. <!--[endif]-->One (1) of my student employment is

 pending, she is an international student. She might be selected for

 employment, if not, attend graduate school at Iowa State University.

<!--[if !supportLists]-->4. <!--[endif]-->I or my designee will be meeting with a

 Monsanto representative later next week in Mississippi on strengthen

 Monsanto partnership with my department for internships, financial

 assistance, industry in the classroom, research collaborations, and

 student employment opportunities.

<!--[if !supportLists]-->5. <!--[endif]-->There is a possibility that Monsanto will

(b) (6)
 provide a letter of support for a “Coexistence” research grant proposal.

 The entities sought are some of the seed panel experts at our LaJolla

 NOSB meeting. The proposed grant will probably have involvement of

 Iowa State, The Ohio State, Oregon State, Florida A & M, and Central

 State in Ohio. I hope to add a Hispanic serving institution to the team. The

 grant is due early June 2015. Certainly, there is no guarantee that the

 grant will be funded. 

<!--[if !supportLists]-->6. <!--[endif]-->Monsanto does provide funds to SU Ag

 Center Sustainable Agriculture Program. The support has been for several

 years.

Syngenta

Syngenta Agricultural Scholarship

<!--[if !supportLists]-->1. <!--[endif]-->One (1) of my Plant and Soil Science

 students is applying for a Syngenta Agricultural Scholarship on or before

 May 15, 2015. Syngenta seeks to increase it footprint on various 1890 and

 1862 colleges’ campus. 

These associations are routine among 1862 and 1890 land grant universities. I do

 not see that any GMO proposal or matter on the fall of 2015 NOSB agenda would

 prevent me from advocating for my sector wherein I represent on NOSB.

Best and high regards,

Calvin
From: McEvoy, Miles - AMS

To: " "

Cc: Tucker, Jennifer - AMS

Subject: RE: Declaration of a COI Determination

Date: Thursday, May 28, 2015 11:44:53 AM

Calvin –

At this time, we do not view this as a conflict of interest with your responsibilities on the National

 Organic Standards Board.

Best,

Miles McEvoy

Deputy Administrator

National Organic Program

From: [mailto

Sent: Sunday, May 10, 2015 11:42 PM

To: McEvoy, Miles - AMS; 

Subject: Declaration of a COI Determination

Hello Miles,

I am declaring an association with biotech companies such as Monsanto and Syngenta. I do

 not see it as a conflict of interest (COI). My association is no different than other land-grant

 1862’s and 1890 universities. I do not see anything on the agenda or work plan for the fall of

 2015 that would cause a COI. As Chair of the Department of Agricultural Sciences, Urban

 Forestry, and Natural Resources. I am constantly seeking funding and other collaborations

 with entities that are in various agriculture spheres. Monsanto and Syngenta are just a few of

 these entities. Some of the associations are:

Monsanto

Monsanto has a Monsanto Fund/UNCF 1890’s Scholarship Program. Syngenta has a Syngenta

 Agricultural Scholarship Program. My students and university has benefited. These includes

1. At least five (5) my students have received over $50,000 in Monsanto Scholarship fund

 over the last three years.

2. On Wednesday, May 6, 2015, two (2) of my students were selected by Monsanto for

 summer internships and financial support for academic year of 2015-16. They sought

 more students, but other were already committed elsewhere.

3. One (1) of my student employment is pending, she is an international student. She

 might be selected for employment, if not, attend graduate school at Iowa State

 University.

4. I or my designee will be meeting with a Monsanto representative later next week in

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
 Mississippi on strengthen Monsanto partnership with my department for internships,

 financial assistance, industry in the classroom, research collaborations, and student

 employment opportunities.

5. There is a possibility that Monsanto will provide a letter of support for a “Coexistence”

 research grant proposal. The entities sought are some of the seed panel experts at our

 LaJolla NOSB meeting. The proposed grant will probably have involvement of Iowa

 State, The Ohio State, Oregon State, Florida A & M, and Central State in Ohio. I hope

 to add a Hispanic serving institution to the team. The grant is due early June 2015.

 Certainly, there is no guarantee that the grant will be funded. 

6. Monsanto does provide funds to SU Ag Center Sustainable Agriculture Program. The

 support has been for several years.

Syngenta

Syngenta Agricultural Scholarship

1. One (1) of my Plant and Soil Science students is applying for a Syngenta Agricultural

 Scholarship on or before May 15, 2015. Syngenta seeks to increase it footprint on

 various 1890 and 1862 colleges’ campus.

These associations are routine among 1862 and 1890 land grant universities. I do not see that

 any GMO proposal or matter on the fall of 2015 NOSB agenda would prevent me from

 advocating for my sector wherein I represent on NOSB.

Best and high regards,

Calvin
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: dinner wednesday

Date: Monday, July 09, 2012 10:36:42 AM

Sounds good. I will move reservation and add 2. Jean

On Jul 9, 2012, at 10:13 AM, McEvoy, Miles - AMS wrote:

> It would be great to have Sarah join us. Can we push back dinner to

> 7 pm? I'd also like Cheri Courtney, NOP Accreditation Director, to

> join us.

> Miles

>

> -----Original Message-----

> From: Jean Richardson [mailto

> Sent: Monday, July 09, 2012 9:59 AM

> To: McEvoy, Miles - AMS

> Subject: dinner wednesday

>

> Hi Miles:

> Do prefer to have dinner with just me, or may I have my daughter

> Sarah Flack join us? She a nationally known agriculture specialist,

> grazing expert, lecturer, organic inspector and also does Biodynamic/

> Demeter inspections and humane treatment inspections etc. Also great

> fun to be with.

> You are going to have perfect weather this week for your audit.

> Jean

>

>

>

>

>

> This electronic message contains information generated by the USDA

> solely for the intended recipients. Any unauthorized interception of

> this message or the use or disclosure of the information it contains

> may violate the law and subject the violator to civil or criminal

> penalties. If you believe you have received this message in error,

> please notify the sender and delete the email immediately.

>

(b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: draft agenda - near final

Date: Saturday, January 24, 2015 11:15:49 AM

Hi Miles,

As you know, Colehour sees serious problems with the 3 NOSB officers "training" the new 

members. Can we title that section of the training "Collaboration between NOSB and NOP"? 

and not just have my name there?

Jean

On Jan 23, 2015, at 9:45 AM, McEvoy, Miles - AMS wrote:

Miles McEvoy

Deputy Administrator

National Organic Program

This electronic message contains information generated by the USDA 

solely for the intended recipients. Any unauthorized interception of 

this message or the use or disclosure of the information it contains 

may violate the law and subject the violator to civil or criminal 

penalties. If you believe you have received this message in error, 

please notify the sender and delete the email immediately. <NOSBFeb 2015 Training- DRAFT Agenda.docx>
From: McEvoy, Miles - AMS

To: "Jean Richardson"

Cc: Arsenault, Michelle - AMS

Subject: draft agenda - near final

Date: Friday, January 23, 2015 9:45:55 AM

Attachments: NOSB-Feb 2015 Training- DRAFT Agenda.docx

Miles McEvoy

Deputy Administrator

National Organic Program


From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Draft Chair Remarks

Date: Thursday, April 23, 2015 12:20:54 PM

Attachments: NOSB Report415.doc

Hi Miles

I will not use any slides. Just a short Cheer leading opening to set the tone.

edits welcome

Thank you

Jean
From: McEvoy, Miles - AMS

To: "Jean Richardson"

Subject: RE: Draft Chair Remarks

Date: Friday, April 24, 2015 9:51:59 AM

Jean - this looks great - thanks for the nice words.

The only change would be the reference to Allowance of Green Waste Guidance

See you Sunday

Safe travels,

Miles

-----Original Message-----

From: Jean Richardson [mailto

Sent: Thursday, April 23, 2015 12:19 PM

To: McEvoy, Miles - AMS

Subject: Draft Chair Remarks

Hi Miles

I will not use any slides. Just a short Cheer leading opening to set the tone.

edits welcome

Thank you

Jean

(b) (6)
DRAFT - NOSB CHAIR’s REPORT - April 2015

Good morning

When giving a presentation you can really only expect the audience to remember 3 

points; Today mine are: 

1. The synergy of working together to seek common ground 

2. The multidisciplinary contexts within which we must do our work 

3. An appreciation for the contributions of all the stakeholder groups and individuals. 

Last October when last I stood before you, we were all struggling with how to adapt to 

the revised Sunset Review process, and other NOP changes to our traditional ways of 

operating. In my remarks then I urged us all to work together and seek common ground, 

because the organic community may be an almost $40 billion dollar industry, but it is 

still a very small part of US agriculture, maybe only 5% in sales and 1% in terms of 

farmable land. 

The October meeting went very well, and I sincerely thank everyone for the manner in 

which we were able to deal with our differences and get through the necessary work of 

the Meeting in a professional manner. 

I heard from many of you that you appreciated the manner in which I ran the meeting, 

and so I will try to run a tight ship this week too, - and always with some humor. 

So, you can say or ask for the most outrageous things, - all I ask is that you please do it 

concisely and politely, while remembering that we are all human, and kindness and a 

smile go a long way. ! 

I would also like to express my appreciation for the incredible outpouring of written 

public comment which we have received for this meeting. The Board has read it all and 

we are in awe of the amount of professional detail and heartfelt comments from all 

sectors of the organic community. Thank you. Thank you.

Let me also acknowledge that a cohort of our organic community has filed two law suits 

against the AMS/NOP in order to seek clarification -so to speak - of NOP actions in 

regards the revised Sunset process, and in regards contaminated-compost guidance. 

Judicial challenge of Administrative Procedure is a well-established aspect of our 

American system of checks and balances. So while those issues go through the judicial 

system I ask that we get on with our work.

In recent months I have also given quite a few lectures to university classes, farmers, 

and organizations. I heard young students describe expectations for organic that all 

organic animals are treated well, and, like all of us here, I am looking forward to the 

proposed Animal Welfare standards coming out soon. And I am really pleased to note 

that Secretary Vilisak is obviously supportive.
The students were also concerned about the cost of organic food in the face our Cheap 

American Food Policy. I always make a comment about our cheap food policy because, 

along with the tension between large scale and small scale operations, the Cheap Food 

Policy is the reality of the context within which we must make our recommendations- A 

context where most farms in the US are small and their margin of profit is tiny, and most 

farmers do not receive adequate income for their products. 

There is also the obvious context of global climate change to be recognized given that 

agriculture places the highest demand on water. And the Water Laws of the Western 

States are so radically different from those Riparian laws of the Eastern states. 

Are we asking the right questions as we deliberate organic issues at this meeting.? 

Are we thinking in an interdisciplinary manner? Our deliberations and 

recommendations affect many lives and livelyhoods. We will be making 

recommendations on substances by saying yes or no, and yet there are no black and 

white answers. 

But now to some well deserved thanks: 

First to our Deputy Administrator, Miles McEvoy. I find Miles to be pretty amazing in his 

capacity to answer so many e-mails and phone calls while travelling the world building 

cooperative organic agreements with other nations, writing Policy memos, Guidance 

and Instructions, and dealing with the persistent demands of the NOSB. It is impressive 

that any member of the public can reach Miles or his staff and expect a human being to 

be ready to help. 

And as an aside - In February when Miles came up to give a talk at the NOFA 

winter conference in Vermont, I can tell you that on Sunday morning when he got a 

couple of hours to spare, he insisted on putting on a pair of old wooden cross country 

skis and skiing at 20 below zero!!! The smile on his face when in the photograph

appears frozen in place! And then he wanted to go birdwatching!

But seriously, some other thanks are due to all the Board members. No one can really 

imagine how much time, energy and stress goes in to the NOSB work, week after week 

after week. No NOSB Board has ever done such an incredible detailed analysis of 

Sunset materials. We left no stone unturned to find the necessary scientific information 

and history of use of every material. I get choked up when I look around the table at my 

colleagues. They are an absolutely amazing team to work with. I thank them for 

allowing me to Chair the Board. It is an honor.

I also thank NOP staff Emily and Lisa for their incredible work these last few months, for 

setting up all the templates to make Sunset review so much more open and transparent 

to the public, and for the enormous amount of extra time and energy needed to review 

all the Technical Reports which the NOSB had asked for for Sunset materials. The TRs 

we get now are so much better than in the past. It helps us all so much.

And a special shout out to Michelle our ABS who puts in long hours on an incredible 

array of tasks from being on every conference call, setting up these meetings, 
answering calls from members of the public and dealing with all the challenges of 

computer input of data, and all the day to day minutia! Michelle is the glue that keeps 

us together !

(applause) 

Since October we have also brought on Board 4 new NOSB members who received in -

depth training in Washington in February this year. At that meeting, and on all the 

subcommittee conference calls, we have tried to be sure that they understand the 

depth, breadth and volume of work on their plates, especially having joined the board 

during Sunset Review year.! So far none of them have quit, so please be nice to them!

This is their first meeting and I ask that you be sure to stop and chat with them, and get 

to know them.

I can tell you that Tom Chapman has a mischievous sense of humor, that Lisa de Lima 

demonstrates a fine attention to detail, that Ashley brings a wonderful energy to her 

committee work, and Paula is determined to find a more efficient way for us to 

accomplish all our work, and that all four of them demonstrate an openness to listening 

to all stakeholders.

And right now is a good time to encourage individuals to nominate themselves or other 

for the 5 NOSB positions which will start in January 2016. Theirs will be an easier task 

as Sunset will be another 5 years away!

So I congratulate the new board members on not quitting, and welcome them to what I 

hope will be an enjoyable week where we can all learn something new and fascinating.

So let’s get to work!

****************

Before Public Comments etc. I will say a few words about operating rules for the week

These public meetings operate on a combination of FACA rules, Roberts Rules of 

Order, the NOSB PPM and Tradition! I will try to always be fair, moving the meeting 

along with professional courtesy to all. 

I have a gavel and a wand... etc.
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: DRAFT NODPA article

Date: Monday, April 20, 2015 9:12:06 AM

Hi Miles:

Thank you , couple of comments/questions:

1. So you do not want individual farmers to contact the Secretary about desire to see Animal Welfare soon? I am

 trying to show them that their voices count.

2. Petitions- we have been talking with Emily on our calls and our goal is to have simple annotation petitions have a

 quick turn around - this will be especially important if we are to get prevent delisting some substances.

3. So - money for TR not from Farm Bill. I remain frustrated over the NOP "budget"...

Jean

On Apr 20, 2015, at 8:57 AM, McEvoy, Miles - AMS wrote:

> Nicely done!

> Comments/redlines attached

> Let me know if you have questions.

>

> Miles

>

> -----Original Message-----

> From: Jean Richardson [mailto

> Sent: Friday, April 17, 2015 2:52 PM

> To: McEvoy, Miles - AMS

> Subject: DRAFT NODPA article

>

> Hi Miles

> could you run you eagle eye over this draft due Monday! - sorry!

> thank you

> Jean

>

> <NODPA42015-mvm.doc>

(b) (6)
NODPA-April 20, 2015

In May, by the time you read this article, the April NOSB Meeting in California will be 

over and the Origin of Livestock rule will have been published - any day now I am told. 

At the NOSB meeting in late April we will be voting on two petitioned substances of 

interest to dairy producers: Acidified Sodium Chlorite for use as a pre and post teat dip 

treatment (205.603 (a)) to provide an alternative to iodine based teat dips, and Zinc 

Sulfate for use as a footbath only (205.603(b)). 

Proposed rules to implement the NOSB Animal Welfare recommendations are still going 

through Rule Makingunder development, but this week Secretary Vilisak Vilsack stated 

in public that these will be posted this summer public commentstarting departmental 

clearance this summer. A proposed organic animal welfare rule could be published by 

the end of the year. Apparently this is still a hot topic in DC with some who do not want 

these standards to move forward. So if you have an opinion you may wish to contact the 

Secretary’s Office.

So, today I will talk a bit about what substances on the National List will be coming up 

for Sunset vote at the October meeting, and the kind of input that the NOSB would like 

to hear from NODPA members this summer. 

If you have been following the Sunset Rule Review changes at all you will know that 

now all substances stay on the National List unless the full NOSB (with a two thirds 

majority) votes recommends to remove the substance from the National List. Previously 

all substance went off the National List unless the NOSB voted to add them back during 

the Five Year Review process. Thus you will see that in order to be sure that all 

substances under Five Year Review are reviewed by the FULL Board for vote at public 

meeting, after public comment at two public meetings, every material is brought forward 

from the respective subcommittee on a Motion to Remove. This also ensures that the 

organic community is on public notice that every Sunset material could potentially be 

removed. So, please pay attention and let us know how essential a particular substance 

is to your production. 

When you are researching a particular substance you will see Motions to Remove and 

subcommittee votes and comments or questions during the initial public comment 

period, and more detailed notes for the second public meeting period and the second 

posting. This may seem a bit cumbersome, but it seems to be working well, and 

certainly we are getting plenty of public comment on substances much earlier in the 

Review process, rather than a scramble at the end, or right before vote.

In terms of numbers to be voted on at the October meeting in Vermont: Livestock will be 

presenting 42 substances for Sunset 2017 Review; Crops 43 ; and Handling 79. There 

will be substances of interest to NODPA members in all of these subcommittees.

The NOSB has done an enormous amount of research on all these substances and 

each of us is presently going through more than a thousand written public comments 


From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: DRAFT NODPA article

Date: Monday, April 20, 2015 8:16:36 AM

OK

Thank you

Sarah likes it

jean

On Apr 20, 2015, at 7:50 AM, McEvoy, Miles - AMS wrote:

> I'll look at it this morning.

>

> -----Original Message-----

> From: Jean Richardson [mailto

> Sent: Friday, April 17, 2015 2:52 PM

> To: McEvoy, Miles - AMS

> Subject: DRAFT NODPA article

>

> Hi Miles

> could you run you eagle eye over this draft due Monday! - sorry!

> thank you

> Jean

>

(b) (6)
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Automatic reply: DRAFT NODPA article

Date: Friday, April 17, 2015 2:52:06 PM

I am out of the office. Please contact Joan Avila at 202-720-3252, joan.avila@ams.usda.gov if

 you need immediate assistance.
From: McEvoy, Miles - AMS

To: "Jean Richardson"

Subject: RE: draft NODPA article

Date: Thursday, December 18, 2014 5:08:47 PM

Attachments: NODPA Dec23 - jean richardson.doc

NODPA news submission.docx

Thanks Jean - a few suggested edits

I'm also including my NODPA piece - much dryer and bureaucratic but hey,

Happy Holidays. . I'll be checking email the next two weeks but I'll not be available

 from Jan. 2-12.

All the best. Looking forward to working with you in 2015!

Miles

-----Original Message-----

From: Jean Richardson [mailto

Sent: Thursday, December 18, 2014 8:38 AM

To: McEvoy, Miles - AMS

Subject: draft NODPA article

Hi Miles,

feel free to edit this draft for NODPA NEWS which will come out in January.

Deadline for me to get to NODPA, Dec 22.

Thank you

Jean

PS I hope you share your annual Report of work done with ! Exhausting list!

This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

(b) (6) (b) (6) (b) 

(6)
NODPA news

2015 Organic Outlook

The USDA National Organic Program’s responsibility is to protect the USDA organic seal, from farm to 

market, around the world. We do that through three primary mechanisms – establishing clear standards 

that establish a level playing field for organic farms and businesses; making sure that organic certifying 

agents are properly and thoroughly verifying that organic products comply with the USDA organic 

regulations; and taking appropriate enforcement actions when there are violations of the organic 

standards. 

Our focus in 2015 includes:

USDA organic regulations: The Agricultural Marketing Service plans to publish proposed rules on Origin 

of Livestock, Pet Food, Aquaculture and Animal Welfare in 2015. We look forward to your comments on 

these proposals. In addition, the NOP will continue to support the work of the National Organic 

Standards Board, and provide clarifications through guidance and instructions to organic producers, 

handlers and certifiers.

 

Certifier Accreditation and International Activities: In 2015, the NOP will conduct certifier audits

throughout the U.S. and in more than a dozen countries to ensure certifier compliance with the USDA 

organic regulations. The NOP will conduct assessments of organic trade arrangements to make sure the 

arrangements are properly implemented. In addition we will continue to work with Latin American 

governments to support effective control systems and internal market development. The NOP recently 

provided the USDA organic regulations and NOP Handbook in Spanish to support Spanish-speaking 

members of the organic community.

Compliance and Enforcement: The NOP will continue to investigate and act on regulatory violation 

complaints, and manage appeals, as they are received by the program. Last year, the NOP issued over 

200 enforcement actions, including 9 civil penalties for $81,500 for knowing violations of the Organic 

Food Production Act. These compliance activities support consumer confidence in the USDA organic 

seal and protect certified operations operating in compliance with the standards. 

Sound and Sensible Certification Standards: Many farmers and agricultural businesses have not taken 

advantage of organic market opportunities because of a lack of technical information, recordkeeping 

challenges involved in certification, and inconsistent certification processes. In 2013, the National 

Organic Program initiated a “Sound and Sensible” initiative to make organic certification more 

accessible, attainable, and affordable for small and beginning farmers. The NOP will continue to identify 

the near-term policy changes and clarifications that will streamline requirements; refocus certification 

and oversight on practices rather than paperwork; and support the Secretary’s 2013 Organic Agriculture 

Guidance to eliminate duplicative requirements through cross-USDA collaboration. 

USDA Outreach: The NOP supports the USDA-wide Organic Working Group (including the Organic 

Literacy Initiative), and facilitates implementation of Secretary Vilsack’s Departmental Guidance on 

Organic Agriculture. 

I look forward to another busy and productive year. Please let me know if you have any questions or 

concerns. If you have specific ideas on how we can improve our work or services please get in touch 

with me, Miles McEvoy, at miles.mcevoy@ams.usda.gov. 
NODPA NEWS - Dec 23, 2014

Jean Richardson, Chair National Organic Standards Board (NOSB)

Following the October Meeting in Kentucky the NOSB moved quickly back into its work 

agenda, increasing the number of subcommittee conference calls to accommodate the

required 5 year Sunset Review of materials on the National List as well as petitioned 

materials. Each subcommittee has NOP staff support. All of our present agenda must 

be completed by February 24 so that it can be placed in the Federal Register for Public 

Comment in early March ready for the April meeting in San Diego. Here’s what each 

subcommittee of volunteers is working on: 

Livestock/Aquaculture: The material which continues to occupy much of our time is 

methionine in poultry production. We asked a number of experts from diverse 

perspectives and scales of operation with diverse management techniques, and 

nutritionists to come and answer questions on our conference calls. We have also been 

in conversation with researchers who have been working on alternatives to synthetic 

methionine. You can never know everything when researching a substance as there are 

so many confounding variables, but we have done a lot of research on this developing 

proposal which we hope to bring to full board vote at the April meeting. We shall also be 

voting on acidified sodium chlorite and zinc sulfate, and may have enough research 

completed to consider a proposal for aluminum sulfate for poultry litter treatment.

We will be presenting the initial Sunset Review of 41 Livestock materials in order to 

seek public comment and discuss at the April meeting, with a vote on keeping or 

removing these materials from the National List at the October meeting in Stowe 

Vermont. I won’t list them all here, but they include chlorhexidine, the parasiticides 

fenbendazole, moxidextin and ivermectin; iodine, copper sulphate, peracetic acid, 

lidocaine and methionine. For several of these we have requested updated Technical 

Reports. Your comments on any material up for Review is critical. If you find it hard to 

navigate the NOP Website and find the full list, or want to chat about sunset review of 

materials remember you can call me any time or e-mail me questions.

The Livestock subcommittee also has aquaculture on its Work Agenda, but we are 

waiting on further discussion on these materials until the draft standards are published, 

which may not be until late spring 2015- things move slowly in Washington!

Animal Welfare standards should be out soon, and we are all hoping that these will be 

responsive to the concerns expressed by the NOSB and the public.

Crops: In the crops subcommittee we shall be presenting 4 proposals for new materials 

at the April meeting, and an update on Inerts, as well as a discussion document on 

Contamination in Farm Inputs. For Sunset Review there will be final votes on renewal or 

removal of ferris phosphate and hydrogen chloride, and initial review discussion of an 

additional 45 materials which will be voted on in October following public comment.

thousands of USDA employees who are willing to learnso that USDA can better serve 

the organic community. This is an ongoing and much needed task.

I also happen to know that in his spare time Miles goes bird watching!

 

Do not hesitate to contact me with your questions, comments or concerns any time. If I 

do not know the answer I will find the right person to help you. 

 home phone: 

974 words

(b) (6) (b) (6)
From: Jean Richardson

To: Arsenault, Michelle - AMS

Cc: McEvoy, Miles - AMS

Subject: Re: DRAFT TENTATIVE agenda for spring 2015 NOSB

Date: Thursday, February 19, 2015 1:07:37 PM

Sounds good Michelle. And all Sunset material motions will be to remove, which means as 

much clarification as possible as to which ones we really mean remove!

On Feb 19, 2015, at 12:23 PM, Arsenault, Michelle - AMS wrote:

Excellent feedback, thanks. I will make a few changes and wait for Miles’ feedback 

before sending out the next version. Ah yes, “MISSION” was a holdover from a past 

meeting that we never go to.

One thing Emily, Lisa, and I are still talking about is how to group the sunset materials 

to save time. By NL Section number and then by intended action seems logical. They’ve 

done that in the past. So, for example, list all the 605(a) items and note which ones will 

have a motion to remove, and which ones will not. We definitely all want and need a 

clear idea of the mechanics ahead of time.

Thanks,

Michelle

From: Jean Richardson [mailto:

Sent: Thursday, February 19, 2015 12:18 PM

To: Arsenault, Michelle - AMS

Cc: McEvoy, Miles - AMS

Subject: Re: DRAFT TENTATIVE agenda for spring 2015 NOSB

Hi Michelle

Thank you for the draft agenda

To be honest I do not see how we can get through everything in 4 days, but your 

Agenda looks reasonable.!

Under "Introductions" - Do we really need " NOSB Mission"? I always find that a

 bit odd. All I do is introduce folks.

In terms of your question as to where to place the NOSB Report: Please put Lisa 

Brines right after Miles'NOP Report and then put NOSB Report after Lisa.

The Goal here is to clearly demonstrate the NOSB role and Chair's comments 

which will, in part, add to comments provided by both Miles and Lisa a few 

minutes earlier. This will be the case for all NOSB meeting going forward. It is 

intended to set the tone of professionalism and collaboration for the meeting.

Under Livestock, the Methionine and the ASC are both proposals in response to 

Petitions - so add petitioned

(b) (6)
We will need to be explicit in making sure no-one makes any plane reservations 

until Friday morning at earliest in case we need to keep going to finish on 

Thursday evening.

So in terms of the Hotel reservations let us be sure we have adequate rooms for 

everyone from Saturday night through Thursday night departing Friday.

I will e-mail the Board to let them know this, but we will need to do it more than 

once I am sure.

I am home today Michelle if you need to discuss the proposed Agenda

Cheers

Jean

On Feb 18, 2015, at 6:52 PM, Arsenault, Michelle - AMS wrote:

<2014 template Agenda_Internal.docx>

This electronic message contains information generated by the USDA 

solely for the intended recipients. Any unauthorized interception of 

this message or the use or disclosure of the information it contains 

may violate the law and subject the violator to civil or criminal 

penalties. If you believe you have received this message in error, 

please notify the sender and delete the email immediately.
From: McEvoy, Miles - AMS

To: Arsenault, Michelle - AMS; Barry Flam; Carmela Beck (carmela.beck@driscolls.com); Colehour Bondera

 (colemel@kanalanifarm.org); Harold Austin; Jay Feldman; Jean Richardson (

Jennifer Taylor ( JFoster@ebfarm.com; joe.dickson@wholefoods.com; Nicholas

 Maravell ( Robert Mac Stone (mac@elmwoodstockfarm.com); Rueben Walker

 ( Tracy Favre (tfavre@favrehouse.com); wendy.fulwider@organicvalley.com; Zea

 Sonnabend (zea@well.com)

Subject: draft work plan

Date: Thursday, April 19, 2012 4:35:18 PM

Attachments: NOSB Workplan 2012-13 4-19-12.xlsx

image001.png

Attached is a draft work plan for the fall 2012 and spring 2013 NOSB meetings. We would like to

 establish the work plan so that committee work can proceed effectively. Thank you for your work

 and I look forward to discussing the work plan with you tomorrow.

Miles V. McEvoy

Deputy Administrator

National Organic Program

U.S. Department of Agriculture

Room 2646-So. (Stop 0268)

1400 Independence Ave SW

Washington, DC 20250-0268

202-720-3252

www.ams.usda.gov/nop

Organic Integrity from Farm to Table, Consumers Trust the Organic Label

Register for the NOP Organic Insider, the National Organic Program’s email notification service, by

 visiting http://bit.ly/NOPOrganicInsiderRegistration.

This electronic message contains information generated by the USDA solely for the intended

 recipients. Any unauthorized interception of this message or the use or disclosure of the

 information it contains may violate the law and subject the violator to civil or criminal

 penalties. If you believe you have received this message in error, please notify the sender and

 delete the email immediately.

(b) (6) (b) (6) (b) (6) (b) (6)

NOSB Workplan - DRAFT 

4/19/12

NL = National List

Fall 2012 Spring 2013

Crops NL petition - Ferric phosphate NL petition - Vinasse

NL petition - PGML NL petition - Polyoxin D zinc salt

NL petition - Biodegradable plastic mulch Inerts Working Group - Proposal

NL petition - Oxidized lignite NL petition - Sulfuric acid

Inerts Working Group - Update/Discussion Document NL-aquaculture - plants - Trace minerals

Fire Blight Working Group - Update NL-aquaculture - plant - Vitamins

Livestock NL petition - Nonanoic acid NL-aquaculture - Vitamins

NL petition - Pet food amino acids NL-aquaculture - Trace minerals

Parasiticides for fiber bearing animals discussion document

NL - aquaculture - carbon dioxide Poultry - Omnivore Diets - Proposal

NL-aquaculture - Chlorine

NL-aquaculture - Micronutrients

NL-aquaculture - Vaccines, Biologics

Poultry - Omnivore Diets - Discussion Doc

Handling NL petition - L-carnitine NL petition - Bergamot bitter orange powder (2010/11)

NL petition - L-methionine NL petition - Sulfuric acid (2010)

NL petition - Beta-carotene "Other Ingredients" Proposal

NL petition - Taurine NL petition - DBDMH petition

NL petition - Nucleotides

NL petition - Ascorbyl palmitate

NL petition - Lutein

NL petition - Lycopene

NL petition - Barley betafiber (2009)

NL petition - Sugar beet fiber (2009)

"Other Ingredients" Discussion Doc

Materials CBI on petitions - proposal Ion exchange chromatography discussion doc

Update petition/TR process

Policy Updates to PPM (sent by MB/LB)

NOSB Ethics

CACC Calculating % of Organic Ingredients - Discussion Doc Calculating % of Organic Ingredients - Proposal

Sanitizers in bulk milk trucks - proposal

Monitoring OSP Practices - Discussion Doc Monitoring OSP Practices - Proposal

Sanitizers in 100% Organic Products - Proposal Retail Certification

GMO (Ad-Hoc) Cell Fusion - Discussion Doc

GMO and Organic Seeds - Discussion Doc
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: FYI - Fwd: Task force-hydroponics

Date: Friday, April 10, 2015 1:19:15 PM

Hi Jean,

Thank you for the encouragement. I am planning to put my name in.

I do hope it is a balanced group rather than a bunch of hydroponic

producers, researchers and their certifiers. I do not want to be the token

organic guy.

For this task force to succeed it will also need a good mix of folks who

have the background to assess whether the proposed hydroponic practices

align with OFPA and the USDA organic regulations.

Enjoy your weekend,

Eric

-- 

Eric Sideman

Crop Specialist

Maine Organic Farmers and Gardeners Association

Phone: 603 269 6201

esideman@mofga.org
From: McEvoy, Miles - AMS

To: "Jean Richardson"

Subject: RE: Friday at 8.30?

Date: Wednesday, January 28, 2015 10:00:13 AM

Yes, that will work. 4 pm?

-----Original Message-----

From: Jean Richardson [mailto

Sent: Wednesday, January 28, 2015 8:10 AM

To: McEvoy, Miles - AMS

Subject: Friday at 8.30?

Hi Miles

Looks like I will be in the truck Friday morning headed out for a processing inspection - assuming snow is

 reasonable. So any chance we can chat Thursday late afternoon early evening like last week?

Thanks

Jean

This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

(b) (6)
From: Jean Richardson

To: Arsenault, Michelle - AMS

Cc: Colehour Bondera; Jennifer Taylor; Mac Stone (mac@elmwoodstockfarm.com); Tracy Favre; Brown Rosen, Emily

 - AMS; McEvoy, Miles - AMS

Subject: Re: For review: PDS Notes August 11, 2015

Date: Thursday, August 13, 2015 2:24:11 PM

Do we need a September 8 meeting?

Sent from my iPhone

On Aug 13, 2015, at 12:55 PM, Arsenault, Michelle - AMS

 <Michelle.Arsenault@ams.usda.gov> wrote:

Hello Policy Development folks,

Attached, please find the notes from our August 11, 2015. Our next call is September 8, 2015 2:00

 ET.

Thanks,

Michelle

Michelle Arsenault

Advisory Committee Specialist

USDA National Organic Program

1400 Independence Ave SW; Room 2638S

Washington, DC 20250-0268

Office: 202.720.0081

Mobile: 

michelle.arsenault@ams.usda.gov

<PDS 08 11 15 draft.docx>

(b) (6)
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: RE: Field trip prior to NOSB?

Date: Friday, March 13, 2015 12:58:01 PM

Yup - might be too much

-----Original Message-----

From: Jean Richardson [mailto

Sent: Friday, March 13, 2015 12:08 PM

To: McEvoy, Miles - AMS

Subject: Field trip prior to NOSB?

Hi Miles

I am wondering if we are asking too much of everyone to do a field trip, plus added expenses for NOP budget.

Since the meeting is 4 days, if folks come in Saturday rather than Sunday, that would be a time commitment of 7

 days as I imagine everyone would need to fly out on Friday morning.

Just a thought,

Jean

(b) (6)
From: Jean Richardson

To: Paula Daniels

Cc: Mac Stone; Tracy Favre; McEvoy, Miles - AMS

Subject: Re: few words from each?

Date: Thursday, April 30, 2015 12:02:54 PM

Ah no, thank you for letting me know.

Do you want to leave some words for me to speak for you?

We will try to get votes completed before you have to leave.

Jean

On Apr 30, 2015, at 11:56 AM, Paula Daniels wrote:

> I'm not sure if I mentioned this to you but I will be leaving at the 3:30 break

>

> ********

> Sent from my iPhone

> (tip-typing away)

>

>> On Apr 30, 2015, at 8:40 AM, Jean Richardson < wrote:

>>

>> Hi,

>> as suggested, I will ask each of you to say a few words about your goals for your next 5 years on the Board,

 when you get your plaque from Miles this afternoon at 5 pm

>> check with Ashley for ideas...

>> Jean

(b) (6)
From: Jean Richardson

To: Kent Henderson

Bcc: McEvoy, Miles - AMS

Subject: Re: Fenbendazole update

Date: Monday, May 07, 2012 8:00:42 PM

Hi Kent:

Thank you. I have forwarded this to Miles McEvoy and the Chair of the NOSB Livestock 

committee as well.

Jean

On May 7, 2012, at 4:49 PM, Kent Henderson wrote:

Dear Tom,

 Three weeks ago, I wrote to draw Senator Leahy’s 

office’s attention to the extensive delay in approval of 

Fenbendazole by USDA for organic producers. As you 

suggested, I contacted Jean Richardson and we met for a few 

hours two weeks ago. She helped me understand how her 

board works and I offered observations from the animal health 

field. We have agreed to meet on a regular basis.

 We were under the impression that Mr. McEvoy’s office 

had been contacted and we could expect the appearance of 

Fenbendazole in the Federal Registry on Friday April 27.

When the Registry was checked on Tuesday May 1, 

Fenbendazole was missing from the list.

 Dairy replacement heifers are being put out on pasture 

this week in Vermont. For proper strategic deworming 

strategy, I will be advising non organic Vermont dairy farmers 

to deworm with Fenbendazole in 3-5 weeks. Is there any 

hope that Mr. McEvoy’s office can sign off on Fenbendazole, 

before the organic dairy heifers start picking up internal

parasites?

Thanks,

Kent Henderson

Northwest Veterinary Associates, Inc.

From: Kent Henderson [mailto:

Sent: Sunday, April 15, 2012 7:57 PM

To: 'Tom Berry'

(b) (6)
Cc: 'stephen.tegarden@merck.com'; 'Jackson, Rick'; 'S B B Lewis'; 

Allison Maslack; Jennifer Taylor; Stephen Wadsworth (cowvet@myfairpoint.net)

Subject: safeguard organic letter-2011 (3)

Dear Tom,

 Recently we met at the Friends of Northern Lake Champlain 

advisory council meetings and annual meeting. For the past year,

 I have had the honor of succeeding Pixley Tyler Hill as chair of 

FNLC. Tonight, I would like to send along comments as president

 and business manager of Northwest Veterinary Associates, Inc., 

a six person dairy exclusive veterinary practice serving NW 

Vermont and NE New York. Organic dairy and beef cow/calf are 

growing portions of our veterinary practice and If I am reading 

national publications correctly, Vermont has one quarter to one 

third of the nation's organic dairy farms. We have always been 

appreciative of Senator Leahy's support of the overall dairy 

industry and new parallel organic industry, so we turn to you for

support.

 For the past decade, our practice has been diagnosing internal 

parasite problems in our organic herds and we can offer no 

practical and effective program to cure these animals according to

 Organic standards. In addition to the death of many clinical 

cases of parasitism, we have documented several of our organic 

farms that have high parasite loads that reduce the ability of 

animals to resist all types of diseases. Since we are the advocate

 for the cow, we were delighted to learn four years ago, that the 

NOFA board of medical advisors had unanimously approved the 

addition of Fenbendazole (Safeguard) to the list of approved

drugs. Briefly, Fenbendazole has an outstanding record of 

effectiveness and virtually no evidence of parasite resistance 

since its introduction 25+ years ago. The drug stays in the lumen 

of the gut and does not go systemic, so it has zero milk and meat 

withholding time and is widely used on Vermont dairy farms.

When it is passed in the feces, it does no harm to the environment

 and beneficial worms and beetles that break down "cow patties."

 Four long years have gone by since the NOFA board approval 

and USDA has not followed through with approval. As you can 

see by the March 4, 2011 date on the attached letter, another 

year went by after our careful comment. We are facing a critical 

time for pasture based organic cows and heifers. In early May,

(b) (6)
they will be put out on worm-infested pastures with no effective 

protection. The organic farms need the approval to use 

Fenbendazole now, and can't understand why there should be 

any delay.

 It is our understanding that the whole process of approval has 

stopped on the desk of:

 Miles McEvoy

 Deputy Administrator

 National Organic Program

 1400 Independence Ave., S. W.

 Room 2646-S, STOP 0268

 We respectfully request that Senator's Leahy's office take 

urgent action by contacting Mr.. McEvoy to speed along the 

availability of Fenbendazole to organic dairy and beef animals.

Thank you,

Kent Henderson, DVM

Northwest Veterinary Associates, Inc.

6 Fairfield Hill Rd., Saint Albans, VT .05478

 cell

(b) (6) (b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: February in VT

Date: Friday, December 12, 2014 2:41:22 PM

Great. I do not know Linda, but hear good things about her.

I shall try to keep Nor Easters at bay during mid February.

Jean

On Dec 12, 2014, at 2:32 PM, McEvoy, Miles - AMS wrote:

> That would be fun. Thank you. I would like to try to get in a visit with Linda Berlin, a UVM faculty person who

you may know.

>

> Miles

> -----Original Message-----

> From: Jean Richardson [mailto On Behalf Of Jean Richardson

> Sent: Friday, December 12, 2014 2:23 PM

> To: McEvoy, Miles - AMS

> Subject: February in VT

>

> Hi Miles

> I would be delighted if you would stay at my place in February when you come to Vermont.

> Cheers

> Jean

>

>

>

>

>

> This electronic message contains information generated by the USDA solely for the intended recipients. Any

unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

notify the sender and delete the email immediately.

(b) (6)

From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Feb 3 visits?

Date: Monday, January 26, 2015 4:57:45 PM

Hi Miles

Both Tracy and I are available for meetings with anyone you think we should meet with on Tuesday Feb 3, day

 before our new Board member Training. I am additionally available on Friday morning following the training.

Let us know what you would like us to do.

Thank you

Jean
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Farmers Union talk

Date: Saturday, September 20, 2014 12:03:36 PM

HI Miles

I have just agreed to be part of an organic panel for the New England Farmers Union convention in Portland Maine

 on Dec 12.

The person contacting me, Roger Noonan, was at NASDA. He would like you or Betsy to be on the panel and I said

 I would drop you a note. He is pretty upset with the OTA Check off program, and wants to be able to talk about

 Sunset etc.

He will be at NODPA this coming Thursday.

Cheers

Jean
From: Jean Richardson

To: B. Flamm

Cc: Mac Stone; CALVIN WALKER; Carmela Beck; COLEHOUR BONDERA; Harold Austin; Jay Feldman; Jennifer Taylor;

joe.dickson@wholefoods.com; John Foster; Nicholas Maravell; Tracy Favre; Wendy Fulwider; Zea Sonnabend;

Arsenault, Michelle - AMS; McEvoy, Miles - AMS

Subject: Re: Fall Meeting

Date: Wednesday, June 13, 2012 10:20:23 AM

Public Meeting of NOSB:

Format of set up:

I liked the use and placement of cameras and screens, but I suggest an

oval shape for the table set up so we can all see each other. This

would make it easier to chair the meeting too. So for example it would

be easier for the Chair to know which board member has a hand raised

to ask questions.

Conflict of Interest:

This was not merely awkward it was a bit silly. The Chair should ask

for "Any disclosures of Interest"or some such and not "Any Conflict of

Interest" as this creates a potential public misperception. I suggest

that NOP review what procedures we legally/ethically require under

FACA and that these are clearly understood by us all prior to next

public meeting. The so-called disclosures made by members were

irrelevant and need not have been made in my opinion. So let's have an

NOP ethics lawyer clarify this.

Voting:

If we listen to public comment, and sub committees then huddle

together to discuss possible recommendations, and then vote

immediately, it creates several impressions to the public:

1. We take public verbal comment very seriously (which is good), but:

2. we do not take the time to read additional written comment just

handed to us by the presenter before we vote; and

3. We appear to confirm the public's impression that coming to the

meeting and speaking is very important and perhaps more important than

all the written comments submitted before the meeting.

So It may make more sense to do all the voting on the Friday after we

have had time to digest both verbal and additional written material.

3 minutes or 5?;

I do not care as long as the meeting is run smoothly and all Board

members are given an opportunity to ask questions if they wish.

Expert Comment:

I like the use of invited experts to testify. They allow board members

who are not on a specific sub committee, eg livestock and GMO vaccine

issue, to clarify the scope of the issue and have their questions

answered. But invited experts will need to be alloted more time. How

can we best handle such experts and not be viewed as getting excessive

"corporate input"?

Use of the Gavel:

Should we encourage the Chair to use the gavel if and when there is

disruptive or unpleasant behavior by members of public or board?
Pre-Meeting subcommittee discussions:

It is pretty critical to the success of our joint work (NOSB and NOP)

that all board members meet with each of the subcommittees prior to

the formal public meeting. We are only on 3 sub committees and cannot

be on every conference call, yet we must vote with clear understanding

of the implications of each vote. So we need most of the Monday to do

that effectively. So let us request the NOP to allow the necessary

face to face discussion time prior to the Tuesday start of formality.

That will be money well spent!

I enjoyed meeting you all, and look forward to working with you over

the next few years.

Jean
From: Jean Richardson

To: McEvoy, Miles - AMS; Arsenault, Michelle - AMS; Tucker, Jennifer - AMS

Subject: Extend date for Nosb nominations

Date: Thursday, May 14, 2015 2:41:48 PM

Hi I am getting calls to ask if in fact nomination date for Nosb was actually extended?

Help please

Jean

Sent from my iPhone
From: Jean Richardson

To: Colehour Bondera

Cc: Zea Sonnabend; Tracy Favre; Harold Austin; Arsenault, Michelle - AMS; McEvoy, Miles - AMS; Brown Rosen,

 Emily - AMS

Subject: Re: Executive call April 10, 2015

Date: Wednesday, April 15, 2015 4:35:34 PM

I really have said all I wish to say on this subject

Jean

Sent from my iPhone

> On Apr 15, 2015, at 3:28 PM, Colehour Bondera < wrote:

>

> TY for responding, Jean.

>

> Sincerely,

>

> Colehour

>

>> On Apr 15, 2015, at 2:49 AM, Jean Richardson wrote:

>>

>> To be honest Colehour, we volunteers can say whatever we want on an Executive call. It should be a safe place

 for us to express our frustrations, suggest new ways to approach issues, or sort through complexities to seek the best

 way forward for NOP and NOSB in our respective roles. I feel that we should be kind to one another, respectful of

 the divergence of opinions and perspectives, and not just be tolerant of the diversity, but celebrate the diversity.

 Each of the 15 members alone can have a positive impact on the organic community, but it is the synergy of us all

 together that will lead to the needed change.

>>

>> So I ask for your kindness and understanding as we move forward.

>> Respectfully, Jean

>>

>>

>>

>>

>>> On Apr 15, 2015, at 12:53 AM, Colehour Bondera wrote:

>>>

>>> Aloha Jean,

>>>

>>> I appreciate your initially quick response to my communication of concern.

>>>

>>> At this time I request that you please fully respond as to how you, as Chair, will provide attention to this issue

(b) (6)

(b) (6)
 (see below) in a way that affects all involved, notably the one who behaved in a manner to raise concern regarding

 our equal, fair and non-discriminatory responsibilities in representing the public regarding organics. Correct a

 problem before it gets out of hand, and be sure that there are not actions taken due to the distraction of a lawsuit

 when we are required to properly reach conclusions without pre-decisions based on outside actions that we may not

 support, but that are not related to the considerations on the table.

>>>

>>> Thank you for your immediate response.

>>>

>>> Yours,

>>>

>>> Colehour

>>>

>>>> On Apr 12, 2015, at 3:54 PM, Jean Richardson wrote:

>>>>

>>>> Hi Colehour

>>>> Thank you for your heartfelt comments.

>>>> I will not make a detailed response in a hasty manner this evening, but I shall think carefully about the

 concerns that you are raising

>>>> Jean

>>>>

>>>> Sent from my iPhone

>>>>

>>>>> On Apr 12, 2015, at 9:08 PM, COLEHOUR BONDERA < wrote:

>>>>>

>>>>> Aloha Jean,

>>>>>

>>>>> Hope that this finds you doing well.

>>>>>

>>>>> It is with some concern and uncertainty that I send this message to you, however I feel that the subject must

 be dealt with by the Executive Committee at minimum, if not via the NOP and/or at least the PDS.

>>>>>

>>>>> While I could include legal references and quotes from websites and the PPM (in whatever form is

 considered "current") regarding this subject, I would rather start on more friendly terms and receive

 acknowledgement of my points of concern from both yourself and the NOP (which is why I have cc'ed Miles, given

 his position as well as the fact that he was on the call referred to...)

>>>>>

>>>>> The point of concern that I am writing this about was during the Executive Subcommittee NOSB call of

 April 10, 2015, on which I was a "listener". Specifically, during discussion regarding the topic of a lawsuit, which

 I believe that you raised, there was some discussion that I both want to be sure is in the meeting notes for the sake

 of reference (which is why I have also cc'ed Michelle), but also for the reference of action that I believe must be

 formally taken at this time.

>>>>>

>>>>> In my opinion, based not only on NOP acceptance to NOSB members, NOP trainings as well as the PPM, all

 members of the NOSB are responsible and required to duly consider all input provided by all members of the public

 (who we represent as a public advisory committee to the USDA), not only those who we agree with or are already

 friends with, so to speak.

>>>>>

>>>>> Points and opinions provided should not and from the perspective of discrimination, cannot be disregarded

 or dismissed due to previous actions of said party or organization is my understanding of how the basis of the legal

 framework guides our responsibilities.

>>>>>

>>>>> That said, while I perhaps am reading more into it that is deserved, it was with significant concern that I

 heard and considered the implications of the comments that Zea Sonnabend went out of her way to not only make,

 but to clarify in the brief discussion that followed. Zea noted that she would not provide equal due consideration

 henceforth to the groups/group representatives whos' names were associated with the procedural lawsuit filed last

 week towards the USDA regarding the NOP and the sunset process revisions.

>>>>>

(b) (6)
>>>>> That said, Zea made it quite clear that she would not give equal consideration, and in fact my memory is that

 she stated that she would, 'disregard comments from said entities' during upcoming meeting(s)/decision(s).

>>>>>

>>>>> As it is suggested at the start of this communication, it would be much better to not cite programmatic or

 even legal points of order regarding such a position, in my opinion. However given the circumstances and the

 timeliness of the points made (by Zea, not others) in terms of consideration from said groups in written and/or live

 testimony, my request is that Zea be called to order at this time (ie, not wait until the meeting only, though a general

 statement at the meeting as well would make a lot of sense).

>>>>>

>>>>> If it is felt that this must be done generically, such as via an email to all NOSB members regarding due

 diligence and our required equal consideration and attention to all members of the public aside from our areas of

 assignment and/experience with individuals or groups, I believe that such a communication from the Chair and the

 NOP would likely be sufficient, if done right away.

>>>>>

>>>>> Frankly, I believe that a warning to said individual (Zea) in terms of the requirements of the position that she

 holds as an NOSB member should come from the Executive Subcommittee (for which reason the other members of

 which are also cc'ed on this message), and I hereby request such an action, for noted rationale. If it is determined

 by some that we must consider this issue in the PDS, that is a separate longer term topic, but cannot and should not

 be used as an excuse to not call on the approach being used for our upcoming meeting in terms of full and equal

 consideration being shown by all NOSB members to all public communications be they individual, group, and/or

 from those who each of us represent in our specific position.

>>>>>

>>>>> While my position as a Producer is not specifically for Consumer/Public Interest representation, it is with

 full respect that I remind you that the NOP has made it quite clear that each of our designations does not remove

 our requirement to respectfully consider and allow to influence input from all members of the public, and for that

 reason this request is to be sure that all NOSB members are doing so even if they have personal annoyance with

 actions of groups; that those personal feelings have to be removed from our assigned duties and agreed upon

 responsibilities.

>>>>>

>>>>> Thank you for your serious consideration and attention to this experiential area of concern which I hope

 could be wrapped up at this time with your appropriate action as our elected Chair.

>>>>>

>>>>> Sincerely,

>>>>>

>>>>> Colehour

>

Fall 2015 Milestones Target date

NOP - Complete Fall 2015 NOSB meeting tentative agenda July 8, 2015

NOSB - Spring 2015 proposals due to NOP Aug 26, 2015

NOP - Post proposals, Publish FRN, Open public comment Sep 8, 2015

Discuss work agendas on ES call Sep 11, 2015

Public comment closes Oct 5, 2015

Work agendas finalized on ES call (last call before fall meeting) Oct 8, 2015

NOP - Send compiled public comments to NOSB Oct 13, 2015

Fall 2015 NOSB meeting - Stowe, VT Oct 26 - 29, 2015

Agenda

Approve notes of March 13, 2015 and April 10, 2015 (not yet available for review)

Chairs Report - JR

o Mechanism for getting public Comment late summer – e.g. open call that can be 

recorded for record.

o Review of Meeting - suggestions/changes for October?

· Advisory Board Specialist (ABS) update - MA

o Travel reimbursement vouchers

o Fall timeline

· NOP news and update - MM

· Subcommittee Reports (5 minutes each)

Policy Development (PDS) - MS

Handling (HS) - TC

Materials/GMO ad hoc (MS/GMO) - CW

Compliance, Accreditation, & Certification (CACS) - CBe

Crops (CS) - ZS

Livestock (LS) - TF

Additional Items

Adjourn


From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: example of public comment!

Date: Sunday, April 19, 2015 12:07:03 PM

 one public comment urges the NOSB to "protect our men's sperm count, keep organic strong!"... 

spending the day reading comments again.

Jean


From: McEvoy Miles - AMS

To: "Calvin Walker"

Cc: "Francis Thicke"; Brown Rosen Emily - AMS; "Tracy Favre"; Arsenault Michelle - AMS; "Stone Mac"; "Richardson Jean"; "Bondera Colehour"; "Swaffar Ashley";

"Daniels Paula"

Subject: RE: EU: Synthetic methionine

Date: Friday, April 03, 2015 10:16:21 AM

Hi Calvin,

The EU regs provide flexibility through derogations. Each competent authority (member state like Germany, Latvia, etc.) may allow up to

 5% non-organic feed through a derogation. The 5% non-organic feed is utilized to ensure adequate high methionine supplements

 though synthetic methionine is not allowed in the non-organic feed component. The EU regs also provide additional derogations -

Basic rule:

"Organic livestock shall be born and raised on organic holdings." (Regulation 834/2007, article 14(1)(a)(i))

Derogation

Under exceptional rules, "with prior authorization of the competent authority, when a flock is constituted for the first time, renewed or

 reconstituted and organically reared poultry are not available in sufficient numbers, non-organically reared poultry may be brought into

 an organic poultry production unit, provided that the pullets for the production of eggs and poultry for meat production are less than

 three days old" (Regulation 889/2008, article 42(a)).

Conversion

"Where non-organic livestock has been brought onto a holding [...], the production rules [of Regulation 834/2007 and Regulation

 889/2008] must have been applied for at least:

(c) 10 weeks for poultry for meat production, brought in before they are three days old;

(d) six weeks in the case of poultry for egg production." (Reg 889/2008, article 38(1))

Miles

From: Calvin Walker [mailto

Sent: Thursday, April 02, 2015 9:47 AM

To: McEvoy, Miles - AMS

Cc: Francis Thicke; Brown Rosen, Emily - AMS; Tracy Favre; Arsenault, Michelle - AMS; Stone Mac; Richardson Jean; Bondera Colehour;

 Swaffar Ashley; Daniels Paula

Subject: Re: EU: Synthetic methionine

Miles,

I hope your trip to Brussels went well. Did you get a chance to find out how the EU states or EU Commission deal with the use of

 synthetic methionine in organic poultry diets? Was the 5% non organic ingredients still allowed?

Best and high regards.

Calvin

Sent from my iPhone

On Apr 2, 2015, at 7:56 AM, "McEvoy, Miles - AMS" <Miles.McEvoy@ams.usda.gov> wrote:

I didn’t hear anything about this when I was in Brussels a few weeks ago. The EU Commission, organic farming groups, and

 the competent organic authorities in each EU member state were very interested in learning how U.S. organic livestock

 producers manage without antibiotics.

Miles

From: Francis Thicke [mailto:fthicke@iowatelecom.net] 

Sent: Wednesday, April 01, 2015 3:31 PM

To: Brown Rosen, Emily - AMS; 'Calvin Walker'

Cc: 'Tracy Favre'; Arsenault, Michelle - AMS; 'Stone Mac'; 'Richardson Jean'; 'Bondera Colehour'; 'Swaffar Ashley'; 'Daniels Paula';

 McEvoy, Miles - AMS

Subject: RE: EU: herbal remedies outlawed in organic

I think you are right, Emily, that all EU livestock producers must meet this regulation. If herbal remedies were outlawed

 here in the US it would be a tremendous burden for organic livestock producers.

Francis

From: Brown Rosen, Emily - AMS [mailto:Emily.BrownRosen@ams.usda.gov] 

Sent: Wednesday, April 01, 2015 10:35 AM

To: Calvin Walker; Francis Thicke

Cc: Tracy Favre; Arsenault, Michelle - AMS; Stone Mac; Richardson Jean; Bondera Colehour; Swaffar Ashley; Daniels Paula;

(b) (6)
 McEvoy, Miles - AMS

Subject: RE: EU: herbal remedies outlawed in organic

HI all,

I am not familiar with the regulation mentioned in the article, but it sounds to me like this is a new requirement for all EU

 livestock producers, not just organic. EU organic regs refer to a lot of other regulations that farmers must also follow. I

 know that some EU countries have regulated herbal remedies (e.g. Germany) extensively, just like pharmaceuticals.

I'm copying Miles in case he has some further insight,

Emily

Emily Brown Rosen

Specialist, Standards Division

USDA-AMS-NOP

www. ams.usda.gov/nop

609-737-8630 NJ office

 cell

-----Original Message-----

From: Calvin Walker [mailto

Sent: Tuesday, March 31, 2015 11:42 PM

To: Francis Thicke

Cc: Tracy Favre; Arsenault, Michelle - AMS; Stone Mac; Richardson Jean; Bondera Colehour; Brown Rosen, Emily - AMS;

 Swaffar Ashley; Daniels Paula

Subject: Re: EU: herbal remedies outlawed in organic

Miles was in the EU recently ..... He might have a source to verify.

Calvin

Sent from my iPhone

> On Mar 31, 2015, at 9:07 PM, "Francis Thicke" <fthicke@iowatelecom.net> wrote:

>

> I came across this strange article about how it is illegal to use herbal remedies for animals in place of antibiotics for

 organic livestock production in the EU. Does anyone know anything about this?

>

>

http://www.theecologist.org/News/news_analysis/2468118/eu_outlaws_animal_use_of_herbal_remedies_on_organic_farms.html

>

>

>

(b) (6) (b) (6)
From: McEvoy Miles - AMS

To: "Francis Thicke"; Brown Rosen Emily - AMS; "Calvin Walker"

Cc: "Tracy Favre"; Arsenault Michelle - AMS; "Stone Mac"; "Richardson Jean"; "Bondera Colehour"; "Swaffar Ashley"; "Daniels Paula"

Subject: RE: EU: herbal remedies outlawed in organic

Date: Thursday, April 02, 2015 8:56:07 AM

I didn’t hear anything about this when I was in Brussels a few weeks ago. The EU Commission, organic farming groups, and the

 competent organic authorities in each EU member state were very interested in learning how U.S. organic livestock producers

 manage without antibiotics.

Miles

From: Francis Thicke [mailto:fthicke@iowatelecom.net] 

Sent: Wednesday, April 01, 2015 3:31 PM

To: Brown Rosen, Emily - AMS; 'Calvin Walker'

Cc: 'Tracy Favre'; Arsenault, Michelle - AMS; 'Stone Mac'; 'Richardson Jean'; 'Bondera Colehour'; 'Swaffar Ashley'; 'Daniels Paula';

 McEvoy, Miles - AMS

Subject: RE: EU: herbal remedies outlawed in organic

I think you are right, Emily, that all EU livestock producers must meet this regulation. If herbal remedies were outlawed here in the

 US it would be a tremendous burden for organic livestock producers.

Francis

From: Brown Rosen, Emily - AMS [mailto:Emily.BrownRosen@ams.usda.gov] 

Sent: Wednesday, April 01, 2015 10:35 AM

To: Calvin Walker; Francis Thicke

Cc: Tracy Favre; Arsenault, Michelle - AMS; Stone Mac; Richardson Jean; Bondera Colehour; Swaffar Ashley; Daniels Paula; McEvoy,

 Miles - AMS

Subject: RE: EU: herbal remedies outlawed in organic

HI all,

I am not familiar with the regulation mentioned in the article, but it sounds to me like this is a new requirement for all EU livestock

 producers, not just organic. EU organic regs refer to a lot of other regulations that farmers must also follow. I know that some EU

 countries have regulated herbal remedies (e.g. Germany) extensively, just like pharmaceuticals.

I'm copying Miles in case he has some further insight,

Emily

Emily Brown Rosen

Specialist, Standards Division

USDA-AMS-NOP

www. ams.usda.gov/nop

609-737-8630 NJ office

 cell

-----Original Message-----

From: Calvin Walker [mailto

Sent: Tuesday, March 31, 2015 11:42 PM

To: Francis Thicke

Cc: Tracy Favre; Arsenault, Michelle - AMS; Stone Mac; Richardson Jean; Bondera Colehour; Brown Rosen, Emily - AMS; Swaffar

 Ashley; Daniels Paula

Subject: Re: EU: herbal remedies outlawed in organic

Miles was in the EU recently ..... He might have a source to verify.

Calvin

(b) (6) (b) (6)
Sent from my iPhone

> On Mar 31, 2015, at 9:07 PM, "Francis Thicke" <fthicke@iowatelecom.net> wrote:

>

> I came across this strange article about how it is illegal to use herbal remedies for animals in place of antibiotics for organic

 livestock production in the EU. Does anyone know anything about this?

>

>

http://www.theecologist.org/News/news_analysis/2468118/eu_outlaws_animal_use_of_herbal_remedies_on_organic_farms.html

>

>

>

06/06/12 (77 FR 33290)

Sunset Date: 6/27/2017

Subcommittee Review

Lidocaine is a local anesthetic. It numbs ONLY the area to be worked on.

The NOSB in its initial request for public comment asked:

1.     Since this material was last reviewed have alternative materials 

emerged?

2.     What is the scientific rational for what appears to be an excessively long 

withdrawal period?

3.     Is there research to indicate that a shorter withdrawal period would be 

appropriate?

Public comment did not provide any alternatives, did not provide any 

scientific rationale for the lengthy withholding period and recommendations 

were received suggesting that a very short withholding period would be

scientifically acceptable. The LS cannot make an annotation at Sunset review

 but will consider introducing a proposal to change the withholding period to 

5 days for all livestock, slaughter and dairy.

There was widespread stakeholder support for continuing to list lidocaine.

This material meets the OFPA criteria.

 I do not have a specific number of days yet which I would propose for 

Withholding, but I believe this annotation change should be fairly easy and 

meet with general support from a broad range of stakeholders.

2. Parasiticides.

Parasiticides are covered in both 205.603 and also 205.238, so changes will be 

more complex than for Lidocaine and Procaine above. But changes are needed, 

and we now have the scientific data to support our proposal. These changes will 

have a positive impact on Livestock production. If we can get the proposal out 

and get comments for October we can wait and vote next April if Comment 

indicates we are asking for too much.

The general language at 205.603 treats all parasiticides the same, but they are not 

all the same.

There are three parasiticides on the list: Ivermectin, Moxidectin and 

Fenbenzadole.

We will most likely be voting to Remove Ivermectin from the list for many 
reasons

We may or may not be recommending removal of Moxidectin

We will be likely to keep Fenbenzadole on the list.

Here are some of the notes from our Sunset template showing some of the issues 

with our present language:

1.    Fenbendazole, which is considered the most 

environmentally benign, is annotated to require the “written 

order of a licensed veterinarian". Ivermectin and Moxidectin 

have no such requirement. That may lead producers to 

choose a more environmentally detrimental parasiticide for 

convenience.

2.    Moxidectin is annotated “for control of internal parasites 

only.” However, Moxidectin is widely used as a pour-on, and 

when used in that form for control of internal parasites it is 

also a de facto control for external parasites. Moreover the 

annotation “for control of internal parasites only": was

apparently written based on incorrect information on the halflife of Moxidectin in the soil.

3.    §205.603(a)(18) requires a 90-day withholding period for 

milk or milk products from a treated animal. There seems to 

be wide consensus that 90 days is much too long of a 

withholding period, because 1) it may motivate a producer to

 withhold needed treatment of an animal because of the 

severe consequences of a 90-day withdrawal, and 2) that is 

considered an excessive withdrawal time for food safety. 

Fenbendazole and Moxidectin have no milk withdrawal time 

for use in conventional production.

4.    Ivermectin is not allowed for use in slaughter stock under the

 NOP, and it is not allowed for use in dairy animals of 

breeding age by the FDA, leaving the only legal use of 

Ivermectin to be on breeder stock before the last third of 

gestation for progeny to be sold as organic.

The newest addition to the list, Fenbenzadole, functions quite differently from 

the other 2 and the research, new TR and public comment over several years

indicates that the manner in which it is used should be modified in terms of a 

much shorter withholding time and other aspects of parasite management.

We also have public comment and research which would indicate that sheep wool

 could be sold as Organic after the withholding period.

I have a working draft proposal of the proposed changes for both 205.603 and 

205.238, but I am not quite ready to circulate it, but if necessary I can provide you

 with more detail so we can move forward and get this added to our LSAgenda.
Please let us know if we can add these to the LS Agenda right away.

Thank you

Jean
From: Jean Richardson

To: McEvoy, Miles - AMS

Cc: Arsenault, Michelle - AMS

Subject: Re: EC call

Date: Friday, November 14, 2014 12:34:46 PM

OK thank you

Jean

On Nov 14, 2014, at 12:29 PM, McEvoy, Miles - AMS wrote:

> I am in an AMS management retreat. I'll try to step out to call in to today's call but would only be available for a

 short time.

> My report would be short -

> Two NOP memos to the board next week - one on BPA, one on peer review. Both request NOSB review of these

 topics.

> I'll be in Mexico next week for equivalency negotiations/preliminary assessment.

>

> Miles V McEvoy

> Deputy Administrator

> USDA National Organic Program

>

>

>

>

> This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

From: Jean Richardson

To: Bailey, Melissa - AMS

Cc: Zea Sonnabend; Calvin Walker; Colehour Bondera; Francis Thicke; Jay Feldman; Jennifer Taylor; Mac Stone

(mac@elmwoodstockfarm.com); Lipson, Mark - OSEC; Arsenault, Michelle - AMS; Tucker, Jennifer - AMS; 

McEvoy, Miles - AMS

Subject: Re: GMO ad hoc revised report for Monday

Date: Monday, August 26, 2013 12:18:51 PM

OK - So we may not need the added conference call today?

Jean

On Aug 26, 2013, at 12:04 PM, Bailey, Melissa - AMS wrote:

All – We appreciate the attempt made to address the NOP’s concerns about this 

document. As Zea noted, the content has not changed much but it has been re-titled 

as a “report” and some of the “recommendations” re-labeled as “suggestions”. Our 

concerns have not been resolved by this revision and we can’t post the document in its

current form.

We are open to a revision that simplifies the document to provide a clear, objective 

analysis regarding the pros and cons of a seed purity standard and (given the 

fundamental obstacles identified in your analysis) then offers some realistic options to 

the full board for proceeding further. Such a revision is not achievable in the time 

frame available for the Fall meeting. We would like to regroup with you to figure out 

how to best work on the seed purity issue between now and the Spring 2014 NOSB

meeting.

Thanks, Melissa

From: Zea Sonnabend [mailto:zea@well.com]

Sent: Saturday, August 24, 2013 5:35 PM

To: Arsenault, Michelle - AMS

Cc: Calvin Walker; Colehour Bondera; Francis Thicke; Jay Feldman; Jean Richardson; 

Jennifer Taylor; Mac Stone (mac@elmwoodstockfarm.com); Bailey, Melissa - AMS; Lipson, 

Mark - OSEC

Subject: Re: GMO ad hoc revised report for Monday

Hello subcommittee,

As we discussed on our last call, here is a revision of our Seed Purity document 

into a "Report" instead of a proposal. I did not change most of the content that 

much, because as a report we can put in everything we have talked about so far. I 

did remove most track changes from the older text so that it is easier to see the 

new changes.

We only have one call left on Monday to finalize this, so please read this before 

then and either circulate revisions by email or be prepared to discuss in detail.

Regards,
Zea

On Aug 22, 2013, at 12:00 PM, Arsenault, Michelle - AMS wrote:

GMO ad hoc extra call

Monday August 26, 2013

10:00 PT/1:00 ET

This electronic message contains information generated by the USDA solely for 

the intended recipients. Any unauthorized interception of this message or the use 

or disclosure of the information it contains may violate the law and subject the 

violator to civil or criminal penalties. If you believe you have received this 

message in error, please notify the sender and delete the email immediately.

<Mail Attachment.ics>

(b) (6) (b) (6)
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Automatic reply: GMO ad hoc revised report for Monday

Date: Monday, August 26, 2013 12:18:51 PM

I am out of the office. Please contact Joan Avila at joan.avila@ams.usda.gov if you need

 assistance.

This electronic message contains information generated by the USDA solely for the intended

 recipients. Any unauthorized interception of this message or the use or disclosure of the

 information it contains may violate the law and subject the violator to civil or criminal

 penalties. If you believe you have received this message in error, please notify the sender and

 delete the email immediately.
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Automatic reply: GM Vaccine WG Update

Date: Wednesday, July 11, 2012 10:45:16 AM

I am currently out on vacation. Please contact Rita Meade (rita.meade@ams.usda.gov) at 202-

720-3252 if you need immediate assistance.

This electronic message contains information generated by the USDA solely for the intended

 recipients. Any unauthorized interception of this message or the use or disclosure of the

 information it contains may violate the law and subject the violator to civil or criminal

 penalties. If you believe you have received this message in error, please notify the sender and

 delete the email immediately.
From: Jean Richardson

To: Bailey, Melissa - AMS

Cc: Nick Maravell; Updike, Scott - AMS; McEvoy, Miles - AMS

Subject: Re: GM Vaccine WG Update

Date: Monday, July 16, 2012 2:32:02 PM

July 24, 25, 26, 27 should all be OK for me. I can work around any time except the Tuesday 

afternoon when we already have NOSB calls scheduled.

Jean

On Jul 16, 2012, at 12:12 PM, Bailey, Melissa - AMS wrote:

Jean & Nick,

I am working with APHIS to set up our first conference call for the last week of July. Any

 particular scheduling issues from your end?

Also, I have attached a draft/proposed scope for the working group. We would all 

discuss this draft on our first call, but wanted to get something in front of you for your 

consideration.

Thanks, Melissa

From: Jean Richardson [mailto:

Sent: Wednesday, July 11, 2012 10:45 AM

To: Nick Maravell

Cc: Bailey, Melissa - AMS; Updike, Scott - AMS; McEvoy, Miles - AMS

Subject: Re: GM Vaccine WG Update

Hi Melissa

I am available any time Thursday July 12 (tomorrow!) but assume there is no 

call?

I am also available Tuesday 17 between 9 am and noon or any time on Thursday 

the 19th or Friday 20th before 11 am

Let me know how you are doing setting up a meeting which includes APHIS

Thank you, Jean

On Jul 11, 2012, at 9:37 AM, Nick Maravell wrote:

Melissa

I am available on Thursday 7/12 or Friday 7/13, but I think Jean is only available 

on July 12. Please let me know how and when you want to proceed. Obviously, 

APHIS participation is key to making progress on establishing a usable list of 

GMO vaccines. APHIS should be involved from the very beginning.

Please include Jean on all of these emails so everyone is in the loop. Jean and I 

will be working very closely on this issue on behalf of the Livestock 

(b) (6)

then they are doing this of their own accord, not on behalf of the agency –that is 

entirely up to them. However, if we request that they conduct such a survey on behalf 

of the NOP or the NOSB (as the advisory board to the NOP) and/or provide specific 

questions for them to ask their membership, this would be considered information 

collection under the Paperwork Reduction Act and we would need to submit the survey

 and other documentation for comment and OMB review. The latter is not something 

we are prepared to do at this point. Just wanted to get back to you on your question. 

Please let me know if this all seems reasonable or if you have any questions. 

Thanks, Melissa

Melissa R. Bailey, Ph.D.

Director, Standards Division

National Organic Program

U.S. Department of Agriculture

Room 2646-So. (Stop 0268)

1400 Independence Ave SW

Washington, DC 20250-0268

202-260-8079

www.ams.usda.gov/nop

Organic Integrity from Farm to Table, Consumers Trust the Organic Label

Register for the NOP Organic Insider, the National Organic Program’s email notification 

service, by visiting http://bit.ly/NOPOrganicInsiderRegistration.

This electronic message contains information generated by the USDA 

solely for the intended recipients. Any unauthorized interception of this 

message or the use or disclosure of the information it contains may 

violate the law and subject the violator to civil or criminal penalties. If 

you believe you have received this message in error, please notify the 

sender and delete the email immediately.

<GM Vaccine Working Group Proposal.docx>
From: Jean Richardson

To: Francis Thicke

Cc: Michelle Arsenault; Tracy Favre; McEvoy, Miles - AMS; Jennifer Taylor; joe.dickson@wholefoods.com; Nick

 Maravell; Calvin Walker; COLEHOUR BONDERA; Zea Sonnabend; Wendy Fulwider; Jay Feldman; Carmela Beck;

Harold Austin; Mac Stone; John Foster

Subject: Re: FYI: Jim Riddle letter

Date: Sunday, October 13, 2013 4:10:04 PM

Francis

Thank you for forwarding this

Jean

Sent from my iPad

On Oct 13, 2013, at 3:51 PM, "Francis Thicke" <fthicke@iowatelecom.net> wrote:

To read Melody Myer’s original post: www.organicmattersblog.com

From Jim Riddle

October 11, 2013

To the OTA Board of Directors:

I have been involved in the organic sector since the early 1980’s as a producer,

 inspector, trainer, policy specialist, outreach coordinator, grant program

 administrator, activist and eater— as well as serving on the National Organic

 Standards Board. I have been a member of the Organic Trade Association since

 the early 1990’s, was co-author of OTA’s American Organic Standards and

 wrote OTA’s comments on the USDA’s second proposed organic rule.

OTA’s new Board President, Melody Meyer, recently wrote and released a

 divisive, inaccurate and accusatory article entitled, “Stop the lies and get behind

 your National Organic Program.”

In her article, Ms. Meyer displayed an alarming lack of understanding of the

 Organic Foods Production Act (OFPA) and the National Organic Program (NOP)

 Final Rule, as well as disrespect for public interest groups who have been part of

 the organic movement from the beginning.

For starters, Ms. Meyer stated, “In 2001 the first US organic standards were

 written into law after years of discussion, discovery and scientific review.” This

 statement is incorrect. The law, OFPA, was passed in 1990. The NOP Final Rule

 (which is a regulation, not a law) was released in December 2000 and took effect

 in October 2002.

In discussing allowed and prohibited substances on the National List, Ms. Meyer

 overlooks the fact that OFPA only allows the use of synthetic and non-organic

 substances as “exemptions.” Those exemptions are required by OFPA to sunset,

 or end, after 5 years, unless the allowances are reviewed and renewed by the

 NOSB, which has statutory authority over the content of the National List.
Ms. Meyer states, “All that’s changed is it now takes two thirds majority to vote

 to list and two-thirds to delist. “

That is a huge change, and one that does not comply with the OFPA’s clear

 language regarding the powers of the NOSB to determine substances and

 annotations on the National List; OFPA’s sunset provisions; and the need for any

 action of the Board to be based on a 2/3 majority “decisive vote.”

Despite the NOP’s new directive, OFPA (the law) has not changed. Substances

 sunset from the National List unless they are reviewed and renewed by a decisive

 2/3 vote of the NOSB. In order for listings to be legally valid, they need to be

 renewed following an affirmative vote of the Board. Any substance renewed by a

 less than 2/3 affirmative vote will certainly be subject to legal challenge.

Ms. Meyer goes on to state, “Elsewhere the article cites the “lack of public input

 on this process.” This statement is, again, outrageously bogus.“

The NOP’s new directive was issued without any discussion with the Board at a

 public meeting. There was no vote of the Board to support the directive, and no

 opportunity for members of the public to offer input to the NOSB or the NOP on

 the directive.

This situation is analogous to the 4 “retracted directives” that were issued by the

 NOP in 2004, when I served on the NOSB. Those directives would have: a)

 allowed the labeling as “organic” of products not covered by NOP standards; b)

 allowed the use of antibiotics in dairy cattle to be used in organic production; c)

 allowed the use of fish meal in livestock feed; and d) allowed the use of

 pesticides with unknown inert ingredients. They were issued with no NOSB

 consultation or public comment.

After public outcry, USDA Sec. Anne Veneman intervened, ordered the directives

 withdrawn, and ordered staff to work in close consultation with the NOSB on

 future draft rules, policies and directives. It appears that those lessons have been

 forgotten. Consulting with the NOSB on implementing OFPA is required by law.

Finally, Ms. Meyer suggests that persons with concerns “reach out to the NOP

 directly. They are always available to answer questions and concerns.” Not! The

 NOP’s website is not even operational during the shutdown!

Due to the divisiveness and inaccuracy of the new OTA President’s comments, I

 have decided to allow my OTA membership to expire.

Though I disagreed, I have maintained my OTA membership as OTA has tried to

 push through a new tax (checkoff) on all certified organic operations to fund an

 organic promotion program, instead of looking for creative ways to capture

 support dollars from retailers and consumers who benefit from organic

 production.

I have maintained my OTA membership, even though I have seen my trade
 association place its lobbying strength and resources to pass an organic checkoff

 referendum while programs that benefit organic producers, such as the national

 organic certification cost share and the organic research and extension initiative,

 have gone unfunded.

I have remained a member when I have seen OTA advocate for the allowance of

 questionable artificial (i.e. synthetic) additives used in organic food production

 and processing.

But the positions taken and attitude displayed by the OTA’s new president are too

 much. I cannot, in good conscience, renew my OTA membership.

Respectfully,

Jim Riddle

Organic Independents LLP

Winona, MN
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Automatic reply: FYI: Jim Riddle letter

Date: Sunday, October 13, 2013 4:10:05 PM

Thank you for your message.

I am not in the office at this time. I am on furlough without access to email, due to the lapse in

 federal government funding. I will return your message as soon as possible once funding has

 been restored.

For information about available government services, visit USA.gov.

This electronic message contains information generated by the USDA solely for the intended

 recipients. Any unauthorized interception of this message or the use or disclosure of the

 information it contains may violate the law and subject the violator to civil or criminal

 penalties. If you believe you have received this message in error, please notify the sender and

 delete the email immediately.
From: Jean Richardson

To: Nick Maravell

Cc: Wendy Fulwider; Colehour Bondera; C. Reuben Walker ( Mac Stone (Personal); 

joe.dickson@wholefoods.com; Tracy Favre; McEvoy, Miles - AMS

Subject: Re: GMO Vaccines Resolution

Date: Wednesday, May 23, 2012 9:39:44 PM

Hi Nick and Wendy:

I was not aware of this proposed resolution until it was raised by Nick in public session, and I 

am concerned that I will not be able to vote positively on the resolution as presently drafted.

The opening paragraphs are fine, and I would add a sentence that states that consumers assume

 that all organic products are gmo free , but I am not inclined to support a request for gmo 

labeling for a number of reasons and I cannot support that request in the "resolution".

Rather, I would prefer to send a clear message to manufacturers that organic producers and 

ACA's will be looking for non-gmo documentation for livestock vaccines as is done in 

organic processing etc.

Asking for a clear list is really important.

We are not just looking for information. NOP staff have given us some bits and pieces which 

have been not strictly accurate. We want detailed, accurate data and information with some

initial analysis by NOP.

The attached questions should not go forward at this time. They require a considerable amount

 of editing into a concise and clear list of well articulated questions

Jean

On May 23, 2012, at 6:40 PM, Nick Maravell wrote:

LC

Please review and discuss.

Nick

Attached is a DRAFT resolution of the Board on GMO vaccines

<GMO vaccine resolution>

Attached is a DRAFT of questions that could be address.

<GMO Vaccine Questions.doc>

On May 20, 2012, at 2:56 PM, Wendy Fulwider wrote:

(b) (6)
<aleabanr.gif>

Dear LC,

I have a brief ppt outline and would like your input as 

to changes, adds, etc. I only made a placeholder for 

gmo vaccines as I expect Nick and Jean will take the 

lead on that discussion. If you would like to add slides 

to the ppt, please make up slides as you need and we

 can pop them in. I will continue working on the slides 

I have made so far.

Safe travels!

Dr. Wendy K. Fulwider

Animal Care Specialist

Organic Valley / Organic Prairie

Fax: 608-625-3019

Cell:

<2012 Spring Meeting short.ppt>

(b) (6)

20 July 2015

I recently received a petition from a group of organic dairy goat producers for the 

NOP to change the 30% dry matter intake rule for dairy goats, changing it to 

“pasture access” only. We have had a certified organic dairy goat herd for 15 years 

and I would like to write in support of the current DMI rule. We have had no 

problem exceeding the 30% DMI (usually approaching 50%) during the grazing 

system and I think this rule is a key component to maintaining integrity in the 

organic label.

Arguments were made that the modern dairy goat has very high production and a 

very selective diet and that they are also natural browsers. I agree with all of this 

but feel that a well managed pasture system can enable them to thrive. I understand 

the argument that browse takes a very long time to be regenerate but we have found 

that our goats do quite well on very well managed pasture with limited judicious 

access to browse. Our browse component is very important during times of high 

heat or rain, but the majority of the intake for our goats is from very diverse pasture. 

Our goats are moved to a fresh paddock at least every 12 hours and are occasionally 

moved after 6 in certain conditions. The selectivity of the goats requires this

intensive paddock rotation to obtain good DMI, but I believe this is the case for well 

managed cow dairies as well.

Pasture access only for goats, in my experience, would result in very limited fresh 

forage intake for the goats. Without moving to a fresh and interesting paddock 

regularly, goats will do very little grazing. We have a 4 acre paddock in our 

barnyard that is part of our rotation system. This often contains beautiful forage of 

optimal height and palatability. When we bring our goats back to the barn at 

nightfall they always have access to these fields but very rarely do they choose to 

graze there. It would certainly look great for a “pasture access” system, but I think 

my goats would be taking in 90% stored feeds in such a situation.

I agree there are challenges, but I think there are challenges with every organic 

system, and there are actually many advantages to pastured goats over cows 

including access to more marginal lands, less damage to wet land, and more spritely 

movement from distant paddocks to barns. We have developed our system and our 

herd over many years and we have a productive, healthy and profitable herd. I 

really think goat farmers can rise to the challenge of meeting this DMI and I would 

hate to see the standard lowered. 

We currently milk 55 goats and graze them on 45 acres including browse and 

hayland. We graze other species on the land as well. This works well for us but I 

believe we could be successful with access to fewer acres/goat as well.

Thank you for your consideration,

Kristan Doolan
Does’ Leap LLC

Bakersfield VT 

>>> Owing to a long standing commitment I shall not be available for the Admin call on Thursday, or Exec call on

 Friday as I shall be in New York City with my daughter Sarah.

>>> Mac will run these calls for me.

>>>

>>> I will be chatting with Michelle on Monday afternoon (we also met in San Antonio for a while on Friday

 afternoon).

>>>

>>> I would like to chat by phone with you about our work over the next 6 months at least, including some ways we

 might get some good PR so there is a more balanced public record; also let's discuss where to go with aquaculture,

 and how best to deal with the 5 year motions of Jay's etc. and other items I am sure you have in mind.

>>>

>>> I am around Monday any time, and Tuesday (except HS and LS meeting times), and Wednesday morning this

 week. Do any of these times work for you?

>>>

>>> Cool and wet here, more like mid April.

>>> Cheers,

>>> Jean

>>>

>>>

>>>

>>>

>>>

>>>

>>>

>>> This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

>>

>>

>

From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Automatic reply: Harold at NOSB meeting

Date: Thursday, August 27, 2015 5:12:11 PM

I am out of the office and will return on September 8. Please contact Joan Avila at 202-720-

3252, joan.avila@ams.usda.gov if you need immediate assistance.
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Automatic reply: Hi from Vermont

Date: Sunday, April 14, 2013 12:30:41 PM

I am out of the office until April 23. Please contact Joan Avila at joan.avila@ams.usda.gov if

 you need assistance.

This electronic message contains information generated by the USDA solely for the intended

 recipients. Any unauthorized interception of this message or the use or disclosure of the

 information it contains may violate the law and subject the violator to civil or criminal

 penalties. If you believe you have received this message in error, please notify the sender and

 delete the email immediately.

From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Automatic reply: Hi from Vermont

Date: Thursday, September 26, 2013 5:33:13 PM

I am out of the office. Please contact Joan Avila at joan.avila@ams.usda.gov if you need

 assistance.

This electronic message contains information generated by the USDA solely for the intended

 recipients. Any unauthorized interception of this message or the use or disclosure of the

 information it contains may violate the law and subject the violator to civil or criminal

 penalties. If you believe you have received this message in error, please notify the sender and

 delete the email immediately.

From: Jean Richardson

To: Brines, Lisa - AMS

Cc: Lewis, Paul I - AMS; McEvoy, Miles - AMS

Subject: Re: Harold at NOSB meeting

Date: Thursday, August 27, 2015 5:12:11 PM

Hi Lisa

Thank you

This is a good foundation.

We can chat about details in September

Thank you

Jean

On Aug 27, 2015, at 1:55 PM, Brines, Lisa - AMS wrote:

Hi Jean,

This is a follow-up to your previous request below. I’m also happy to schedule a time to

 discuss additional details or concerns by phone.

You are welcome to share following information if questions arise about Harold’s 

virtual participation:

Unfortunately, Harold cannot attend the Fall NOSB meeting in person due 

to a personal matter. NOP considers this a special circumstance that 

warrants an exception to the usual practice of in-person participation.

NOP supports Harold’s virtual participation at the Fall 2015 NOSB meeting.

The Fall 2015 NOSB meeting is subject to FACA requirements. FACA does 

not prohibit remote attendance and, in fact, allows for “virtual” public 

meetings as is evident with other Federal advisory committees.

The NOSB Policy and Procedures Manual does not preclude virtual 

attendance and participation.

At the beginning of the meeting, the Chair will announce that one Board 

member is participating by phone and give him opportunities to be 

recognized and speak when appropriate.

The transcripts for the meeting will reflect that one Board member is 

participating remotely.

During the meeting, NOP will work closely with the NOSB Secretary to 

ensure that the virtual Board member’s votes are recorded.

If you have any further questions or concerns, please do not hesitate to let me know. 

I’ll be out of the office August 31-September 10, but Paul Lewis is familiar with the 

issues and can also be reached in my absence atPaulI.Lewis@ams.usda.gov (cc’d 

above) or (202) 260-9294.

Sincerely,

From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Harold

Date: Tuesday, June 02, 2015 6:12:10 PM

Hi Miles

If you have not chatted with Harold recently on the phone, now would be a good time.

His cell phone is 

Chat with me first if you wish

Cheers

Jean

(b) (6)
From: Jean Richardson

To: Mac Stone

Cc: Arsenault, Michelle - AMS; "Barry Flamm"; "Calvin Walker"; "Carmela Beck"; "Colehour Bondera"; "Harold

Austin"; "Jay Feldman"; "Jennifer Taylor"; joe.dickson@wholefoods.com; "John Foster"; "Nick Maravell"; "Tracy

Favre"; "Wendy Fulwider"; "Zea Sonnabend"; McEvoy, Miles - AMS

Subject: Re: Happy Thanksgiving!

Date: Thursday, November 22, 2012 9:01:08 AM

Thank you Mac and everyone;

Hope you are all having an organic, heritage breed turkey today, fresh chilled off the local 

farm.

Ours will be stuffed with sausage meat, apples and sage etc and served all the fixings 

including Grandma's cranberry bread and pecan pie

Happy Turkey Day

Jean

On Nov 22, 2012, at 7:42 AM, Mac Stone wrote:

We saw the PBS show “My Life as a Turkey” last night, they are truly fascinating 

creatures and many do not get the counterintuitiveness of preservation thru 

consumption. May we all take a little time to relax and enjoy friends, family and food. 

We have been thrown together to guide the most valuable food policy on earth. It is 

very rewarding to see how we quickly become friends, respect our differences, and 

build on our commonalities. Eagles are strong and beautiful when they soar, but 

turkeys stay on the ground and communicate to coexist like no other animal on earth. 

Ben Franklin was right, they should have been the National Bird. Thanks for the 

opportunity to work with a bunch of turkeys like yall. Happy Holidays, Mac

From: Arsenault, Michelle - AMS [mailto:Michelle.Arsenault@ams.usda.gov]

Sent: Wednesday, November 21, 2012 3:01 PM

To: Barry Flamm; Calvin Walker; Carmela Beck; Colehour Bondera; Harold Austin; Jay 

Feldman; Jean Richardson; Jennifer Taylor; joe.dickson@wholefoods.com; John Foster; 

Mac Stone; Nick Maravell; Tracy Favre; Wendy Fulwider; Zea Sonnabend

Subject: Happy Thanksgiving!

Hello all,

I just wanted to wish everyone a happy and safe Thanksgiving!

Talk to you next week,

Michelle

Michelle Arsenault

Advisory Board Specialist

USDA National Organic Program

1400 Independence Ave SW; Room 2640S

Washington, DC 20250-0268

Office phone: (202) 720-0081
Mobile: 

michelle.arsenault@ams.usda.gov

This electronic message contains information generated by the USDA solely for 

the intended recipients. Any unauthorized interception of this message or the use 

or disclosure of the information it contains may violate the law and subject the 

violator to civil or criminal penalties. If you believe you have received this 

message in error, please notify the sender and delete the email immediately.

(b) (6)
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Automatic reply: Happy Thanksgiving!

Date: Thursday, November 22, 2012 9:01:09 AM

I am out of the office. Please contact Rita Meade (rita.meade@ams.usda.gov) at 202-720-3252

 if you need immediate assistance.

This electronic message contains information generated by the USDA solely for the intended

 recipients. Any unauthorized interception of this message or the use or disclosure of the

 information it contains may violate the law and subject the violator to civil or criminal

 penalties. If you believe you have received this message in error, please notify the sender and

 delete the email immediately.




From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: hydroponic- Nicole Dehne?

Date: Thursday, March 19, 2015 5:33:54 PM

Hi Miles

You mentioned that Nicole had written the hydroponics article in Cornucopia, but the only one I saw was Linley

 Dixon.

Did you see another one?

Thanks

Jean
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Automatic reply: hydroponic- Nicole Dehne?

Date: Thursday, March 19, 2015 5:33:55 PM

I am out of the office. Please contact Joan Avila at 202-720-3252, joan.avila@ams.usda.gov if

 you need immediate assistance.

From: "Rakola, Betsy - OSEC" <Betsy.Rakola@osec.usda.gov>

Date: February 7, 2015 at 11:33:26 AM EST

To: "McEvoy, Miles - AMS" <Miles.McEvoy@ams.usda.gov>

Subject: Fw: How 'organic' are vegetables when they're grown in

 hydroponic greenhouses?

----- Original Message -----

From: Betsy Rakola [mailto:

Sent: Saturday, February 07, 2015 08:30 AM

To: Rakola, Betsy - OSEC

Subject: How 'organic' are vegetables when they're grown in

hydroponic greenhouses?

http://www.burlingtonfreepress.com/story/news/2014/02/14/howorganic-are-vegetables-when-theyre-grown-in-hydroponicgreenhouses-/5492347/

Sent from my iPhone

This electronic message contains information generated by the USDA solely for

the intended recipients. Any unauthorized interception of this message or the use

or disclosure of the information it contains may violate the law and subject the

violator to civil or criminal penalties. If you believe you have received this

message in error, please notify the sender and delete the email immediately.

(b) (6)

From: Jean Richardson

To: Francis Thicke

Cc: Brown Rosen, Emily - AMS; "Calvin Walker"; "Carmela Beck"; "Colehour Bondera"; "Harold Austin"; "Jay

Feldman"; "Jennifer Taylor"; joe.dickson@wholefoods.com; "John Foster"; "Mac Stone"; "Nick Maravell"; "Tracy

Favre"; "Wendy Fulwider"; "Zea Sonnabend"; Arsenault, Michelle - AMS; McEvoy, Miles - AMS; Updike, Scott -

AMS

Subject: Re: High Methionine Corn

Date: Tuesday, August 19, 2014 7:12:24 AM

Hi Francis

Fascinating article and research.

Thank you for circulating

Jean

On Aug 18, 2014, at 10:03 PM, Francis Thicke wrote:

Hello NOSB Members,

This message is intended primarily for the Livestock Subcommittee, but I thought all 

would be interested, because synthetic methionine is an issue we are all grappling 

with.

I attended a field day at a research farm in western Illinois on Saturday and saw some 

test plots of high methionine corn. The attached photo shows the high methionine 

corn on my left in the photo, with a standard corn hybrid variety on my right. Judging 

by walking through the corn plots, it appears that the high methionine corn will yield

comparable to the standard hybrid variety.

The field day featured several speakers, including Dr. Walter Goldstein, who provided 

the seed for the plot study and who spoke about his recent experience in breeding high

 methionine corn. His research shows that he is getting nearly as good, or as good, 

yields with corn varieties (both hybrid and open pollinated) that have 25 to 30% higher

methionine content than standard hybrid corn varieties. Also, several organic farmers 

in the audience spoke about their experiences growing Walter’s high methionine corn

and indicated that it yielded very well. One farmer said his combine yield monitor 

peaked at 278 bu/acre in his high methionine corn field.

Walter is going to be sending me more specific data on his yield and methioninecontent trials. I would like to have Walter speak to the LS about his research on high 

methionine corn, if the LS is willing. Walter is willing to do so.

Thanks,

Francis

<High Methionine Corn.jpg>
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Automatic reply: Hydroponics

Date: Saturday, October 26, 2013 11:01:30 AM

I am out of the office. Please contact Joan Avila at 202-720-3252, joan.avila@ams.usda.gov if

 you need immediate assistance.

This electronic message contains information generated by the USDA solely for the intended

 recipients. Any unauthorized interception of this message or the use or disclosure of the

 information it contains may violate the law and subject the violator to civil or criminal

 penalties. If you believe you have received this message in error, please notify the sender and

 delete the email immediately.
From: McEvoy, Miles - AMS

To: Jean Richardson

Cc: Bailey, Melissa - AMS; Tucker, Jennifer - AMS

Subject: RE: Hydroponics

Date: Monday, October 28, 2013 8:24:04 PM

Hi Jean,

There are a few dozen USDA organic certified hydroponic operations. We have no restrictions on organic

 hydroponics if they meet the USDA organic regulations.

Miles V McEvoy

Deputy Administrator

National Organic Program

202-720-3252

-----Original Message-----

From: Jean Richardson [mailto

Sent: Saturday, October 26, 2013 11:01 AM

To: McEvoy, Miles - AMS

Subject: Hydroponics

Hi Miles

This morning I have an urgent e-mail from some farmers to make sure organic hydroponic ag. is NOT approved As

 I recall, you said recently that it will be approved?

Here is a letter from a major very large organic tomato producer They are scheduling meetings with the VT Sec. Ag

 and Leahy staff on this topic for first week in November, and for me to be there.

The more I know the better. Call if needd. I expect that given the push for organic aquaculture this is a non starter?

Best Regards

This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

(b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Hydroponics

Date: Wednesday, January 29, 2014 11:55:25 AM

Hi Miles

I am at the annual meeting of VOF. Good turnout of farmers.

Just had a very balanced discussion on hydroponics, based on materials circulated ahead of time, and passed with

 overwhelming numbers, a motion to support the 2010 NOSB recommendation

Cheers, Jean

Sent from my iPhone
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Hydroponics

Date: Monday, February 10, 2014 4:08:27 PM

Hi Miles.

A reporter, Joel Baird, interviewed me again today for an article he is doing on hydroponics for the Burlington Free

 Press (Gannet Chain). He asked for your phone NOP phone number which I gave him. Both Senator Sanders and

 Leahy staff have called me this weekend as well. Baird says he is doing a balanced article. He understands that I am

 not taking a position and has run by me the quotes he intends to use.

Cheers,

Jean
From: Jean Richardson

To: McEvoy, Miles - AMS

Cc: Zea Sonnabend

Subject: Fwd: Hydroponics

Date: Friday, March 27, 2015 1:49:02 PM

FYI

Jean

Begin forwarded message:

From: Dave Chapman <

Subject: Update

Date: March 27, 2015 1:42:25 PM EDT

To: undisclosed-recipients:;

Bcc: 

Hi all,

Ten days ago there was a "clarification" to the task force announcement

 that first appeared in the Federal Register:

Clarification on Nominations for Hydroponic 

and Aquaponic Task Force

On March 9, 2015, the Agricultural Marketing Service (AMS) 

published a Federal Register Notice calling for nominees for a 

hydroponic and aquaponic task force. The task force will report 

to the National Organic Standards Board to (1) describe current

 hydroponic and aquaponic production methods used in organic 

production, and (2) assess whether these practices align with 

Organic Foods Production Act

and the USDA organic regulations.

AMS would like to clarify that our objective is to assemble a 

task force whose members represent a diversity of perspectives

 on the topic. Accordingly, this includes individuals who have 

not worked in hydroponics and aquaponics, but who have 

relevant experience and knowledge that will enable them to 

provide valuable contributions to the process.

As stated in the Notice, candidates with demonstrable 

knowledge of organic production or certification procedures are 

preferred.

The deadline for nominations is May 8, 2015. For further 

information please contact Mark Bradley, Assistant to the 

Deputy Administrator, National Organic Program; 

Telephone(202) 720-3252; email:

Mark.Bradley@ams.usda.gov 

(b) (6) (b) (6)
This was to change the original makeup of the task force, which was 

limited to hydroponic proponents. I think that regardless of any 

"clarifications," it is clear that Miles' intent for the task force is to create 

a report favorable to hydroponic growing being permitted in organic 

certification. It is only remarkable that Miles was so forthright in his 

original announcement. There has been considerable debate among some

 of us whether it is a sound idea to participate in a rigged game. But so 

far three of us (Davey Miskell, Eric Sideman, and myself) have agreed 

that we will put their names forward for Miles' task force. It is my hope

that many others from the traditional organic community will be willing 

to put their names forward as well. We are looking for help. All of you 

please join us!

Other news for last week is that the Organic Trade Association has 

publicly restated their support for the 2010 NOSB recommendation that 

organic hydroponic be banned from USDA certification. To read their 

statement, visit this link to our website:

http://www.keepthesoilinorganic.org/#!organic-trade-assoc/c2vx

I am surprised by their position, but Nate Lewis, their Senior Crops and 

Livestock Specialist, insisted that the OTA continues to support the 

NOSB recommendation. This again reveals the wrongness of Miles' 

contention that the only group that opposes his redefinition of organic is 

Vermont. There is no respected organic group in the US that has issued a

 statement of support for the NOP position. The petition that supported 

organic hydroponic got 100 signatures in 4 years. Our two amateur 

petitions challenging the NOP decision have gotten 1243 signatures in a 

little over a year, with more coming every week.

More soon.

many thanks,

Dave
From: Jean Richardson

To: Tracy Favre; Austin Harold; Mac Stone ( Sonnebend Zea; Calvin Walker; Carmela

 Beck

Cc: Arsenault, Michelle - AMS; Brown Rosen, Emily - AMS; McEvoy, Miles - AMS

Subject: Interim Minority Opinion Policy - Exec call

Date: Thursday, March 05, 2015 5:17:08 PM

Attachments: Minority Opinion.doc

Hi Exec

An item for discussion on March 13 on the Exec call.

Proposed Interim Minority Opinion policy.

Can the Exec adopt an Interim Policy?

It would be nice to have this more clear before we get into the Sunset materials this summer. etc.

Michelle please put on Exec Agenda

Also put Biomulch on Exec Agenda

Thank you

Jean

(b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Independent Parliamentarian?

Date: Saturday, October 11, 2014 11:20:41 AM

Importance: High

Hi Miles

Could we talk about possibly hiring Al Gage to be Parliamentarian at one day, Wednesday, 

when Jay tells me we will need one!

As it turns out the 900 FFA students will be doing parliamentary procedure and Al will be 

staying at the Gault House and thus he will not charge NOP for room, lodging, air fare, etc, 

only $750 for one day on consulting which will include in depth conversations with me and 

review of the PPM and agenda for preparation. He has looked at the PPM. He can be available

 Wednesday, but Thursday only by phone call at the hotel. But I think that will be fine. 

This will let Jenny off the hook.

I have had a good conversation with Al. He understands that we use Roberts Rules, but also 

use the PPM and "Tradition". I found him very professional (see his contact information 

below). I believe that many of the motions Jay may bring are out of the purview of the NOSB 

and thus will be ruled out of order. I will probably be interpreting them as going to the 

perceived "legality" of the manner in which Sunset was re-written and thus beyond the 

purview of the NOSB as they relate to the motions on the substances at this meeting.

I would like to allow a full discussion on the motion to send back to sub committee.

Jay understands that I want to maintain control while allowing a full discussion on the record.

Please also note that Jay has talked with Al Gage (before I talked with him). I was my usual 

very frank self with Al regards Jay and how Jays motions cause confusion. I have instructed 

Jay to have his motions short, concise and written down so we can understand them, or I will 

Rule them out of order. I also told him to pick his battles! (interestingly these comments were 

the same as what this guy Al says!).

There is an element of distrust of NOP, so having an independent Parliamentarian may be 

money well spent!

Al Gage

Professional Registered Parliamentarian-NAP

Professional Accredited Parliamentarian-SAEP

Certified Parliamentarian-AIP

www.TheParliPros.com

al@algage.com

(623)-536-8200

What do you think?

I can be reached at home today, Sunday, or Monday morning between 8 and 9.30, then on 

my cell phone off doing a problematic dairy inspection

Cheers

Jean
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: RE: hydroponics and aquaponics

Date: Friday, February 14, 2014 9:50:49 AM

I miss skiing. We used to go frequently when we lived in Olympia. Here we get snow but not good snow.

There should be an article in the Burlington paper about hydroponics coming out soon.

Interesting that aquaponics is ok, hydroponics not. There is a new restaurant in DC that has a rooftop organic

 aeroponics garden where they obtain a lot of their produce.

We are excited about developing new opportunities for underserved areas to have affordable certification options.

 Moving forward with aquaculture, apiculture and other projects. Hopefully animal welfare.

Miles V McEvoy

Deputy Administrator

National Organic Program

-----Original Message-----

From: Jean Richardson [mailto

Sent: Friday, February 14, 2014 9:44 AM

To: McEvoy, Miles - AMS

Subject: hydroponics and aquaponics

Hi Miles

There is a dinner meeting of no hydroponics people tonight in Burlington before the Winter Conference of

 NOFAVT. I will be there to listen. Just thinking of the NOC position which appears to say that aquaponics is a

 system and thus is OK for organic certification, but not hydroponics. So NOP could come out in support of

 aquaponics right now and wait a while (post April meeting anyway) before making a comment on hydroponics.

 Since there is already the Sunset and no Policy and Procedures issues for the public to shout about, no need to add

 hydroponics to the mix as a further "undermining" of NOSB "authority" and the integrity of the organic label.... Just

 an idea fabulous amount of more snow here today.

I 've been cross country skiing every day for 6 days. Yeh! I will be a reluctant member on the Exec phone call!

Jean

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 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

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(b) (6)
To: Executive Subcommittee 

From: Jean

RE : Minority Opinion 

March 5, 2015 

Based on recent work in the Livestock committee it is clear to us all that there needs to be better

articulation of the “Minority Opinion” policy and process for implementation. 

As you know PDS work has been on hold owing to the huge pressure of work for us all regards 

Sunset materials, so I am suggesting that we discuss adopting an interim policy on Minority 

Opinions in order to have clear guidance going forward over the next few months. We would 

like to add this item to the Work Agenda of PDS. 

The PPM includes the following two paragraphs for guidance at present: 

To the maximum extent possible, NOSB members should speak with one voice. Although 

there may be disagreements within NOSB committee or working group sessions, once 

NOSB members leave the session, they have the responsibility to support the integrity of 

the process, whether or not they agree with the final outcome. While NOSB members 

retain the right to express minority opinions, the public airing of dissension could strain 

interpersonal relationships and create distrust and conflict among NOSB members. Such 

stresses could undermine the NOSB’s ability to effectively carry out its role as a 

governmental advisory board. 

 (PPM page 8 Professional and Ethical Standards) 

Minority opinion: If applicable, the dissenting opinion(s) of committee or task force 

members shall be reported. A member of a committee can present a minority report to the 

committee recommendation. Such document should include reasons for opposing a 

proposed recommendation and cite where the opposition points are in the 

recommendation. In addition, the minority report could, provide alternative approaches 

or solutions from those given in the recommendation, or recommend an amendment to 

the recommendation. The minority opinion will be included as a separate document at the 

end of the recommendation. 

(PPM page 24 re Writing Committee Recommendations) 

Proposed Interim Policy on Minority Opinion 

Goal: To integrate the opinions of all subcommittee members into one comprehensive document 

so that a Minority Opinion is not necessary. 

When it is not possible for the subcommittee, during its regular deliberations on conference calls, 

to reach consensus on a proposed document as it is being reviewed and discussed, and there are 

substantive irreconcilable differences, a minority of the subcommittee may develop a written 

minority opinion. 
Such a minority opinion shall be distributed to all members of the subcommittee during the same 

period that the majority recommendation document is also being reviewed. 

Such minority opinion document should include reasons for opposing the proposed 

recommendation and cite where the opposition points are in the recommendation. In addition, the 

minority report could provide alternative approaches or solutions from those given in the 

recommendation. 

If the subcommittee is unable to integrate the minority opinion into the subcommittee 

recommendation, the Minority Opinion will be included as a separate document at the end of the 

recommendation. 

A Minority Opinion cannot be submitted after the subcommittee has voted on the 

recommendation.

I hope this is a good starting point. We will have it on the Friday Exec Agenda 

Thank you

jean
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: IOIA Training agenda Oct 4-5

Date: Tuesday, September 30, 2014 6:03:37 PM

Attachments: 2014 PA ADV Agenda draft ver6.doc

FYI

Jean


From: McEvoy, Miles - AMS

To: "Jean Richardson"

Subject: RE: Ioia Montana

Date: Tuesday, January 20, 2015 2:25:53 PM

I will not be going. We may send someone from NOP but not sure at this time. I can certainly provide you with

 some NOP slides.

Miles

-----Original Message-----

From: Jean Richardson [mailto

Sent: Saturday, January 17, 2015 7:03 PM

To: McEvoy, Miles - AMS

Subject: Ioia Montana

Hi Miles

Margaret has asked me to present the NOSB perspective at IOIA training in Montana in March and I said yes Are

 you going to this ?

If not perhaps I could take some NOP slides ?

Jean

Sent from my iPhone

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 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

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(b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: interview with Kevin Bryan and note to Anne

Date: Friday, October 18, 2013 1:03:17 PM

Hi Miles

I had my interview with Kevin Bryan this morning. I enjoyed the conversation. In preparation I had reviewed many

 documents and would like to have a brief chat with you, most especially regards proposed language changes as to

 who we "represent" as individuals. I am concerned that we are moving towards being categorized as individuals

 representing specific groups, which is not the legislative intent of OFPA. The Board as a whole unit was intended to

 be representative of Stakeholders, but NOSB members as individuals must be able to look at all sides and not just

 represent a specific group. We are not captive lobbyists. We are not elected representatives. We are appointed for

 our knowledge, gender, geography ethnicity etc....

I also feel strongly that we do not need a full blown national meeting right now, but a two day facilitated working

 session in DC, so we can get our ducks in a row and accomplish some good things, together, before the next

 general election.!

The e-mail below is not intended for circulation but I would like you to see what I sent to Anne.

PS I suggested the DC meeting on my interview call before I learned that Mac had had the same brilliant idea!!!

Gorgeous day in Vermont. Off to plant more daffodils. You cant have too many!

You should be able to reach me on cell any time in the next few days 

Cheers, Jean

> Good Morning Anne;

> I had my Interview with Kevin Bryan this morning and really enjoyed it!

> Thank you for requesting this NOSB/NOP Assessment.

> When I had first heard of the Assessment I had felt some concern over the process and its potential to be

 destructive rather than constructive.

> However, in preparing to answer the possible questions posed I learned a great deal more about the NOSP/NOP

 etc. So the OFPA/AMS/NOP/NOSB policy research I have been looking at the last few weeks has been very

 helpful. On the Board I have tended to concentrate more on the relatively black and white of materials analysis, or

 Accreditation based on my science background and inspector experience. This Assessment has allowed me time to

 step back and look at broader policy implications and ways we can work together to do a better job for the sake of

 our children and grandchildren so to speak.

>

> This is a critical time for the organic label and we cannot afford to miss the opportunity to build on what we have

 learned as individuals and through the interview process. Perhaps having the Shutdown was helpful to us because a

 meeting next week based on what I am hearing from the Board and NOP would be very stressful and potentially

 damaging to the organic community. So now is the moment to follow up with a facilitated meeting in DC so we

 can iron out differences, build understanding and map a clear path forward for better communications and

 collaboration between NOP and NOSB.

>

> I believe a two day working meeting in DC early in December, with NOSB and NOP staff (most of whom we

 have never met) would be highly beneficial to the organic label and all that that means. A good way to spend our

 tax dollars!

>

> I hope that this is an idea that you can embrace with enthusiasm, and I look forward to our next meeting in person

> Sincerely

> Jean

(b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Interview observation

Date: Friday, October 18, 2013 10:12:52 AM

Hi Miles

In preparing for "The Interview", which I just had with Kevin Bryan, the issue of "representative Board" versus

 individual Board members as "representatives" came up, and I would like to discuss this with you as I believe it is

 pretty important.

The interview went well from my perspective!

Hope you are enjoying being back at work

Cheers

Jean
Draft6 Aug 20, 2014 

IOIA Advanced Inspector Course 2014

IOIA/PCO ADVANCED INSPECTOR TRAINING COURSE - DRAFT

October 4-5, 2014

The Penn Stater Conference Center Hotel, 

State College, Pennsylvania

Early Registration: 7-9 p.m. October 3 (ask at lobby or look for signage)

PARTICIPANT AGENDA (Day 1), October 4

BREAKFAST on your own

7:00 - 8:00 Registration for late arrivals & commuters

8:00 - 8:30 Introductions

8:30-9:15 Will Your Report Stand up in Court? Matthew Michael, Director, 

Compliance and Enforcement 

Division USDA NOP, Washington, DC

9:15 – 10:15 Good Inspections vs. Poor Inspections – What 

the USDA sees inspectors doing well and not so well

Steve Ross, USDA AMS LPS, 

Assessment Services Supervisor, 

Colorado

10:15 – 10:30 BREAK

10:30 -12:00 Organic Aquaculture George Lockwood, Chair NOP 

Aquaculture Working Group, 

California

12:00 - 1:00 LUNCH

1:00 - 5:30 Improving the In-Out Balance for Processing 

Operators, Inspectors, and Certifiers – 

workshop

Includes BREAK

Margaret Scoles, IOIA Executive 

Director, and Luis Brenes, IOIA 

Trainer, Costa Rica 

DINNER on your own 

Festive evening - planning underway

PARTICIPANT AGENDA (Day 2), October 5

8:30 – 12:00 Livestock Feed Audits – Grazing and NonGrazing Season - in a Multi-species System

Includes BREAK

Sarah Flack, Inspector, Vermont

12:00 pm L U N C H

1:00 - 2:00 Improving the Exit Interview Margaret Scoles and assistants

2:00 – 5:00 Grower Group Inspection and Certification –

applied to contracted poultry production 

Includes BREAK

Luis Brenes and Brian Magaro, 

Inspector, Pennsylvania

5:15 Distribution of Certificates

Acceptance Criteria for IOIA Training

Participants in IOIA Advanced Inspector Training courses must meet course acceptance 

criteria, including prior completion of two inspector training courses and 2 years inspection 

experience with at least 20 inspections or 1 year inspection experience with at least 30 

inspections. 

Requests for exceptions to the requirements should be addressed to the IOIA Executive 

Director. Advanced Inspector Training Certificates of Completion are given to those who 

attend all sessions and meet acceptance criteria. Participants who do not meet these criteria 

are welcome to attend and will receive Certificates of Completion for Organic Inspection 

Workshop. 
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Fwd: IOIA Training Aquaculture

Date: Tuesday, September 16, 2014 1:36:41 PM

Miles, 

I would like to understand George's present NOP role before I attend the IOIA training

October 3,-6, so I do not put my foot in it!. Please advise. Thank you.

George S. Lockwood, California

George Lockwood is a pioneer in aquaculture as well as organic aquaculture. He formed his first fish farming business, Monterey Abalone

Farms, Monterey California, in 1972 to domesticate abalone, a very popular shellfish in California. He then combined abalone production

with sea urchins, salmon and oysters in an integrated system using cold, pure and nutrient rich seawater pumped from the deep ocean.

This unique system is the forerunner of advanced organic fish farming. In addition to these aquatic animals, this system includes culturing

 various species of micro and macro-algae for feed. That advanced system was operated in Hawaii.

He became interested in organic aquaculture in 1999 and served in various feasibility studies between then and 2005 when the Secretary

 of Agriculture appointed a 12-member Aquaculture Working Group to assist NOP and NOSB in the development of organic aquaculture.

He was named chair of AWG by the Secretary at the time. In 2010, after close consultation with NOSB, final recommendations were 

advanced to NOP for standards to be included in the Final Rule. Under his leadership, AWG then responded to a second assignment of

NOP to submit petitions to NOSB for the allowance of use of ten synthetic substances for the organic production of aquatic plants and

aquatic animals. Allowance of these materials is still under consideration by NOSB.

George is a past president of the World Aquaculture Society, and a founder and several term president of the California Aquaculture

Association. He has participated in many commissions for our federal, state, and local governments pertaining to aquaculture and other

matters. If workable standards are adopted in the Final Rule and necessary synthetic materials allowed, George intends to enter the

organic production of salmon, oysters, tilapia, abalone and sea urchins with his integrated system that recycles nutrients and 

incorporates many other organic principles.

Brian

Begin forwarded message:

From: Jean Richardson <

Date: September 14, 2014 8:28:56 AM EDT

To: Miles - AMS McEvoy <

Subject: IOIA Training/NOFA talk

Hi Miles

* I am doing the IOIA Advanced training this October and note that George

Lockwood is giving a presentation on organic aquaculture. He lists himself as

Chair of the NOP Aquaculture Working Group. Does that still exist. Is it still

funded by NOP? If we could chat about this prior to the training that might be

good.

* NOFA VT Winter Conference. Enid was thinking that an introduction at the

main lunch gathering of everyone, followed by a lunchtime "Listening Session"

with me to facilitate might be a good way to give you the best access to a broad

cross section of folks. It is on the UVM campus. Do you want to have some

faculty, Extension, NRCS there?

Cheers

Jean

(b) (6)(b) (6)
From: McEvoy, Miles - AMS

To: Jean Richardson (

Subject: Jean Richardson call

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 or the use or disclosure of the information it contains may violate the law and subject the violator to civil or criminal penalties. If you believe you have

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(b) (6)
From: McEvoy, Miles - AMS

To: Jean Richardson (

Subject: Jean Richardson call

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 or the use or disclosure of the information it contains may violate the law and subject the violator to civil or criminal penalties. If you believe you have

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(b) (6) (b) (6)
From: McEvoy, Miles - AMS

To: Jean Richardson (

Subject: Jean Richardson call

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 or the use or disclosure of the information it contains may violate the law and subject the violator to civil or criminal penalties. If you believe you have

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From: McEvoy, Miles - AMS

To: "Jean Richardson (

Subject: Jean Richardson call

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 or the use or disclosure of the information it contains may violate the law and subject the violator to civil or criminal penalties. If you believe you have

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(b) (6) (b) (6)
From: McEvoy, Miles - AMS

To: "Jean Richardson (

Subject: Jean Richardson call

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 or the use or disclosure of the information it contains may violate the law and subject the violator to civil or criminal penalties. If you believe you have

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(b) (6) (b) (6)
From: McEvoy, Miles - AMS

To: Jean Richardson (

Subject: Jean Richardson call

(b) (6) (b) (6)
From: McEvoy, Miles - AMS

To: "Jean Richardson (

Subject: Jean Richardson call

(b) (6) (b) (6)
From: McEvoy, Miles - AMS

To: Jean Richardson (

Subject: Jean Richardson call

(b) (6) (b) (6)
From: McEvoy, Miles - AMS

To: "Jean Richardson (

Subject: Jean Richardson call

(b) (6) (b) (6)
From: McEvoy, Miles - AMS

To: Jean Richardson (

Subject: Jean Richardson

This electronic message contains information generated by the USDA solely for the intended recipients. Any unauthorized interception of this message

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(b) (6)
From: McEvoy, Miles - AMS

To: Jean Richardson (

Subject: Jean Richardson

This electronic message contains information generated by the USDA solely for the intended recipients. Any unauthorized interception of this message

 or the use or disclosure of the information it contains may violate the law and subject the violator to civil or criminal penalties. If you believe you have

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(b) (6)
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Re: Jean Richardson

Date: Monday, May 05, 2014 8:01:21 AM

That's right

Miles V McEvoy

Deputy Administrator

USDA National Organic Program

On May 5, 2014, at 7:47 AM, "Jean Richardson" < wrote:

This message is blank - My Mac does not read the attachment. I assume it is

 confirmation of our call at 1 pm on Tuesday

Jean

On May 4, 2014, at 7:38 PM, McEvoy, Miles - AMS wrote:

This electronic message contains information generated by the USDA

 solely for the intended recipients. Any unauthorized interception of

 this message or the use or disclosure of the information it contains

 may violate the law and subject the violator to civil or criminal

 penalties. If you believe you have received this message in error,

 please notify the sender and delete the email immediately.

<Mail Attachment.ifb>

(b) (6)
From: McEvoy, Miles - AMS

To: Bradley, Mark - AMS; Holtzman, Max - OSEC; Bailey, Melissa - AMS; Mac Stone

 ( Richardson Jean; jfeldman@beyondpesticides.org; Carmela Beck

 (carmela.beck@driscolls.com)

Cc: Rhonda Cook (

Subject: RE: Maine Travel

Date: Tuesday, July 23, 2013 8:12:29 PM

My cell number is See you tomorrow.

Miles

Miles V McEvoy

Deputy Administrator

National Organic Program

From: Bradley, Mark - AMS 

Sent: Tuesday, July 23, 2013 2:34 PM

To: Holtzman, Max - OSEC; McEvoy, Miles - AMS; Bailey, Melissa - AMS; Mac Stone

 ( Richardson Jean; jfeldman@beyondpesticides.org; Carmela Beck

 (carmela.beck@driscolls.com); Bradley, Mark - AMS

Cc: Rhonda Cook (

Subject: Maine Travel

Greetings All,

We are looking forward to seeing each of you during our upcoming visit to review aquaculture

 operations in Maine. If possible, Sebastian would like to meet with us briefly after we arrive on

 Wednesday evening for an informal greeting and to firm up schedules for Thursday’s tour. If you

 are available around 7 p.m. at the Comfort Inn, we can meet in the vicinity of the lobby. If not, we

 will see you in the lobby of the Comfort Inn in Ellsworth for a 7:30 departure on Thursday morning.

A final itinerary is attached. If you have trouble en route or need assistance, please do not hesitate

 to call me.

Cell numbers for participants in travel status are:

Sebastian Belle – 

Max Holtzman – 

Miles McEvoy –

Melissa Bailey – 

Mark Bradley – 

Mac Stone – 

Jean Richardson – 

Jay Feldman – 

Carmela Beck – (

Travel safely...

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)(b) (6) (b) (6) (b) (6)
Mark Bradley
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Re: Maine aquaculture trip?

Date: Tuesday, June 18, 2013 3:43:05 PM

Trenton, Maine

Miles V McEvoy

Deputy Administrator

USDA National Organic Program

On Jun 18, 2013, at 3:19 PM, "Jean Richardson" < wrote:

> OK good dates for me.

> Location?

>

> On Jun 18, 2013, at 2:50 PM, McEvoy, Miles - AMS wrote:

>

>> Hi Jean

>> The trip is scheduled for July 25 with travel on July 24 and 26. We will be sending out details shortly.

>>

>> Miles McEvoy

>> Deputy Administrator

>> National Organic Program

>> 202-720-3252

>>

>>

>>

>> -----Original Message-----

>> From: Jean Richardson [mailto: On Behalf Of Jean Richardson

>> Sent: Tuesday, June 18, 2013 11:01 AM

>> To: McEvoy, Miles - AMS

>> Subject: Maine aquaculture trip?

>>

>> Hi Miles

>> I am back from Europe and organizing my consulting and NOSB work plan for the next few months.

>> Is there a date yet for the Maine trip?

>> Thank you

>> Jean

>>

>>

>>

>>

>>

>>

>> This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

>>

>

>

(b) (6) (b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS; Bradley, Mark - AMS

Bcc: Arsenault, Michelle - AMS

Subject: Maine aquaculture site visit

Date: Thursday, July 11, 2013 12:13:56 PM

Hi Miles:

I received an e-mail early this morning from Mac asking if, as a member of the Livestock sub-committee, I could

 substitute for Tracy (Livestock Chair) for the visit to the Maine aquaculture facilities on Thursday July 26th. I have

 been able to re-organize my work schedule and can thus accept this invitation.

I shall drive over to the coast and join everyone at the Comfort Inn in Ellsworth Maine, on the afternoon of

 Wednesday July 24, and drive home on Friday 26

Thank you

Jean

Jean Richardson Ph.D.

Consultant

North Ferrisburgh

VT 05473

 (mobile and text)

(b) (6) (b) (6) (b) (6)
From: Jean Richardson

To: Mac Stone

Cc: Arsenault, Michelle - AMS; Calvin Walker; Carmela Beck; Colehour Bondera; Francis Thicke; Harold Austin; Jay

 Feldman; Jennifer Taylor; joe.dickson@wholefoods.com; John Foster; Nick Maravell; Tracy Favre; Wendy

 Fulwider; Zea Sonnabend; Brines, Lisa - AMS; Bailey, Melissa - AMS; McEvoy, Miles - AMS

Subject: Re: Louisville travel guide update

Date: Monday, September 09, 2013 7:19:20 PM

Friday field trips sound great

After all the week's drama!

I am glad I have not yet made flight reservations

I am up for all of them between 9 am and when I have to get to the airport for the plane

Thank you Mac

All the best from Vermont where we had frost yesterday and expect 85 degrees Wednesday!

Jean

Sent from my iPad

On Sep 9, 2013, at 2:30 PM, "Mac Stone" < wrote:

Boys and Girls and Nick,

 I can arrange tours Monday morning for early arrivers of the KY State

 University Aquaculture facility, about a one hour drive from the hotel and/or a tour of

 our farm another 30 minutes east from there. On Friday I can offer a menu of items to

 choose, depending on how early you want to get up and out.

<!--[if !supportLists]-->1. <!--[endif]-->9am aquaculture tour KSU Frankfort

<!--[if !supportLists]-->2. <!--[endif]-->10:30 Elmwood Stock Farm Tour

<!--[if !supportLists]-->3. <!--[endif]-->12 noon Keeneland Race track (historic,

 elegant, small facility)

<!--[if !supportLists]-->4. <!--[endif]-->3pm Woodford Reserve Historic distillery

Return to Looeyville or on to Lexington downtown area.

I can also try to arrange a horse farm tour, you have to see them to believe it.

Let me know who is interested, Thanks, Mac

From: Arsenault, Michelle - AMS [mailto:Michelle.Arsenault@ams.usda.gov] 

Sent: Monday, September 09, 2013 1:51 PM

To: Calvin Walker; Carmela Beck; Colehour Bondera; Francis Thicke; Harold Austin; Jay

 Feldman; Jean Richardson; Jennifer Taylor; joe.dickson@wholefoods.com; John Foster;

 Mac Stone; Nick Maravell; Tracy Favre; Wendy Fulwider; Zea Sonnabend

Cc: Brines, Lisa - AMS; Bailey, Melissa - AMS; McEvoy, Miles - AMS

Subject: Louisville travel guide update

Hi team!

Attached, please find an updated version of the travel guide for Louisville. Lisa B always

 manages to catch my typos, which is a good thing! I’ve also added a Galt-House fact

 sheet that contains handy information about our host venue and the surrounding area.

(b) (6)
Thanks!

Michelle

Michelle Arsenault

Advisory Board Specialist

USDA National Organic Program

1400 Independence Ave SW; Room 2640S

Washington, DC 20250-0268

Office phone: (202) 720-0081

Mobile: 

michelle.arsenault@ams.usda.gov

This electronic message contains information generated by the USDA solely for

 the intended recipients. Any unauthorized interception of this message or the use

 or disclosure of the information it contains may violate the law and subject the

 violator to civil or criminal penalties. If you believe you have received this

 message in error, please notify the sender and delete the email immediately.

(b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: List of NOSB items sitting at NOP?

Date: Friday, August 21, 2015 6:36:50 PM

I don't think so

I am trying to help public understand scope of work in pipeline and our present NOSB work agendas to help public

 understand limitations about what we can realistically take on and also I will probably be asking NOP to give Nosb

 an up date on where pending Nosb items are sitting etc

Sent from my iPhone

On Aug 21, 2015, at 6:30 PM, McEvoy, Miles - AMS <Miles.McEvoy@ams.usda.gov> wrote:

Do you need anything else?

Miles

-----Original Message-----

From: Jean Richardson [mailto

Sent: Friday, August 21, 2015 5:16 PM

To: McEvoy, Miles - AMS

Subject: List of NOSB items sitting at NOP?

Hi Miles

You must have a list of NOSB items which are still sitting in NOP waiting for time and space to move on? If so can

 you send it to me.? Informal list is fine Thank you Jean

(b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS; Brown Rosen, Emily - AMS

Subject: List of NOSB backlog

Date: Tuesday, August 25, 2015 2:43:57 PM

Hi Miles and Emily

I am looking for an informal list of NOSB recommendations etc which are still sitting at NOP waiting for some sort

 of action, such as "calculating percentage organic in multi ingredient products". can you please send to me.

Thank you

Jean
From: Jean Richardson

To: michael Sligh

Cc: AGSEC - OES; Adrienne Wojciechowski@Judiciary-dem.senate.gov; Megan.Debates@mail.house.gov; McEvoy,

 Miles - AMS

Subject: Re: Letter regarding NOP/NOSB

Date: Monday, June 02, 2014 2:09:08 PM

Importance: High

Hi Michael

Thank you for your eloquent and articulate letter to Secretary Vilisak

It will be good to get these issues discussed in Washington and reviewed relative to the Legislative Intent of OFPA

 and the future potential impact of these changes under a different Administration.

In the meanwhile the NOSB will work with due diligence using the new Five Year Review (Sunset) procedures.

Best Regards

Jean

Dr. Jean Richardson, Chair NOSB

Vermont 05473

On Jun 2, 2014, at 9:47 AM, michael Sligh wrote:

> Dear Mr. Secretary,

>

> Please find enclosed an urgent letter regarding recent actions by your Department that affect the organic

 community.

>

> Please confirm and advise,

>

> Sincerely Yours,

>

> Michael Sligh

> Founding Chair NOSB

>

> =============================

>

>

> <Letter to Sec..pdf>
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: RE: Leahy and NOSB

Date: Friday, February 10, 2012 5:05:26 PM

Ok, thanks. I'm sure you'll have words of wisdom for the Senator.

-----Original Message-----

From: Jean Richardson [mailto

Sent: Friday, February 10, 2012 5:05 PM

To: McEvoy, Miles - AMS

Subject: Leahy and NOSB

Hi Miles:

I came up with a few lines for Senator Leahy for his brief comments to the NOFA VT Conference for lunch time

 tomorrow and have sent them on to his staff guy here in Vermont.

 I will also meet with the Senator before he speaks So don't worry about sending me anything. I am sure you have

 plenty of things on your desk.!

Best Regards,

Jean Richardson, Vermont

This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

(b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS; Alonzo, Anne - AMS

Subject: Lawsuit re Sunset

Date: Wednesday, April 08, 2015 11:31:10 AM

Morning!

Read the lawsuit

Feel free to give out both my phone numbers if asked

Let's be sure the court does not stay our sunset work!

Jean

Sent from my iPhone
From: McEvoy Miles - AMS

To: Jean Richardson

Subject: RE: Keep the soil in organic growing!

Date: Thursday, January 09, 2014 9:03:20 AM

Thanks Jean for keeping me in the loop. Dave Chapman has also reached out to me and I’ll be speaking with him next

 week.

Best,

Miles

From: Jean Richardson [mailto On Behalf Of Jean Richardson

Sent: Thursday, January 09, 2014 9:01 AM

To: McEvoy, Miles - AMS

Subject: Fwd: Keep the soil in organic growing!

Hi Miles

I am not playing an advocacy role on hydroponics, but I am in the loop and therefore sending you the latest

petition on Hydroponics which is circulating. 

Dave Chapman called me again yesterday and talked at great length, and he and the other guys are keeping our

sec of Ag (Chuck Ross) and Senator Leahy staff in the loop.

The economic issues are foremost in the minds of most producers. Loss of US tomatoes to very cheap Mexican

organic and non-organic hydroponic tomatoes is of paramount concern.

And so if approved by NOP, despite NOSB recommendation, there will be the demand to label tomatoes as

hydroponic (like GMO labeling)....

All for now

Jean

From: vof@nofavt.org [mailto:vof@nofavt.org]

Sent: Tuesday, January 07, 2014 2:57 PM

To: misktome@gmavt.net

Subject: Keep the soil in organic growing!

You're receiving this email because you are a certified organic operation with Vermont

 Organic Farmers, LLC (VOF).

You may unsubscribe if you no longer wish to receive our emails.

VOF logo

Dear VOF Certified Producers,

We are forwarding an important petition started by one of

 our long-time certified growers, David Chapman, owner

 and operator of Long Wind Farm, urging the NOP to

(b) (6)
 officially prohibit hydroponics from obtaining organic

 certification. Please read on for more background a letter

 from David.

Click here to sign the petition.

Background:

In 2010, the National Organic Standards Board (NOSB) passed a

 recommendation prohibiting crop production systems that eliminate

 soil, such as hydroponics and aeroponics, from obtaining organic

 certification. In this recommendation the NOSB clarified that soilplant ecology is at the foundation of organic farming. Despite the

 fact that the Organic Food Production Act mandates that the NOSB

 advise the National Organic Program (NOP) on implementing the

 organic regulations, this recommendation has yet to be accepted

 and added to the law.

Currently, some certification agencies certify hydroponic operations as

 organic despite the NOSB recommendation, and the NOP allows this

 practice to continue unrestricted. Mexico, Canada, Japan, New

 Zealand, and 24 European countries, (including Holland, England,

 Germany, Italy, France, and Spain) all prohibit hydroponic vegetable

 production to be sold as organic in their own countries, but not in the

 United States. Historically, Vermont Organic Farmers has never

 certified hydroponic operations, based on the idea that it is not

 compatible with organic farming principles.

Click here to tell the NOP to keep the soil in organic growing.

Please note we will be discussing this and other important topics

 at the VOF Annual Meeting on Wednesday, January 29th from

 10am-2pm at the VT Farm Show held at the Champlain Valley

 Exposition, in the Hamlin Room. (Click here to RSVP for the Annual

 Meeting.)

Thank you for your support of this important issue and we hope to see

 you at the meeting!

Regards,
Nicole Dehne

VOF Program Administrator

Hi to all VOF members,

I have been dismayed by the growing surge of "hydroponic organic"

 tomatoes from Mexico in the wholesale market in the last few years.

 In my mind these are not organic. The NOSB agrees with me, but the

 NOP is ignoring their recommendation. I am starting a petition to

 protest the current USDA standards that fail to address hydroponic

 vegetable production. By omission, they are permitting this, and more

 and more hydroponic production is coming into the US.

If you agree that hydroponic is not organic, and that the NOP should

 not ignore the NOSB, then please sign this petition. It is very quick

 and easy.

Thanks,

Dave Chapman

Long Wind Farm

East Thetford, VT

Forward email

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please notify the sender and delete the email immediately.
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: jeans comments on sunset -not for circulation

Date: Monday, October 20, 2014 5:50:14 PM

great

On Oct 20, 2014, at 5:33 PM, McEvoy, Miles - AMS wrote:

> Looks good - I have a few minor points of clarification that I'll send you.

> Miles

>

> -----Original Message-----

> From: Jean Richardson [mailto

> Sent: Monday, October 20, 2014 5:14 PM

> To: McEvoy, Miles - AMS

> Subject: jeans comments on sunset -not for circulation

>

> Miles

> I ran this by my core board members last week and they seem to like it. OK?

> I am trying to not avoid the elephant in the room.

> Jean

>

>

>

>

>

> This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

(b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: jeans comments on sunset -not for circulation

Date: Tuesday, October 21, 2014 8:38:41 AM

Hi Miles,

thank you for the 2002 catch and for reviewing the very brief comments. Much appreciated.

I will re-think wording for the end. I understand correct NOP language and would write it as you have for

 publication or a general talk but here I am trying for Kindergarten clarity simply to help them understand the

 upcoming vote only - Everyone will be a bit stressed and too many words makes it confusing. And not every

 member has been on the CS or HS committees and in the sunset weeds so to speak.

Jean

On Oct 21, 2014, at 8:00 AM, McEvoy, Miles - AMS wrote:

> Let me know if you have any questions.

> Miles

>

> -----Original Message-----

> From: Jean Richardson [mailto

> Sent: Monday, October 20, 2014 5:14 PM

> To: McEvoy, Miles - AMS

> Subject: jeans comments on sunset -not for circulation

>

> Miles

> I ran this by my core board members last week and they seem to like it. OK?

> I am trying to not avoid the elephant in the room.

> Jean

>

>

>

>

>

> This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

> <Sunset comments JR-miles.doc>

(b) (6)
From: Jean Richardson

To: FAMU Register

Cc: Tracy Favre; Harold Austin; Ashely Swaffar; Calvin Walker; COLEHOUR BONDERA; Mac Stone

(mac@elmwoodstockfarm.com); Zea Sonnabend; Nick Maravell; Paula Daniels; Carmela Beck; Tom Chapman; 

Francis Thicke; Lisa de Lima; Arsenault, Michelle - AMS; Brown Rosen, Emily - AMS

Bcc: McEvoy, Miles - AMS

Subject: Re: Jean, Public Comment sessions September 22 and 29

Date: Wednesday, June 24, 2015 1:01:44 PM

Hi Jennifer:

The idea is that a farmer may be more likely to take an hour to be on a webinar public 

comment in September in front of his/her computer, or at an Extension office, rather than 

waste time, money and the environment to fly to a meeting to talk for 3 minutes. And he or 

she would be given more time to speak and answer questions on a webinar format than at the 

October meeting.

But that same person could not also talk in October, although there is no limit in how much 

written comment they can send in. And in October, public oral comment time will be filled to 

the number of hours allotted, and a waiting list in place as usual.

If I understand your other question correctly, the Webinar public comment session will be 

available to all the public pretty much immediately. Certainly that is the way we do it with 

other organizations or universities etc.

Hope that clarifies

Thank you

Jean

On Jun 24, 2015, at 12:14 PM, FAMU Register wrote:

Thank you so much Jean. We do think that this may be great, especially if

 it is used to be inclusive of all comments and the need to update 

comments during the following NOSB public meeting. 

Hopefully not used to organically squash stakeholder/public 

dialog/comments.

Just a question, will the September oral comments of one who is 

associated with an agency or organization that will be participating in the 

NOSB public meeting - in any way hinder the agency's/organization's 

ability to participate through oral and written public comment during our

NOSB public meetings? 

AND when would we provide this discussion to the public for public input; 

and addition to the PPM - or is this cause?
We know you have this all worked out, we appreciate your thoughts and 

all that you are doing. 

Thank you so much.

Best regards,

Jennifer Taylor

On Wed, Jun 24, 2015 at 10:23 AM, Jean Richardson <

wrote:

Hi NOSB members:

As you know, we are having two public comment sessions in September in 

order to be able to reach a broader audience, get comment early and save us 

time in October at our meeting, and hopefully reduce our carbon footprint a bit .

 The days in September are Tuesdays which are already on your busy calendars 

- September 22 and 29 from 1-4 ET, so you can all be present. Oral commenters

 in September will get maybe 7 minutes? plus questions ... am not sure yet. So 

this should hopefully attract speakers. Speakers in September will not speak in 

October. How will we deal with the demand to speak on Monday October26?

not sure yet! I am encouraging written comment.

We are also working to try to get a public Docket system as you know.

And we are working to somehow spread the Sunset Review materials over more

 than one meeting/year in order not to have this bottle neck situation every five 

years.

These September will be formally announced in the Federal Register of course, 

with instructions, at the beginning of July.

But in the meanwhile I was thinking it might be a good idea for you to be in

touch with your stakeholder groups to get it on their calendars:

Here is our timetable:

Our documents all have to be to Michelle by August 26, and Posted on the FR 

on September 8. So the public will have been able to read our postings. I am 

encouraging my stakeholders to get us written material sooner rather than at the 

last minute. They all have plenty of notice as to what we are looking at and

where we may be headed. If a stakeholder sends you some useful information 

during the summer as you are working on materials be sure to remind them to 

send it in as formal public comment in September so all the public can see the

information.

As always, please call me any time-on my mobile phone or home office.

Cheers

(b) (6)
Jean
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Automatic reply: maine!

Date: Monday, July 01, 2013 12:23:28 PM

I am out of the office. Please contact Joan Avila at joan.avila@ams.usda.gov if you need

 assistance.

This electronic message contains information generated by the USDA solely for the intended

 recipients. Any unauthorized interception of this message or the use or disclosure of the

 information it contains may violate the law and subject the violator to civil or criminal

 penalties. If you believe you have received this message in error, please notify the sender and

 delete the email immediately.
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: maine!

Date: Monday, July 01, 2013 12:23:28 PM

Hey Miles, I quite understand. ! No problem

Jean
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Meeting 5.30?

Date: Monday, February 03, 2014 4:49:08 PM

Hi miles

Are still for meeting at 5.30 at zayin ya

Jean

Sent from my iPad
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Fwd: Media request // Modern Farmer magazine

Date: Monday, July 27, 2015 9:12:48 AM

Importance: High

Want to give me a quick phone call?

Thank you

jean

Begin forwarded message:

From: 

Date: July 27, 2015 8:52:39 AM EDT

To: " <

Subject: Media request // Modern Farmer magazine

Dear Ms. Richardson,

We are doing a story on the growth of organic farming and wanted to invite input

from you as the chair of the NOSB.

Can you clarify the reasons why the Sunset Clause was changed in September

2013 to require a 2/3 vote to remove substances from the national list? How do

you respond to those that say this move veered from the intent of the law?

As for the Cornucopia Institute's claims that a number of certified organic farms 

are not following the standards for livestock, do you know if the USDA 

investigating the 14 farms that were photographed showing few or no animals on 

pasture? While there are valid reasons that the animals would not be on pasture at 

all times, the fact that such a large number of farms had no animals out in the 

middle of the day early in the grazing season would seem to reinforce the idea 

that something was askew.

We are on a short deadline for the story, so a quick response would be very much 

appreciated. A written response would be fine, though I'd be happy to speak via 

phone today, as well.

Thank you,

Brian Barth

Contributing editor

ModernFarmer.com

613-421-9745

(b) (6)(b) (6) (b) (6)
From: McEvoy, Miles - AMS

To: Arsenault, Michelle - AMS

Cc: Jean Richardson; Brines, Lisa - AMS

Subject: Re: Materials Subcommittee request for a spring 2015 panel

Date: Tuesday, December 09, 2014 8:06:41 AM

What is the purpose? Who do they want to invite?

Miles V McEvoy

Deputy Administrator

USDA National Organic Program

On Dec 8, 2014, at 2:27 PM, "Arsenault, Michelle - AMS"

 <Michelle.Arsenault@ams.usda.gov> wrote:

Hi Miles and Jean, 

The Materials subcommittee discussed the potential of having a panel at the spring

 2015 meeting to discuss seed purity in relation to the following:

Prevention Strategies for Excluded Methods in Crops and Handling – “... ZS noted that

 she would like to include a piece on non-organic feed, and will assist FT with this. The

 members discussed having an expert panel at the spring 2015 meeting to discuss the

 seed component part of this topic. MA will discuss this with the NOSB Chair and the

 Deputy Administrator and report back to the Subcommittee. The NOP noted that past

 panels have included 3 or 4 panelists. The group discussed several possible panelists

 and will refine the list. The NOP asked that the MS expand the bios for each of the

 people they are considering in an effort to seat a panel representative of the

 community.

Our next call is tomorrow and I will provide an update if there is one.

Thanks,

Michelle

Michelle Arsenault

Advisory Committee Specialist

USDA National Organic Program

1400 Independence Ave SW; Room 2638S

Washington, DC 20250-0268

Office voicemail only: (202) 720-0081

Mobile: 

michelle.arsenault@ams.usda.gov

(b) (6)
This electronic message contains information generated by the USDA solely for the intended

 recipients. Any unauthorized interception of this message or the use or disclosure of the

 information it contains may violate the law and subject the violator to civil or criminal

 penalties. If you believe you have received this message in error, please notify the sender and

 delete the email immediately.
From: Jean Richardson

To: Zea Sonnabend

Cc: Arsenault, Michelle - AMS; McEvoy, Miles - AMS; Brown Rosen, Emily - AMS; Calvin Walker

Subject: Re: Materials SC Seed panel

Date: Tuesday, February 10, 2015 12:50:27 PM

I will be on the ES call on my mobile with headset, in my Honda truck, and Miles should be able to call in when he

 lands! Crazy I know! And Tracy can take over as Vice Chair if needed. And Emily will be on the call for NOP as

 well.

On Feb 10, 2015, at 11:15 AM, Zea Sonnabend wrote:

> After ESIs okay with me, but how are we going to have the ES call with Jean and Miles at the airport?

> Zea

>

> Sent from my iPad

>

>> On Feb 10, 2015, at 7:45 AM, Arsenault, Michelle - AMS <Michelle.Arsenault@ams.usda.gov> wrote:

>>

>> As soon as you confirm the time/date let me know so I can get this on people's calendars. Miles, is 2:30 going to

 work if you land at 1:10? Am I inviting the entire MS or just the folks that are copied here?

>>

>> Thanks,

>> Michelle

>>

>> -----Original Message-----

>> From: McEvoy, Miles - AMS

>> Sent: Tuesday, February 10, 2015 8:33 AM

>> To: Brown Rosen, Emily - AMS; Zea Sonnabend; Calvin Walker

>> Cc: Jean Richardson; Arsenault, Michelle - AMS

>> Subject: RE: Materials SC Seed panel

>>

>> That might work. Jean is picking me up at the airport during that time. My flight is scheduled to land at 1:10.

>>

>> -----Original Message-----

>> From: Brown Rosen, Emily - AMS

>> Sent: Monday, February 09, 2015 1:54 PM

>> To: McEvoy, Miles - AMS; Zea Sonnabend; Calvin Walker

>> Cc: Jean Richardson; Arsenault, Michelle - AMS

>> Subject: RE: Materials SC Seed panel

>>

>> Miles, there is an ES call from 1-2:30 pm, eastern will you be participating in that? Did you want to talk about

 seed panel after that?

>> Emily

>>

>> Emily Brown Rosen

>> Specialist, Standards Division

>> USDA-AMS-NOP

>> www. ams.usda.gov/nop

>> 609-737-8630 NJ office

>> cell

>>

>>

>>

>> -----Original Message-----

(b) (6)
>> From: McEvoy, Miles - AMS

>> Sent: Monday, February 09, 2015 1:32 PM

>> To: Zea Sonnabend; Calvin Walker

>> Cc: Jean Richardson; Brown Rosen, Emily - AMS

>> Subject: RE: Materials SC Seed panel

>>

>> I'm not available at either of those times. How about Friday afternoon at 2 pm eastern time. I'll be with Jean in

 Vermont.

>>

>> Miles

>>

>> -----Original Message-----

>> From: Zea Sonnabend [mailto:zea@well.com]

>> Sent: Sunday, February 08, 2015 9:36 PM

>> To: Calvin Walker

>> Cc: McEvoy, Miles - AMS; Jean Richardson; Brown Rosen, Emily - AMS

>> Subject: Re: Materials SC Seed panel

>>

>> Miles,

>> We have a conference call already set up to discuss this: Tuesday, Feb. 10 at 10 am Pacific, 1 pm eastern. If that

 doesn't work for you,please suggest another time; maybe right before the Ex com on Friday?

>>

>> We don't care which day but it makes sense to have it when the Material/GMO SC section is. About an hour and

 a half would be good, but an hour would work.

>>

>> We will have some prepared questions for them and an open question period too. We can wait to identify the

 questions, but we should choose the panelists and let them know soon so they can fit it into their schedules.

>> Regards,

>> Zea

>>

>> Sent from my iPad

>>

>>> On Feb 8, 2015, at 4:45 PM, Calvin Walker < wrote:

>>>

>>> We could use the next MS call .....we have only one item to brief discuss and vote... The remaining time could

 be devoted to this issue .

>>> Bottom line: any time is good for me.

>>> Calvin

>>>

>>> Sent from my iPhone

>>>

>>>> On Feb 8, 2015, at 4:55 PM, "McEvoy, Miles - AMS" <Miles.McEvoy@ams.usda.gov> wrote:

>>>>

>>>> Please se up a conference call to discuss. NOP will send out invites. Need to know what day you are

 considering, do you want short presentations? How much time? Questions ahead of time for panelists? We'd like to

 make this as productive as possible for your continued work.

>>>>

>>>> Miles V McEvoy

>>>> Deputy Administrator

>>>> USDA National Organic Program

>>>>

>>>>> On Feb 8, 2015, at 12:16 PM, "Jean Richardson" < wrote:

>>>>>

>>>>> Hi Zea and Calvin

>>>>> I am copying Miles and Emily here so that they can provide some guidance on whether or not to formally

 invite your Materials subcommittee proposed seed panel members for the April Meeting. My sense is that it will be

 just fine.....

(b) (6) (b) (6)
>>>>>

>>>>> Miles, the Materials subcommittee only meets once a month, given our heavy Sunset load, and thus it will be

 important to know before Tuesday if the Materials subcommittee can invite panel members. Waiting till March

 would probably be too late.

>>>>> Please indicate yes so they can go ahead and plan for this.

>>>>> Thank you

>>>>> Jean

>>>>

>>>>

>>>>

>>>>

>>>> This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

Climate Smart Agriculture (CSA), Post-Harvest Waste and innovations with ICT and GIS for Agriculture

will be a key themes at GFIA 2015. 

These themes are especially timely, given the launch of the Global Alliance for Climate Smart 

Agriculture (GACSA) at the UN Secretary-General's Climate Summit in New York in 

September 2014..

The GACSA Interim Secretariat includes the Netherlands government, FAO and the World 

Bank - who are also on the GFIA - CSA Advisory Council. The U.S. government is also now 

a member of GACSA.

Attached the GFIA 2015 Executive Summary for you to review with your colleagues at USDA as well as the 

following link to a short video with Bill Gates, a keynote speaker at GFIA 2014, discussing the Gates Foundation

partnership with GFIA. 

http://gfiatv.com/bill-gates-view-gfia-2014-2/

Other noteworthy updates for GFIA 2015 include: 

1. We will have national delegations attending GFIA from more than 70 countries including Ministers of 

Agriculture from:

Brazil, China, Costa Rica, Ireland, France, Japan, Mexico, Netherlands, Norway, Philippines, Spain, UK, 

US and Vietnam as well as Ministers of Agriculture from 42 African Union countries and Ministers from 9

Small Island Developing States (SIDS) in the Caribbean, Pacific and Indian Oceans.

2. GFIA 2015 confirmed & invited keynote speakers include:

* His Highness Sheikh Mansour Bin Zayed Al-Nahyan, Deputy Prime Minister of the UAE,

Minister of Presidential Affairs and Chairman of the Abu Dhabi Food Control Authority 

(ADFCA)

* AGRA (Dr. Agnes Kalibata, Interim President)

* Clinton Climate Initiative (CCI) (Dymphna van der Lans, CEO)

* CGIAR (Dr. Frank Rijsberman, CEO)

* FAO (Dr. Graziano da Silva - Director-General)

* GEF (Dr. Naoko Ishii - CEO)

* ICRAF (Dr. Tony Simons, Director-General)

* NEPAD (Dr. Martin Bwalya, Head of Agriculture)

* Netherlands Ministry of Agriculture (Sharon Dijksma - Minister)

* UAE Minister of Environment and Water (H.E. Dr. Rashid Ahmed Bin Fahad)

* World Bank Group ( Dr. Juergen Voegele, Sr. Director - Global Agriculture)

* President William Jefferson Clinton (Invited)

* Tom Vilsack, USDA Secretary (Invited)

* Christiana Figueres, Executive Secretary of the United Nations Framework Convention on Climate Change 

(UNFCCC) (Invited) 

On Thu, Dec 4, 2014 at 4:55 PM, McEvoy, Miles - AMS <Miles.McEvoy@ams.usda.gov> 

wrote:

I am forwarding you information about an upcoming international conference in Abu Dhabi. The 

conference has a lot of potential to expand opportunities for organic agriculture and trade.

I have been in discussions with Raymond Chavez about conducting an organic session at the 

conference. I put together a draft workshop outline that you can see below. At this time USDA-
NOP and Betsy Rakola are not able to participate or contribute to the development of this 

session. By way of this email I am introducing you to Raymond Chavez who can assist you if you 

are interested in participating.

My understanding is that IFOAM has agreed to participate and will be taking the lead on 

developing the organic workshop. Please work with Raymond if you are interested in contributing

 to this conference.

Miles V. McEvoy

Deputy Administrator

National Organic Program

1400 Independence Ave. SW

Washington, DC 20250-0268

202-720-3252

www.ams.usda.gov/nop

Organic Integrity from Farm to Table, Consumers Trust the Organic Label

From: Raymond Chavez [mailto:

Sent: Wednesday, November 26, 2014 12:02 PM

To: McEvoy, Miles - AMS

Subject: Meeting request re. USDA Organic - GFIA 2015 speakers & presentation design

Hi Miles,

I hope this finds you well and looking forward to a wonderful Thanksgiving holiday.

I am writing to set up a phone meeting with you at your earliest convenience next week to 

discuss in more detail the USAID Organic presentations and exhibit at GFIA 2015 in Abu 

Dhabi. 

Below is the excellent concept note you sent to us listing speakers and themes for USDA's 

(b) (6)
presentations at GFIA. 

I have also attached a GFIA 'session' template which we are using for 90 - 120 minute 

sessions which we can use further design the Organic presentations at GFIA. 

I am based in Washington DC and available any day next week from 11am - 2pm for a 

phone meeting. 

I am in regular contact with Elise Golan, Mark Manis and now with Jamie Adams at USDA

 who has been designated as our point person to discuss the USDA pavilion - exhibit at 

GFIA 2015.

I have a phone meeting with Jamie Adams next Tuesday, Dec. 2 at 11am to discuss the 

USDA exhibit at GFIA and the list of invited 'science innovators' that USDA is proposing 

to attend and present at GFIA 2015.

This will include the USDA Organic speakers you are proposing to invite. 

Following is the link for you to request each of the proposed USDA speakers to submit for 

those who need travel subsidy to attend GFIA. 

http://www.innovationsinagriculture.com/Visiting/Hosted-Scientist-Programme/ADFCA-HostedScientist-Programme-Application-Form

As you may recall, thanks to the generous support of the Abu Dhabi government, we can 

pay the airfare, hotel, meals and local transportation for 'science innovators' to attend and 

present at GFIA 2015.

I look forward to speaking with you at your earliest convenience.

Best Regards,

Raymond Chavez

Senior Program Development Advisor

Global Forum for Innovations in Agriculture
US Mobile: 

Skype: 

Find out what’s new at GFIA 2015: www.innovationsinagriculture.com

<image001.jpg>

*************************************************************************

****************

Global Forum for Innovations in Agriculture

March 9-10, 2015, Abu Dhabi

Organic Agriculture Workshop

Presenters Content

· Laura Batcha, Organic Trade 

Association

· Kelly Strzelecki, USDA Foreign 

Agriculture Service

Organic markets and trade data

· Miles McEvoy, Deputy Administrator 

of USDA’s National Organic Program

· Joao Onofre, European Commission

· Andre Leu, IFOAM President

Organic Standards

· CODEX

· USDA organic regulations

· EU organic regulations

· Ken Cummins, International 

Organic Accreditation Service

· Miles McEvoy

· Jean Richardson, Chair of the 

USDA National Organic 

Standards Board

Accreditation and certification

International Norms – ISO 17011 and ISO 17065

Inspections

· Miles McEvoy International Trade Arrangements

· Jean Richardson

· Betsy Rakola, USDA Organic Policy 

Organic Support – Technical Assistance, 

extension, research, Advisory Boards

(b) (6) (b) (6)
Advisor

· Gunnar Rundgren, Grolink

This electronic message contains information generated by the USDA solely for the 

intended recipients. Any unauthorized interception of this message or the use or disclosure 

of the information it contains may violate the law and subject the violator to civil or 

criminal penalties. If you believe you have received this message in error, please notify the 

sender and delete the email immediately.

<GFIA_2015_Executive Summary_English_Updated Oct 2014.pdf>
From: McEvoy, Miles - AMS

To: "Jean Richardson"; Strzelecki, Kelly - FAS; Laura Batcha

Cc: "Raymond Chavez (

Subject: FW: Meeting request re. USDA Organic - GFIA 2015 speakers & presentation design

Date: Thursday, December 04, 2014 4:55:20 PM

Attachments: GFIA - Climate observation in Africa - presentation template - sample for USDA 11.25.14.docx

I am forwarding you information about an upcoming international conference in Abu Dhabi. The conference has a lot

 of potential to expand opportunities for organic agriculture and trade.

I have been in discussions with Raymond Chavez about conducting an organic session at the conference. I put

 together a draft workshop outline that you can see below. At this time USDA-NOP and Betsy Rakola are not able to

 participate or contribute to the development of this session. By way of this email I am introducing you to Raymond

 Chavez who can assist you if you are interested in participating.

My understanding is that IFOAM has agreed to participate and will be taking the lead on developing the organic

 workshop. Please work with Raymond if you are interested in contributing to this conference.

Miles V. McEvoy

Deputy Administrator

National Organic Program

1400 Independence Ave. SW

Washington, DC 20250-0268

202-720-3252

www.ams.usda.gov/nop

Organic Integrity from Farm to Table, Consumers Trust the Organic Label

From: Raymond Chavez [mailto

Sent: Wednesday, November 26, 2014 12:02 PM

To: McEvoy, Miles - AMS

Subject: Meeting request re. USDA Organic - GFIA 2015 speakers & presentation design

Hi Miles, 

I hope this finds you well and looking forward to a wonderful Thanksgiving holiday. 

I am writing to set up a phone meeting with you at your earliest convenience next week to discuss in more

detail the USAID Organic presentations and exhibit at GFIA 2015 in Abu Dhabi.

Below is the excellent concept note you sent to us listing speakers and themes for USDA's presentations at

GFIA.

I have also attached a GFIA 'session' template which we are using for 90 - 120 minute sessions which we can

use further design the Organic presentations at GFIA.

I am based in Washington DC and available any day next week from 11am - 2pm for a phone meeting. 

I am in regular contact with Elise Golan, Mark Manis and now with Jamie Adams at USDA who has been

designated as our point person to discuss the USDA pavilion - exhibit at GFIA 2015. 

I have a phone meeting with Jamie Adams next Tuesday, Dec. 2 at 11am to discuss the USDA exhibit at

GFIA and the list of invited 'science innovators' that USDA is proposing to attend and present at GFIA

2015. 

(b) (6) (b) (6)
This will include the USDA Organic speakers you are proposing to invite.

Following is the link for you to request each of the proposed USDA speakers to submit for those who need

travel subsidy to attend GFIA.

http://www.innovationsinagriculture.com/Visiting/Hosted-Scientist-Programme/ADFCA-Hosted-Scientist-ProgrammeApplication-Form

As you may recall, thanks to the generous support of the Abu Dhabi government, we can pay the airfare,

hotel, meals and local transportation for 'science innovators' to attend and present at GFIA 2015. 

I look forward to speaking with you at your earliest convenience. 

Best Regards, 

Raymond Chavez

Senior Program Development Advisor

Global Forum for Innovations in Agriculture

US Mobile: 

Skype: 

Find out what’s new at GFIA 2015: www.innovationsinagriculture.com

*****************************************************************************************

Global Forum for Innovations in Agriculture

March 9-10, 2015, Abu Dhabi

Organic Agriculture Workshop

Presenters Content

· Laura Batcha, Organic Trade

Association

· Kelly Strzelecki, USDA Foreign

Agriculture Service

Organic markets and trade data

· Miles McEvoy, Deputy Administrator

of USDA’s National Organic Program

· Joao Onofre, European Commission

· Andre Leu, IFOAM President

Organic Standards

· CODEX

· USDA organic regulations

· EU organic regulations

· Ken Cummins, International

Organic Accreditation Service

Accreditation and certification

International Norms – ISO 17011 and ISO 17065

(b) (6) (b) (6)
· Miles McEvoy

· Jean Richardson, Chair of the

USDA National Organic

Standards Board

Inspections

· Miles McEvoy International Trade Arrangements

· Jean Richardson

· Betsy Rakola, USDA Organic Policy

Advisor

· Gunnar Rundgren, Grolink

Organic Support – Technical Assistance,

extension, research, Advisory Boards

This electronic message contains information generated by the USDA solely for the intended recipients. Any

unauthorized interception of this message or the use or disclosure of the information it contains may violate

the law and subject the violator to civil or criminal penalties. If you believe you have received this message

in error, please notify the sender and delete the email immediately.
GFIA - Climate Resilience Monitoring – Presentation Proposal 

Session title* (please kindly use media-friendly language)

Demand for Climate Observations in Africa – case studies in social services, farm services, and crop insurance

Session description* (180 words, please kindly use media-friendly language)

African climate data is needed urgently for civil preparedness, farm planning, and crop insurance, to name a few of the areas clamouring for 

data. This session lays out the case for commercially viable on-the-ground climate observations across Africa. The session is kicked off 

by a broad assessment of the opportunities for financial returns stemming from climate observations, as well as a presentation of a 

continent-wide effort to address the climate observation gulf. The session then moves to case studies, starting with Kenya, where the 

government has crafted and is executing the installation of a strategic climate observation network of 2,000 stations. They have 

developed novel electronic data acquisition hardware and data analysis software that may well become the standard across Africa. Two 

pioneers in commercialization will present climate-data-based products: an insurance system covering 200,000 growers in East Africa; and a 

new cocoa producers climate observation system in Ghana. The 35-minute wrap up will provide a practical discussion of what is needed 

to make climate observations economically viable in Africa by leveraging commercial use of these data.

Session Duration* 90min □ 120min

Session schedule in detail

(Insert as many items as 

you wish)

Order Estimated lead time (min) Description of items/presentations Confirmed speakers

1 15 

Introduction, Presentation –

Innovations in ground observations 

of African Climate

John Selker

TAHMO

2 15 

Lessons from Kenya: strategic plan 

for geospatial coverage of climate 

data

David Mburu

Kenyan Meteorological 

Service 

3 10 

Lessons from Ghana: Bringing 

technology to bear on Climate data 

acquisition and dissemination

Alloysius Attah, Owner, 

Farm-tech

4 10 

The African Climate Data Market: 

200,000 weather-index based

micro-crop insurance policies

Wairimu Muthike Acre, 

Kenya

5 35 Roundtable Discussion All

6 5 Concluding Remarks

Nick van de Giesen

Tech University of Delft

Session objectives and outputs* (please kindly use media-friendly language)

Objective: Lay out a commercially viable framework for sustainable climate observation in Africa. 

Outcomes:

• Set the foundation for investment in Africa climate observation for expanded food production, and show that investment in this 

system will bring excellent returns. 

Session Contribution* (How this session can contribute to the implementation roadmap)

While many have bemoaned the lack of climate data for Africa, no one has laid out the business case for solving this problem. We show 

that the confluence of cell-phones, micro-sensor technology, climate change, and proven business models for sale of climate-based 

products has taken Africa beyond the old obstacles to climate observation. This session will energize and accelerate the investment in 

climate observation in Africa based on a vision for self-supporting networks of observation.

3. Session Format/Logistics 

Expected number of Participants(room size)1) *

□ Less than 50pax □ 50~100pax 100~150pax □ 150~200pax □ More than 200pax ( pax)

Preferred Room Type2) *

□ Theater Type □ Classroom Type Roundtable Type □ Other( )

• All rooms will be equipped with 1 computer, 1 video projector, 1 screen, 2 microphones and 1 staff.
From: Jean Richardson

To: McEvoy, Miles - AMS

Cc: Rakola Betsy - OSEC

Subject: Re: Meeting request re. USDA Organic - GFIA 2015 speakers & presentation design

Date: Wednesday, November 26, 2014 10:30:19 PM

Betsy, I am in India until December 10

I have some internet connection and will check each day.

I would be interested in presenting if you were also attending.

Too bad Miles can't fit it in.

What do you think?

Jean

Sent from my iPad

On Nov 26, 2014, at 8:54 PM, "McEvoy, Miles - AMS" <Miles.McEvoy@ams.usda.gov> wrote:

Hi Betsy and Jean,

Information about the GFIA conference in Abu Dhabi next March. I think this conference has potential for

 supporting organic agriculture worldwide. However, in order to pull this off it would require a significant time

 investment. Due to my travel schedule and workload demands I am not interested in participating. I am

 forwarding this to you two to see if you’d like to pursue organic this organic session.

I put together a rough outline for an organic session with suggested speakers that is outlined below. I have

 not contacted any of the suggested speakers because I didn’t know whether GFIA was interested in this

 session. So, if you’d like to pursue this you would need to organize the organic session and contact possible

 speakers to see if they’d participate. There is support for travel and expenses so you may be able to pull it off.

I’ll speak with Raymond next week and let him know that I am not able to participate.

Miles McEvoy

Deputy Administrator

National Organic Program

From: Raymond Chavez [mailto

Sent: Wednesday, November 26, 2014 12:02 PM

To: McEvoy, Miles - AMS

Subject: Meeting request re. USDA Organic - GFIA 2015 speakers & presentation design

Hi Miles,

I hope this finds you well and looking forward to a wonderful Thanksgiving holiday.

I am writing to set up a phone meeting with you at your earliest convenience next week to discuss in

 more detail the USAID Organic presentations and exhibit at GFIA 2015 in Abu Dhabi. 

Below is the excellent concept note you sent to us listing speakers and themes for USDA's

 presentations at GFIA. 

I have also attached a GFIA 'session' template which we are using for 90 - 120 minute sessions which

 we can use further design the Organic presentations at GFIA. 

I am based in Washington DC and available any day next week from 11am - 2pm for a phone meeting.

 

I am in regular contact with Elise Golan, Mark Manis and now with Jamie Adams at USDA who has

 been designated as our point person to discuss the USDA pavilion - exhibit at GFIA 2015.

(b) (6)
I have a phone meeting with Jamie Adams next Tuesday, Dec. 2 at 11am to discuss the USDA exhibit

 at GFIA and the list of invited 'science innovators' that USDA is proposing to attend and present at

 GFIA 2015.

This will include the USDA Organic speakers you are proposing to invite. 

Following is the link for you to request each of the proposed USDA speakers to submit for those who

 need travel subsidy to attend GFIA. 

http://www.innovationsinagriculture.com/Visiting/Hosted-Scientist-Programme/ADFCA-Hosted-ScientistProgramme-Application-Form

As you may recall, thanks to the generous support of the Abu Dhabi government, we can pay the

 airfare, hotel, meals and local transportation for 'science innovators' to attend and present at GFIA

 2015.

I look forward to speaking with you at your earliest convenience.

Best Regards,

Raymond Chavez

Senior Program Development Advisor

Global Forum for Innovations in Agriculture

US Mobile: 

Skype: 

Find out what’s new at GFIA 2015: www.innovationsinagriculture.com

<image001.jpg>

*****************************************************************************************

Global Forum for Innovations in Agriculture

March 9-10, 2015, Abu Dhabi

Organic Agriculture Workshop

Presenters Content

· Laura Batcha, Organic Trade

 Association

· Kelly Strzelecki, USDA Foreign

 Agriculture Service

Organic markets and trade data

· Miles McEvoy, Deputy Administrator

 of USDA’s National Organic Program

· Joao Onofre, European Commission

· Andre Leu, IFOAM President

Organic Standards

· CODEX

· USDA organic regulations

· EU organic regulations

· Ken Cummins, International

 Organic Accreditation Service

· Miles McEvoy

Accreditation and certification

International Norms – ISO 17011 and ISO 17065

Inspections

(b) (6) (b) (6)
· Jean Richardson, Chair of the

 USDA National Organic

 Standards Board

· Miles McEvoy International Trade Arrangements

· Jean Richardson

· Betsy Rakola, USDA Organic Policy

 Advisor

· Gunnar Rundgren, Grolink

Organic Support – Technical Assistance,

 extension, research, Advisory Boards

This electronic message contains information generated by the USDA solely for the intended

 recipients. Any unauthorized interception of this message or the use or disclosure of the information it

 contains may violate the law and subject the violator to civil or criminal penalties. If you believe you

 have received this message in error, please notify the sender and delete the email immediately.

<GFIA - Climate observation in Africa - presentation template - sample for USDA 11.25.14.docx>
From: Jean Richardson

To: Zea Sonnabend

Cc: Harold Austin; John Foster; Tracy Favre; Jennifer Taylor; joe.dickson@wholefoods.com; Brown Rosen, Emily -

AMS; Arsenault, Michelle - AMS; Mac Stone; McEvoy, Miles - AMS

Subject: Re: More on BPA

Date: Thursday, March 06, 2014 3:02:47 PM

Hi Zea

yes I have been following BPA for some years. Thank you for your work on this

Jean

On Mar 6, 2014, at 2:57 PM, Zea Sonnabend wrote:

Hi Handlers and NOP,

For all of you who saw the FDA paper on this, and those who didn't but follow 

this subject, please read the below article, especially the first paragraph.

Zea Sonnabend (Zea@well.com) thought you would like to see this page from Mother Jones.

The Scary New Evidence on BPA-Free Plastics

http://www.motherjones.com/environment/2014/03/tritan-certichem-eastman-bpafree-plastic-safe.

Regards,

Zea
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Monday meeting

Date: Sunday, February 02, 2014 2:54:28 PM

Hi Miles

I am looking forward to our meeting tomorrow.

If things change - note that my best e-mail is this one, 

and my cell phone is 

Jean

(b) (6) (b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS

Cc: Arsenault, Michelle - AMS; Brown Rosen, Emily - AMS; John Foster; Mac Stone; Tucker, Jennifer - AMS; Brines,

 Lisa - AMS

Subject: Re: Modify Meeting document

Date: Tuesday, September 09, 2014 5:51:01 PM

Sounds good

Thank you Miles

Michelle can we do that tomorrow?

Sent from my iPhone

> On Sep 9, 2014, at 5:39 PM, "McEvoy, Miles - AMS" <Miles.McEvoy@ams.usda.gov> wrote:

>

> Clarification is fine.

>

> I'd suggest a simple change to first bullet:

> On the first page under "Meeting Format" add a bullet as first bullet:

> *The Designated Federal Officer (DFO), NOP Deputy Administrator, will call the meeting to order. After the

 meeting is called to order the NOSB Chair, Jean Richardson, will chair/facilitate the meeting.

>

> Miles V McEvoy

> Deputy Administrator

> National Organic Program

>

> -----Original Message-----

> From: Jean Richardson [mailto

> Sent: Tuesday, September 09, 2014 5:31 PM

> To: Arsenault, Michelle - AMS; McEvoy, Miles - AMS; Brown Rosen, Emily - AMS; John Foster; Mac Stone

> Subject: Modify Meeting document

> Importance: High

>

> Hi all

> I am getting calls that it looks like Miles is Chairing it all.

> Lets either fix this tomorrow or add to exec agenda a discussion of how to fix this right away.

> May I suggest the following simple change:

> On the first page under "Meeting Format"

> add a bullet as first bullet:

> *The Designated Federal Officer (DFO), Deputy Administrator, will call the meeting to order and chair the

 presentations by NOP staff.

> * second bullet National List Manager etc as written

> * Add as Bullet 3:

> The NOSB meeting will be called to order and Chaired by the Chair of the NOSB let me know what you think

 Jean

>

>

>

>

>

> This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

(b) (6)



From: Jean Richardson

To: Tucker, Jennifer - AMS

Cc: McEvoy, Miles - AMS

Subject: Michelle"s Excellent work

Date: Thursday, April 02, 2015 9:57:16 AM

Hi Jenny:

I know that each year you ask the NOSB for input into the Evaluation of our ABS, Michelle Arsenault.

Thus I write this Note to be considered in her 2014-2015 evaluation:

Dated April 2, 2015

Please contact me if I can provide any further information

Jean Richardson PhD

Chair NOSB

(b) (6), (b) (5)
From: McEvoy, Miles - AMS

To: Colehour Bondera (colemel@kanalanifarm.org); Jean Richardson (

joe.dickson@wholefoods.com; Robert Mac Stone (mac@elmwoodstockfarm.com); Nick Maravell; Rueben Walker

 ( Tracy Favre (tfavre@favrehouse.com); wendy.fulwider@organicvalley.com

Cc: Bailey, Melissa - AMS; Coke, Lorraine - AMS; Brines, Lisa - AMS; Updike, Scott - AMS; Brown Rosen, Emily - AMS

Subject: Methionine petition

Date: Thursday, February 09, 2012 2:59:35 PM

The allowance of methionine in poultry feed is scheduled to expire on October 1, 2012. The

 National Organic Program published a proposed rule on methionine on February 6, 2012 that would

 extend the allowance of methionine, at reduced rates, until the next sunset review in 2017. The

 NOP is taking comments on the proposed rule through April 6, 2012 and plans to publish a final rule

 prior to October 1, 2012.

The NOP received a new petition for methionine and the NOSB Livestock Committee has had some

 preliminary discussions regarding the petition and the technical report. It is particularly

 problematical for the NOSB to be reviewing a petitioned substance during an active rule making

 process for the same substance. Therefore, the National Organic Program would like the NOSB to

 defer their review of the new methionine petition until the fall 2012 meeting. At that time the

 previous NOSB recommendation on methionine will have completed its rule making process and the

 new petition could be reviewed.

Thank you for your understanding and your service.

Miles V. McEvoy

Deputy Administrator

National Organic Program

U.S. Department of Agriculture

Room 2646-So. (Stop 0268)

1400 Independence Ave SW

Washington, DC 20250-0268

202-720-3252

www.ams.usda.gov/nop

Organic Integrity from Farm to Table, Consumers Trust the Organic Label

Register for the NOP Organic Insider, the National Organic Program’s email notification service, by

 visiting http://bit.ly/NOPOrganicInsiderRegistration.

This electronic message contains information generated by the USDA solely for the intended

 recipients. Any unauthorized interception of this message or the use or disclosure of the

 information it contains may violate the law and subject the violator to civil or criminal

 penalties. If you believe you have received this message in error, please notify the sender and

 delete the email immediately.

(b) (6) (b) (6)
From: Jean Richardson

To: Brown Rosen, Emily - AMS

Cc: Tracy Favre (tfavre@favrehouse.com); McEvoy, Miles - AMS; Arsenault, Michelle - AMS

Subject: Re: methionine minority piece

Date: Monday, March 02, 2015 6:36:21 PM

Are there grounds to not publish it?

Sent from my iPad

On Mar 2, 2015, at 5:49 PM, "Brown Rosen, Emily - AMS"

 <Emily.BrownRosen@ams.usda.gov> wrote:

Tracy,

Please note that this version of minority opinion Colehour submitted on the 25th is

 substantially different than the one discussed by the LS on the 24th. I have attached

 both. It also does not have any disclaimer about author and date as discussed.

Please advise!

Emily

From: Arsenault, Michelle - AMS 

Sent: Monday, March 02, 2015 5:17 PM

To: 'Tracy Favre'; Brown Rosen, Emily - AMS

Subject: FW: methionine minority piece

Tracy, are you able to confirm that this is the MET doc that you would like to submit? If

 so, I’ll save this one as final.

Sorry I missed that you didn’t send it with the other docs in the previous emails.

Michelle

From: Colehour Bondera [mailto:

Sent: Wednesday, February 25, 2015 1:03 AM

To: Tracy Favre

Cc: CALVIN WALKER; Arsenault, Michelle - AMS

Subject: methionine minority piece

aloha tracy,

attached please find the final of the methionine minority position to be added to

 the LS recommendation in response to the petition received.

please contact me and calvin if any questions or issues to get this finalized at this

 time!

(b) (6)
cheers,

Colehour

This electronic message contains information generated by the USDA solely for

 the intended recipients. Any unauthorized interception of this message or the use

 or disclosure of the information it contains may violate the law and subject the

 violator to civil or criminal penalties. If you believe you have received this

 message in error, please notify the sender and delete the email immediately.

<Methionine_Minority_Opinion_2015.docx>

<Methionine Minority Opinion 2015 2-21-15.docx>
From: Jean Richardson

To: AMS - Office Of The AMS Administrator

Cc: McEvoy, Miles - AMS; Arsenault, Michelle - AMS

Subject: Re: Message for Dr. Jean Richardson at NOSB

Date: Tuesday, July 21, 2015 3:17:25 PM

Thank you Sam,

Much appreciated.

Jean

On Jul 20, 2015, at 10:34 AM, AMS - Office Of The AMS Administrator wrote:

Good morning,

Please see below. Thanks!

Sam Jones-Ellard

Public Affairs Specialist

USDA | Agricultural Marketing Service

202.660.2268

100 Years of USDA Market News: the trusted source – then, now and always

Follow us on Twitter @USDA_AMS or read our stories on the USDA blog.

From: Sally Dodge [mailto:

Sent: Saturday, July 18, 2015 1:19 PM

To: AMS - Office Of The AMS Administrator

Cc: canecreekfarm@gmail.com

Subject: Message for Dr. Jean Richardson at NOSB

Dear Dr. Richardson,

This is to recommend Eliza MacLean as a new member of the National Organic 

Standards Board, she has been nominated as a consumer/public interest 

advocate for the next round of NOSB board members. Elizabeth is a longtime 

farmer in North Carolina, and has been committed to sustainable and humane 

farming for many years. She trained as a veterinarian technician, but over the 

years has raised hogs and other animals at NC A&T, for Niman Ranch, and for 

many years has been in business raising meat animals on her own family farm. 

What is impressive is her commitment to clean and sustainable farming, her 

innovation at marketing, and her understanding of the intracacies of maintaining 

the family farm in an overwhelmingly industrial food system. I think Eliza would 

bring a wealth of experience and understanding to the NOSB board. You can see 

her website atwww.canecreekfarm.us

You may remember my daughter, Heidi Guldbrandsen, who was a student of 

(b) (6)
yours at UVM in the late 80s. She considers you her greatest mentor. I also have 

been a Vermont farmer, and local foods promoter, and created several Taste of 

Vermont events, the largest being at Shelburne Farms for the Land Trust Alliance 

Rally, at which the Flack family participated. My friends Amy Seidel and Walter 

Polman continue in your tradition of excellent field study at UVM’s environmental

 programs!

Thank you for your consideration.

Best regards, Sally Dodge (formerly Mole)
From: Jean Richardson

To: Alonzo, Anne - AMS

Cc: McEvoy, Miles - AMS; Whitley, Patricia - AMS

Subject: Re: Meeting?

Date: Monday, May 19, 2014 8:25:59 PM

Hi Anne

I get into DC Tuesday evening

I can do lunch on Wednesday at newseum

Yes we need some strategic PR!

Jean

Sent from my iPad

> On May 19, 2014, at 8:19 PM, "Alonzo, Anne - AMS" <Anne.Alonzo@ams.usda.gov> wrote:

>

> Hi Jean, believe you are in town tonight. Am hoping we can catch some time while you are in DC this week.

 Strategic/crisis communications could be one of our topics.

>

> Options:

> Wednesday there is a l hr lunch break at the Newseum .

>

> Thursday am works. Copying in my Admin Asst Patricia in case it works.

>

> Tks Anne

>

>

>

>

>

>

> This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

>
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: Morning

Date: Thursday, September 18, 2014 7:55:48 AM

OK call this am

I will be in until 10.30

Jean

Jean

On Sep 18, 2014, at 6:54 AM, McEvoy, Miles - AMS wrote:

Hi Jean,

Thanks for all of your emails. Lots to talk about. The 2015 NOSB appointments will be 

announced today.

We have a call scheduled for tomorrow morning but I’ll give you a call this morning to 

see if I can catch you.

Best,

Miles

This electronic message contains information generated by the USDA 

solely for the intended recipients. Any unauthorized interception of 

this message or the use or disclosure of the information it contains 

may violate the law and subject the violator to civil or criminal 

penalties. If you believe you have received this message in error, 

please notify the sender and delete the email immediately.
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Automatic reply: Morning

Date: Thursday, September 18, 2014 7:55:49 AM

I am out of the office. Please contact Desiree Lee at 202-720-3252, desiree.lee@ams.usda.gov

 if you need immediate assistance.

This electronic message contains information generated by the USDA solely for the intended

 recipients. Any unauthorized interception of this message or the use or disclosure of the

 information it contains may violate the law and subject the violator to civil or criminal

 penalties. If you believe you have received this message in error, please notify the sender and

 delete the email immediately.
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: Morning

Date: Monday, February 23, 2015 8:05:11 AM

OK

On Feb 23, 2015, at 7:56 AM, McEvoy, Miles - AMS wrote:

> I'm running a few minutes late. I'll call you around 8:10

>

> Miles V McEvoy

> Deputy Administrator

> USDA National Organic Program

>

>

>

>

> This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Morning paper - BP lawsuit

Date: Wednesday, April 08, 2015 9:20:05 AM

Importance: High

http://mobile.nytimes.com/2015/04/08/business/lawsuit-challenges-change-in-rules-onorganic-farming.html?referrer=
From: McEvoy, Miles - AMS

To: Mac Stone; Bailey, Melissa - AMS; Lipson, Mark - OSEC; Brines, Lisa - AMS; Arsenault, Michelle - AMS; Jones,

 Samuel - AMS; John Foster; Jean Richardson

Subject: Morning protest

Date: Monday, April 28, 2014 9:53:46 PM

I understand that OCA plans a protest when I start my opening remarks tomorrow morning. Apparently there will be

 a small group that will unfurl a banner.

I will stop the meeting and ask them to leave. If it persists the board members can leave via a back exit until the

 disruption ends and we can restart the meeting.

Miles V McEvoy

Deputy Administrator

USDA National Organic Program
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Automatic reply: move NOSB Executive call?

Date: Saturday, September 06, 2014 8:46:40 AM

I am out of the office. Please contact Desiree Lee at 202-720-3252, desiree.lee@ams.usda.gov

 if you need immediate assistance.

This electronic message contains information generated by the USDA solely for the intended

 recipients. Any unauthorized interception of this message or the use or disclosure of the

 information it contains may violate the law and subject the violator to civil or criminal

 penalties. If you believe you have received this message in error, please notify the sender and

 delete the email immediately.
From: McEvoy, Miles - AMS

To: Jean Richardson

Cc: Arsenault, Michelle - AMS; Brines, Lisa - AMS

Subject: Re: move NOSB Executive call?

Date: Saturday, September 06, 2014 9:33:37 PM

Jenny, Melissa and I are all unavailable on the 12th. Lisa brines may be available. If that works for you let's stick

 with the same time.

Miles V McEvoy

Deputy Administrator

USDA National Organic Program

> On Sep 6, 2014, at 7:46 AM, "Jean Richardson" < wrote:

>

> Hi Miles

> Michelle contacted me Friday afternoon to say that you would be out of town on September 12 and wished to

 move the NOSB Exec call. It may not be possible to change the calendars of 7 NOSB members with such sort

 notice, but could you suggest a couple of dates for Michelle to check out? My preference would be to keep the Exec

 calls as scheduled and have an NOP staff person on the call if you wish.

> Have a great trip.

> cheers,

> Jean

This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

(b) (6)
From: Jean Richardson

To: Zea Sonnabend; Mac Stone; John Foster; Harold Austin; Tracy Favre; Carmela Beck; Calvin Walker; Arsenault,

 Michelle - AMS; McEvoy, Miles - AMS; Bailey, Melissa - AMS

Subject: Move Exec till next week?

Date: Wednesday, May 07, 2014 4:43:32 PM

Hi Executive team:

Miles called me a few minutes ago and suggested that we move the Exec. Subcommittee to NEXT Friday, May 16

 at 1.pm ET. He noted that neither Tracy nor I could be on the call this week. This seems like a fine idea to me and

 hopefully it will be possible for all of you to fit it in. My personal apologies for all the inconvenience.

Michelle will check with Miles and send out formal notice when she returns to her office (she is not in today).

 Please let Michelle know your availability.

I feel as though I have been on the phone continuously ever since Sunday morning when I got home, including

 providing a debriefing for Senator Leahy's staff in DC and discussions with them on Sunset.

I have asked Miles to get to work as quickly as possible to bring the PPM up to date, including role of NOSB Chair.

 We need clarity on what in the PPM is acceptable to NOP/AMS and which parts are not. Presently we seem to work

 on a mix of the outdated PPM, FACA, tradition and Roberts Rules in varying combinations. John, Michelle, and

 Colehour's PDS did a lot of work on proposed edits over the last year or so, so there is a foundation document to

 work from. I would ask that the edited PPM and related document if any be brought to the Exec. when ready to

 review.

It would be great if we can begin to think how we could get some good PR for the NOSB and organics, and not just

 the negative things. Your ideas will be most welcome.

The sun is out in Vermont! A great sight in this long cold spring

Best to all of you

Jean
From: Jean Richardson

To: Jay Feldman

Cc: Arsenault, Michelle - AMS; Nick Maravell; Colehour Bondera; John Foster; Carmela Beck; Zea Sonnabend; Harold

 Austin; Francis Thicke; Mac Stone; Calvin Walker; Jennifer Taylor; joe.dickson@wholefoods.com; Tracy Favre;

Wendy Fulwider; McEvoy, Miles - AMS

Subject: Re: Motion on emergency tetracycline

Date: Thursday, April 11, 2013 8:06:16 PM

OK Jean

On Apr 11, 2013, at 8:01 PM, Jay Feldman wrote:

> Request that the NOP investigate the ability of the Secretary to invoke its authority under the "Emergency Spray

 Programs" provision of the Organic Foods Production, 7 U.S.C. 6518(k)(6) and Act 7 C.F.R section 205.672, to

 allow the emergency use of oxytetracycline for fire blight during the period of October 21, 2014 to October 21,

 2017.

> ________________________________

> Jay Feldman| <mailto:jfeldman@beyondpesticides.org>jfeldman@beyondpesticides.org

> Executive Director

> Beyond Pesticides

> 701 E Street, SE

> Washington DC 20003

> <http://www.beyondpesticides.org/>http://www.beyondpesticides.org

> (202) 543-5450 | fax (202) 543-4791
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: Morning protest

Date: Tuesday, April 29, 2014 7:48:25 AM

Ok

Sent from my iPhone

On Apr 28, 2014, at 8:53 PM, "McEvoy, Miles - AMS" <Miles.McEvoy@ams.usda.gov>

 wrote:

This message has no content.
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Automatic reply: Morning protest

Date: Tuesday, April 29, 2014 7:48:26 AM

I am out of the office. Please contact Joan Avila at 202-720-3252, joan.avila@ams.usda.gov if

 you need immediate assistance.

This electronic message contains information generated by the USDA solely for the intended

 recipients. Any unauthorized interception of this message or the use or disclosure of the

 information it contains may violate the law and subject the violator to civil or criminal

 penalties. If you believe you have received this message in error, please notify the sender and

 delete the email immediately.
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: Morning protest

Date: Tuesday, April 29, 2014 7:48:27 AM

Ok

Sent from my iPhone

On Apr 28, 2014, at 8:53 PM, "McEvoy, Miles - AMS" <Miles.McEvoy@ams.usda.gov>

 wrote:

This message has no content.
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: NOC

Date: Tuesday, June 30, 2015 2:33:21 PM

Abby Youngblood called me just now. I had asked for a specific list of concerns but she stated she cannot yet do this

 as NOC is having a hard time reaching consensus regards the oral comment Webinar. I stated that I believed we

 would be following up as requested with a phone conference call. She thanked us for responding to NOC.

Cheers

Jean
From: McEvoy, Miles - AMS

To: Arsenault, Michelle - AMS; Brown Rosen, Emily - AMS; Brines, Lisa - AMS; "Jean Richardson"

Subject: FW: NIFA Organic Programs announcement

Date: Friday, March 06, 2015 12:09:34 PM

fyi

From: Ngouajio, Mathieu 

Sent: Friday, March 06, 2015 11:49 AM

To: Rakola, Betsy - OSEC

Cc: McEvoy, Miles - AMS

Subject: NIFA Organic Programs announcement

Betsy

Our two organic RFAs have been released.  Please note that we have included a link to NOSB

priorities in the RFAs: Page 8 for OREI and Page 7 for ORG.

Please share the information below with your network and perhaps the Organic Insider.

Dear all

The 2015 NIFA Organic Programs RFAs have been released and can be accessed at the

following links:

Organic Agriculture Research and Extension Initiative (OREI)

NIFA Funding Opportunity Page:

http://www.nifa.usda.gov/fo/organicagricultureresearchandextensioninitiative.cfm.

Grants.gov Page:

http://www.grants.gov/web/grants/view-opportunity.html?oppId=274996.

Organic Transitions (ORG)

NIFA Funding Opportunity Page:

http://www.nifa.usda.gov/fo/organictransitionsprogram.cfm.

Grants.gov Page:

http://www.grants.gov/web/grants/view-opportunity.html?oppId=274820.

Please share this announcement with potential applicants

Best regards

Mat

Mathieu (Mat) Ngouajio, Ph.D.

National Program Leader – Division of Plant Production

USDA-NIFA (National Institute of Food and Agriculture)

Institute of Food Production and Sustainability

Stop 2240

1400 Independence Avenue, SW

Washington, DC 20250-2240

Tel:  (202) 401-4895

Fax: (202) 401-6488

Email: mngouajio@nifa.usda.gov
Web: www.nifa.usda.gov

INVESTING IN SCIENCE | SECURING OUR FUTURE
From: Jean Richardson

To: Nick Maravell

Cc: Harold Austin; Calvin Walker; tchapman@clifbar.com; Carmela Beck; mac@elmwoodstockfarm.com; Tracy Favre;

Colehour Bondera; Francis Thicke; lisa.delima@momsorganicmarket.com; 

Ashley.swaffar@vitalfarms.com; Zea Sonnabend; Brown Rosen, Emily - AMS; Arsenault, Michelle - AMS; McEvoy,

Miles - AMS

Subject: Re: Nick on the Today Show

Date: Friday, August 21, 2015 8:01:28 AM

I can just hear the beef doing sound bites! Good work Nick

Jean

On Aug 20, 2015, at 11:04 PM, Nick Maravell wrote:

Harold

I estimate I might get 15 to 60 seconds of air time—remember this is television 

news not a documentary. The show is slated to air on Tues. morning.

The topic is the safety of grass fed ground beef compared to conventional 

(feedlot) beef. Consumers Reports (CR) is about to release a study which, I have 

been told, concludes that organic and sustainably raised grass fed ground beef 

contain the lowest levels of pathogens. The news story is about the CR study.

The interview will be conducted tomorrow on my farm. Now my herd and I have 

to prepare our sound bites. 

Nick

On Aug 20, 2015, at 10:31 PM, Harold Austin <harolda@Zirklefruit.com> wrote:

Francis

Thanks for letting us know that! Did he say what exactly it would be on?

Sent from my U S Cellular® Smartphone

-------- Original message --------

From: Francis Thicke

Date:08/20/2015 6:47 PM (GMT-08:00)

To: Harold Austin ,'Calvin Walker' ,'Tom Chapman' ,'Jean Richardson' ,'Nick 

Maravell' ,'Carmela Beck' ,"'Mac (AGR) Stone'" ,'Tracy Favre','Colehour 

Bondera' ,'Jennifer Taylor' ,'Lisa de Lima' ,'Ashley Swaffar' ,'Zea Sonnabend'

Cc: 'Emily - AMS Brown Rosen' ,'Michelle - AMS Arsenault' ,'Miles - AMS 

McEvoy'

Subject: Nick on the Today Show

>>> "Francis Thicke" 2015-08-20T18:47:32.973963 >>>

I was chatting with Nick Maravell today and learned that he will be 

(b) (6)
interviewed for a story to be aired on the Today Show next Tuesday.
From: Jean Richardson

To: Nick Maravell

Cc: Tracy Favre; Francis Thicke; Harold Austin; Zea Sonnabend; Mac (AGR) Stone; Carmela Beck; Calvin Walker; Lisa

 de Lima; Tom Chapman; Colehour Bondera; Jennifer Taylor; Ashley Swaffar; Arsenault, Michelle - AMS; McEvoy,

 Miles - AMS; Brown Rosen, Emily - AMS

Subject: Re: Nick on the Today Show

Date: Tuesday, August 25, 2015 8:46:55 AM

Yeh Nick!

Good work, nice looking animals, lovely looking farm, and you sounded eloquent and sincere.

 I'll buy your beef!

Cheers.

Jean

On Aug 25, 2015, at 8:29 AM, Nick Maravell wrote:

Folks

In true organic form, the cows got more air time than I did. 

The national media obviously think they have more to say.

I should probably let the cows speak for me at the next NOSB meeting.

Nick

http://www.today.com/food/how-safe-your-ground-beef-consumer-reports-howavoid-harmful-t40226

On Aug 21, 2015, at 7:03 PM, Tracy Favre <tfavre@favrehouse.com> wrote:

Wow! Fantastic. Good luck Nick.

T

Sent from my iPad

On Aug 20, 2015, at 8:47 PM, Francis Thicke <fthicke@iowatelecom.net> 

wrote:

I was chatting with Nick Maravell today and learned that he 

will be interviewed for a story to be aired on the Today Show

 next Tuesday.
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Nice Poem

Date: Wednesday, April 10, 2013 11:08:11 AM

Very good reading

Thank you

Jean
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Re: next phone conversation

Date: Wednesday, July 23, 2014 8:09:15 PM

Yes that's right.

Miles V McEvoy

Deputy Administrator

USDA National Organic Program

> On Jul 23, 2014, at 6:28 PM, "Jean Richardson" < wrote:

>

> Hi Miles

> I have our next phone call set for 8 am on Monday the 28th correct?

> Thank you

> Jean

This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

(b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: New NOSB member

Date: Thursday, September 18, 2014 5:01:41 PM

Hi Miles

I think Lisa de Lima was one of my former students!

Jean
From: Jean Richardson

To: Arsenault, Michelle - AMS; Tracy Favre

Cc: Brown Rosen, Emily - AMS; McEvoy, Miles - AMS

Subject: New chair PDS

Date: Tuesday, April 14, 2015 5:13:11 PM

Hi Michelle

I am replacing Mac as Chair of PDS with Tracy. Effective today.

I sent Mac a note.

Tracy will ask Colehour to be Vice Chair and we will move the PPM right along!

Thank you

Jean

Sent from my iPhone
From: Jean Richardson

To: McEvoy, Miles - AMS

Cc: Alonzo, Anne - AMS; Tucker, Jennifer - AMS; Brown Rosen, Emily - AMS; Arsenault, Michelle - AMS; Tracy Favre;

Harold Austin

Subject: New Board Member Training

Date: Sunday, February 08, 2015 1:49:56 PM

Hi Miles and NOP team

Just a note to say thank you very much indeed for an excellent training for new board members.

I do hope that the NOP will make New Member Training a permanent part of its WorkPlan each year . I know that

 it is time consuming and expensive, but I believe that it will lead to greater consistency in our work and strengthen

 collaboration between volunteers and NOP.

In addition, the concept of the 3 NOSB officers attending is logical and will always improve our leadership and

 management. I know that I found it very helpful.

Thank you

Jean
From: McEvoy, Miles - AMS

To: Barry Flam; Carmela Beck (carmela.beck@driscolls.com); Colehour Bondera (colemel@efn.org); Harold Austin;

Jay Feldman; Jean Richardson ( Jennifer.Taylor@famu.edu;

JFoster@ebfarm.com; joe.dickson@wholefoods.com; Nicholas Maravell ( Robert Mac

 Stone (mac@elmwoodstockfarm.com); Rueben Walker ( Tracy Favre

 (tfavre@favrehouse.com); wendy.fulwider@organicvalley.com; Zea Sonnabend (zea@well.com)

Subject: New Advisory Board Specialist

Date: Friday, March 09, 2012 5:38:34 PM

Attachments: image001.png

Starting on Monday, March 12, 2012 you will have a new Advisory Board Specialist/Special

 Assistant to the Board.

Michelle Arsenault comes to the National Organic Program after a diverse set of experiences,

including time as a geologist, program assistant, teacher, and park ranger.  For the past five years,

she has served both the National Science Foundation and the National Oceanic and Atmospheric

Administration as a program assistant for Science and Education grant programs.  She is also

currently teaching a geology class at NOVA Annandale.  With a strong interest in environmental

issues, she has served as a National Park Service Ranger, and in a variety of volunteer roles related

to the environment.  She holds a B.A. in Geology from Smith College, and an M.S in Geology/Glacial

Geomorphology and Neo-Tectonics from Oregon State University. 

Please join me in welcoming Michelle to the NOP.  We will send out her contact information next

week.

Miles V. McEvoy

Deputy Administrator

National Organic Program

U.S. Department of Agriculture

Room 2646-So. (Stop 0268)

1400 Independence Ave SW

Washington, DC 20250-0268

202-720-3252

www.ams.usda.gov/nop

Organic Integrity from Farm to Table, Consumers Trust the Organic Label

Register for the NOP Organic Insider, the National Organic Program’s email notification service, by

visiting http://bit.ly/NOPOrganicInsiderRegistration. 

This electronic message contains information generated by the USDA solely for the intended

 recipients. Any unauthorized interception of this message or the use or disclosure of the

 information it contains may violate the law and subject the violator to civil or criminal

 penalties. If you believe you have received this message in error, please notify the sender and

 delete the email immediately.

(b) (6) (b) (6) (b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: need to talk please

Date: Sunday, March 15, 2015 9:16:28 PM

Great!

Sent from my iPad

> On Mar 15, 2015, at 8:54 PM, "McEvoy, Miles - AMS" <Miles.McEvoy@ams.usda.gov> wrote:

>

> We plan to send out clarification tomorrow

>

> Miles V McEvoy

> Deputy Administrator

> USDA National Organic Program

>

>> On Mar 15, 2015, at 7:29 PM, "jean richardson" < wrote:

>>

>>

>>

>>>

>>> Hi Miles

>>> lets have a quick talk about the hydroponic Fed Register notice correction please. I am getting lots of calls and

 e-mails.

>>> Can you call me tomorrow (Monday) morning?

>>> Thank you

>>> Jean

>>

(b) (6)
From: McEvoy, Miles - AMS

To: "Harold Austin"

Cc: Arsenault, Michelle - AMS; "Tracy Favre"; "Jean Richardson"

Subject: RE: Nasty e-mail to Harold

Date: Thursday, May 07, 2015 2:52:01 PM

Harold,

Unfortunately I do not have any better advice to offer other than what Jean suggested, do not

 respond or otherwise engage. Sadly freedom of speech applies to even very hateful speech. As

 long as the person does not engage in direct threats, such as “if I ever see you on the street then I

 am going to (insert potential threat).” Even then it could be a tough sell having to prove someone

 was serious and had the ability to follow through on the potential threat.

I feel very bad that this is happening to you especially because of all you do to support the organic

 community. It’s a shame that you have to put up with this type of abusive behavior.

As Jean said – keep getting better.

Best to you and your family and never hesitate to reach out if you need anything.

Miles

Miles McEvoy

Deputy Administrator

National Organic Program

From: Jean Richardson [mailto:

Sent: Thursday, May 07, 2015 1:55 PM

To: Harold Austin

Cc: Arsenault, Michelle - AMS; Tracy Favre; McEvoy, Miles - AMS

Subject: Re: Nasty e-mail to Harold

Harold: 

there are a lot of nasty people out there. My inclination is to ignore it, but I am copying Miles

here in case he has other NOP advice.

I had a stunningly vile man hurling abuse at me for several months when I was first on the

board.

On the advice of NOP I did not engage him in conversation.

keep getting better

best

Jean

On May 7, 2015, at 1:25 PM, Harold Austin wrote:

Thought you should see this......seriously!

(b) (6)
Sent from my U.S. Cellular® Smartphone

-------- Original message --------

From: Beverly Lawrence

Date:05/07/2015 8:49 AM (GMT-08:00)

To: Harold Austin

Subject: Your position on NOSB

>>> "Beverly Lawrence" 2015-05-07T08:49:05.779885 >>>

Really? Synthetic Methionine is okay to increase in chicken feed? For organic chickens? And

this is for the welfare of the chickens??? What about PEOPLE who want clean food options

Harold?

It's a shame you didn't fall and break your head instead of your hip. Clearly it is time for you

to step down from your position as you do not have the best interests of the people of this

country in mind. You have profit in mind. Shame on you.
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Re: NASDA etc

Date: Saturday, September 13, 2014 2:52:28 PM

Thanks for the update. Heading back to DC tomorrow. Will talk to all NOSB folk.

Miles V McEvoy

Deputy Administrator

USDA National Organic Program

> On Sep 13, 2014, at 8:01 AM, "Jean Richardson" < wrote:

>

> Hi Miles

> * NASDA talk seemed to go well. I gave a copy of my remarks to Betsy. Questions were practical in nature so I

 was also able to show I had boots on the ground experience. Gary Hirshberg was excellent, we made a good team. I

 was overwhelmed with positive comments over the two days and collected a lot of business cards and invitations to

 speak! It was so amazing to see how far we have come in organics being mainstream now! Chuck Ross did an

 amazing job in broadening the national agricultural dialog. His theme was agricultural literacy.

> * The Cornucopia article will be out next week. You will not be entirely happy with it, but you did not see the

 earlier version!!!! I did get some good points and facts in the article however. So taken all together it may help. In

 future I will try to do the question and answer format used by NODPA as that at least allows my voice in the

 interview separate from the perspective of the organization.

> * I chatted with Tracy at some length about her talk for Expo East.

> * Your telephone calls to NOSB members are good. Please try to talk to all 15 - I know that will be hard, but it is

 team building!

> * Leahy staff contacted me again to get up to date with progress on changes.

> * I have not made progress on articles about departing NOSB members. I may get time this week.

> All for now,

> Jean

This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

(b) (6)
From: Jean Richardson

To: Paula Daniels

Cc: McEvoy, Miles - AMS; Tracy Favre

Subject: Re: my resignation from NOSB

Date: Tuesday, August 25, 2015 8:38:35 AM

Hi Paula

Thank you for letting us know .

We all wish you well in your work in California.

I hope that our paths cross again.

Very Best Wishes

Jean

> Dear Miles --

>

> It is with a mix of reluctant emotions that I submit my resignation from the National Organic Standards Board. As

 we've discussed, in March of this year there was an unexpected change in my work and civic obligations which also

 involves a previously unanticipated and significant commitment of time and attention. The nature of these new and

 current obligations will not allow me to devote the necessary attention to the requirements of the NOSB at this

 juncture.

>

> I have delayed this decision to see if circumstances may afford an opportunity to dedicate some time to my role on

 the NOSB, but so far this does not appear to be the case.

>

> In order to make the seat available to someone who can fully participate, it seems best that I resign.

>

> I do regret that I am not able to remain involved for the long term, as the work is important and honorable. I had

 been proud to be able to say that I was a member of the NOSB, and am sorry that my time in that capacity was so

 short.

>

> I greatly value the experience I was able to have, including the chance to meet some outstanding people -- yourself

 included -- who have devoted their talents to the cause of improving the food system through the organic standards.

>

> With deep gratitude for the opportunity,

>

> Paula
From: McEvoy, Miles - AMS

To: Paula Daniels

Cc: Jean Richardson; Tracy Favre

Subject: RE: my resignation from NOSB

Date: Tuesday, August 25, 2015 3:11:37 PM

Paula –

I understand your mix of emotions. The NOSB is both rewarding and demanding. Thank you for your

 service. You contributed a lot since you joined the board in January. Best of luck in your endeavors

 and keep in touch.

Best,

Miles

Miles V. McEvoy

Deputy Administrator

National Organic Program

1400 Independence Ave. SW

Washington, DC 20250-0268

202-720-3252

http://www.ams.usda.gov/about-ams/programs-offices/national-organic-program

Organic Integrity from Farm to Table, Consumers Trust the Organic Label

From: Paula Daniels [mailto:pdaniels@goodfoodla.org] 

Sent: Monday, August 24, 2015 10:13 PM

To: McEvoy, Miles - AMS

Cc: Jean Richardson; Tracy Favre

Subject: my resignation from NOSB

Dear Miles -- 

It is with a mix of reluctant emotions that I submit my resignation from the National Organic

Standards Board. As we've discussed, in March of this year there was an unexpected change

in my work and civic obligations which also involves a previously unanticipated and

significant commitment of time and attention. The nature of these new and current obligations

will not allow me to devote the necessary attention to the requirements of the NOSB at this

juncture. 

I have delayed this decision to see if circumstances may afford an opportunity to dedicate

some time to my role on the NOSB, but so far this does not appear to be the case. 

In order to make the seat available to someone who can fully participate, it seems best that I

resign. 
I do regret that I am not able to remain involved for the long term, as the work is important

and honorable. I had been proud to be able to say that I was a member of the NOSB, and am

sorry that my time in that capacity was so short. 

I greatly value the experience I was able to have, including the chance to meet some

outstanding people -- yourself included -- who have devoted their talents to the cause of

improving the food system through the organic standards.

With deep gratitude for the opportunity, 

Paula
From: Jean Richardson

To: McEvoy, Miles - AMS; Brown Rosen, Emily - AMS; Tracy Favre

Subject: Fwd: NOC and PPM edits

Date: Friday, August 14, 2015 8:21:12 AM

Attachments: memo to Miles re 7-28-2015 callFINAL.pdf

Hi Miles, Emily and Tracy

In reviewing the attached NOC memo, may I suggest that we quickly and carefully review our

 PPM which we are about to post to make sure we have adequate language which covers us all

 for the necessary flexibility to run public meetings and do webinars and use modern

 mechanisms for ensuring good public input. If necessary we should make the necessary

 clarification edits before posting.

Thank you

Jean

Begin forwarded message:

From: Steve Etka <

Date: August 12, 2015 5:17:29 PM EDT

To: "McEvoy, Miles" <miles.mcevoy@ams.usda.gov>

Cc: "Alonzo, Anne - AMS" <anne.alonzo@ams.usda.gov>,

rex.barnes@ams.usda.gov, "Rakola, Betsy"

 <Betsy.Rakola@ams.usda.gov>, lisa.brines@ams.usda.gov, Jean

 Richardson < "nocmembers@googlegroups.com" <noc-members@googlegroups.com>

Subject: Follow up on our July 28th conference call about NOSB

 webinars, ionizing radiation, and materials review

MIlesThanks for the productive call on the 28th. 

Please see the attached document, as a follow up to that discussion. 

Thanks,

Steve Etka

National Organic Coalition

(b) (6) (b) (6)
To: Miles McEvoy, Deputy Administrator, National Organic Program

cc: Anne Alonzo, Administrator, USDA/Agricultural Marketing Service; Rex Barnes, Associate

Administrator, USDA/Agricultural Marketing Service; Betsy Rakola, Organic Policy Advisor, U.S.

Department of Agriculture; Jean Richardson, Chairperson, National Organic Standards Board;

NOC Members

From: Steve Etka, Lynn Coody, Terry Shistar, on behalf of National Organic Coalition

Members

Date: August 12, 2015

Re: Our conversation of July 28, 2015

In this memo, we repeat points we made in our conversation of July 28, 2015. We also recall

and respond to some comments that you made. We ask you to let us know if this memo does

not agree with your recollection.

I. Participants on Call 

Miles McEvoy (NOP)

Lisa Brines (NOP)

Betsy Rakola (AMS)

Steve Etka (NOC)

Lynn Coody (Organically Grown Company)

Terry Shistar (Beyond Pesticides)

Allie Mentzer (National Co+op Grocers)

Harriet Behar (MOSES)

Aimee Simpson (Consumers Union)

Carol Goland (Ohio Ecological Food and Farm Association)

Liana Hoodes (NOC Consultant)

Michael Sligh (RAFI)

II. The agenda of the call consisted of three issues: 

1. The use of webinars for public comment regarding the agenda of the Fall 2015 meeting

of the National Organic Standards Board;

2. Information you wished to share regarding ionizing radiation; and

3. Information you wished to share regarding changes updating NOP Policy Memo 11-4

concerning Materials Review Instructions.

1. The use of webinars for public comment regarding the agenda of the Fall 2015 meeting of

the National Organic Standards Board

Regarding the use of webinars for public comment on NOSB meeting agenda topics, we raised

issues relating specifically to fall 2015, as well as general issues.

A. Regarding the fall 2015 agenda
We fully understand the time and resource constraints faced by the NOP and NOSB with regard

to the heavy workload associated with consideration of the 2017 sunset materials at the

October NOSB meeting in Vermont. We appreciate NOP’s willingness to look for creative

solutions to the problem and to reach out to NOC ahead of time to discuss these options. We

appreciate you reaching out to NOC, and hope that will continue. We hope that you are also

reaching out to others in the affected organic community, to get a full range of perspectives on

this.

We fully support the idea of having two webinars in advance of the NOSB meeting to provide

an opportunity for an additional public comment opportunity. For some, this may be a great

opportunity to provide comment without incurring the time and cost of attending the NOSB

meeting itself.

It is our understanding that despite an earlier proposal, the NOP has decided NOT to reduce the

amount of time allotted to public comment at the NOSB meeting itself. We also greatly

appreciate this, and would not support having webinars as a replacement for in-person public

testimony.

B. The general issues we raised relate to the process of adopting webinars as a part 

of NOSB meetings.

As you know, NOC members are sticklers for process, because we believe that having a clear

and transparent process that follows established rules is the best way to ensure public

engagement where all stakeholders have access to the NOSB and organic standard setting

arena. It is also essential to democracy. There are a few areas where we believe the NOP needs

to ensure that proper process is followed.

First, since electronic meetings of the NOSB are not permitted under the NOSB’s own Policy and

Procedures Manual (PPM), webinars should not be considered part of the NOSB meetings until

the PPM is amended.

Public comment and public testimony are two distinct opportunities for giving input.

Public comment includes:

• Public comment subject to the rules of the public comment period, as presented in the

announcement in the FR prior to the meeting.

• Information is submitted prior to the meeting, either in writing and/or via the proposed

webinar.

• Information submitted in public comments is recorded and is accessible to the NOSB

and the public in preparation for the NOSB meeting.

Public testimony is in-person oral comments presented during the meeting. It is subject to FACA

and the PPM.

So, we believe the best framing for the webinars is as a new, additional format for participating

in public comment period. As has always been the case, participation in the Public Comment

period does not preclude presentation of Public Testimony. Therefore, we disagree with the
NOP proposal that people who speak during the webinar may not also make a presentation

during the NOSB meeting. We believe the webinars before the Stowe meeting can serve as a

test drive of a new system by determining:

• How many people are interested in the webinar as a form of input,

• Whether people will voluntarily use it as a substitute for attending the meeting to make

in-person public testimony, and

• How useful and satisfactory this method of receiving public comment is to the NOSB.

Second, if webinars at some time are to be treated as part of the NOSB meeting, then the

proposal to use webinars as part of the public comment portion of the meeting should be made

first as a proposed addition to the PPM, and proceed through the normal NOSB process for

adopting changes to the PPM, including a notice to the public. We realize that this process is

time consuming, but we believe that following the process is important.

Third, it is our understanding that stakeholders who chose to comment during the webinars

may be barred from doing so at the NOSB meeting itself. We urge you to not make this an

either/or opportunity, because issues may arise in the intervening time that stakeholders may

wish to address at the meeting itself, even if they provided earlier comments during the

webinar.

We also raised ideas for reducing the time burden in future meetings in which there are many

sunset items. Some ideas may require changes to the PPM and hence public comment. But

even if public comment is not required, it can help the Program to address this difficult issue.

Other ideas we have considered in our brainstorming process about this and future meetings

are:

• In the future, the sunset lists could be split into different timeframes so as to avoid the

huge onslaught of materials decisions at one NOSB meeting. We have heard that this

idea is being considered. Although our members are intrigued by this idea, and think it

could be a good solution, we have brainstormed other possibilities.

• The NOSB meeting could be extended, if needed, to accommodate the need for public

comment as well as the time required for review of the 2017 sunset materials;

additional hours could be added during an evening session or the meeting could be

extended by an extra day or half day. Since the fall 2015 meeting and spring 2016

meeting fall in the same fiscal year, perhaps the spring 2016 meeting could be shorter,

resulting in a smaller increase in cost.

• Can the NOSB and NOP provide clarification about how you will use public comments on

the 2017 sunset materials and clarify the issue of “untimeliness”? This question arises

because under new sunset rules and procedures, substantive comments presented

during the October meeting (as well comments given during the proposed webinars) are

considered “untimely” under the new sunset rules and procedures. A careful

articulation of the meaning and impact of the concept of “untimeliness” would help

guide participants to craft comments that are relevant given the new procedure and not

a reiteration of information presented previously in La Jolla.
• We would like to reiterate our support for an open docket, which has been requested by

many organizations and individuals, and would allow for continuous dialogue and public

input between meetings. A proposal for an open docket/portal was passed unanimously

by the NOSB at the April 2013 meeting.

C. What we heard you say.

• With regard to the fall 2015 comments, we heard you say that although the reduction of

time for public testimony at the meeting was considered, that NOP determined that it

was not a good idea, so the same amount of time will be allocated as for the last 6

meetings.

• With regard to the general points, we heard you say:

o Everything that the Board does is under FACA.

o Oral public comments can be received in either venue, before or during meeting,

but not both.

o Webinars are scheduled after the close of the public comment period and before

the meeting in Stowe.

o Nothing in FACA requires NOP to keep a meeting transcript—NOP just does that.

FACA requires detailed notes only.

o The Board is working on substantive changes to the PPM that will be posted for

the fall meeting.

o The Board is very interested in being able to meet electronically. If the Board

cannot finish its work on the Sunset materials, it might be continued

electronically later on. USDA/NOP is looking at ways to use technology to

support the work of the Board.

o NOP is trying to set up the webinars to be interactive, allowing questions and

answers.

• With regard to NOC’s ideas for the future, we heard you say you look forward to our

input.

• With regard to NOC’s comments concerning the timeliness of substantive comments on

2015 sunset items at the fall meeting, we heard you say.

o There is a lot of value to the comments coming in. If information comes in at this

meeting and results in a substantive change, the material would have to go back

to the SC for reconsideration at the next meeting. Some discussion ensued,

where NOC heard Miles clarify that it is not public comment that would be

considered untimely, but a substantive change in the subcommittee proposal

that would be considered untimely.

2. Ionizing radiation

Thank you for giving us a heads-up on your plans. This is what we heard you say:
• Certifiers have a lot of questions about this. There are many things that could be

considered to be ionizing radiation, so NOP is putting the answers that they have

been providing for years into the Handbook.

• The instruction would define Ionizing Radiation as per the FDA regulation, which is

cited in the NOP regulations.

• NOP plans to publish this Instruction for public comment.

• Even before the publication, NOP is seeking NOC feedback or concerns about FDA’s

definition.

• In response to NOC’s request, you said you would send the FDA regulation so that

we know we are on the same page.

3. Materials Review Instructions – updating NOP Policy Memo 11-4 

Thank you again for giving us a heads-up on your plans. This is what we heard you say:

• NOP is approaching this topic via an Instruction because they do not have the authority

to accredit MROs. The purposes are:

o Clearer criteria for how to review materials;

o Specify certifier’s responsibility;

o Education and training;

o Clear written protocols;

o Go into a lot more detail on materials review;

o Define an MRO.

• MRO’s must

o Request recognition from NOP;

o Get accredited to ISO 17065;

o Get accreditation with a member of the NOP as a member of the audit team as a

technical expert.

• NOP is intending to put this instruction out for public comment –not through FR notices,

but through its own system of putting out Instructions. This avoids the backlog at the FR.

The announcement will be through Organic Insider, as opposed to through

regulations.gov.

• In response to our question concerning whether the instructions will cover how

certifiers are audited on these points and whether you are referencing 50a.a.21, you

said that this will be the mechanism used to operationalize the Instruction. It will be

additional an requirement of accreditation.

III. Some reactions

Thank you for taking the time to meet with us. We have a couple of immediate responses to

issues that were discussed.
• We are puzzled about your comments concerning “untimeliness” of

comments/proposals at the second sunset meeting. The September 16, 2013 Federal

Register notice says, “Proposals to remove substances from the National List can only be

considered by the NOSB if they were published as part of the Subcommittee’s

preliminary review for public comment in advance of the NOSB meeting. If the

Subcommittee identifies new information at the meeting that it believes merits

reconsideration of the conclusions presented in the preliminary review, that information

will be considered untimely for purposes of the Sunset Review process.” This statement

says that the information is untimely. In addition, our understanding is that all

subcommittee proposals are proposals to delist, so information could not change the

proposal anyway.

• We do intend to give you some comments on the definition of ionizing radiation.


From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Automatic reply: NOC position on hydroponics

Date: Saturday, February 15, 2014 7:57:00 AM

I am out of the office. Please contact Joan Avila at 202-720-3252, joan.avila@ams.usda.gov if

 you need immediate assistance.

This electronic message contains information generated by the USDA solely for the intended

 recipients. Any unauthorized interception of this message or the use or disclosure of the

 information it contains may violate the law and subject the violator to civil or criminal

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 delete the email immediately.
February 7, 2014

NOC Position on Hydroponic Production

The central theme and foundation of organic farming is the maintenance and 

management of organic matter in the soil, along with the diverse populations 

of organisms that are the foundation of soil ecosystems. Macro and micro 

organisms found in abundance in a well- maintained soil tie together a web of 

interactions that conserve and recycle the elements between all the living 

organisms and minerals in the system. It is the management of this ecological 

balance that defines organic production. Any system labeled organic, (including 

hydroponics) should also be based on management of this ecological balance.

Hydroponics is the most widely used term for the production of crops without 

soil. That system of production most often provides nutrients needed to 

produce a crop by suspending the roots in a nutrient rich solution grown in 

moist inert material. 

Nutrients most commonly used in hydroponic nutrient solutions are synthetic 

salts. Hydroponic solutions can be made using only natural materials, including 

natural mineral salts and organic residuals. While some certifiers believe that 

this makes the production system organic, other certifiers do not because they 

believe that there is much more to organic production than simply adding 

materials for crop fertilization or crop protection. 

NOC finds this differing interpretation and implementation of the NOP 

standards by certifiers disturbing. Inconsistencies among certifiers weaken the 

organic label and reflect poorly on the industry. The NOSB agrees. In 2010 the 

NOSB made a recommendation to the NOP in which they provided guidance on 

which kinds of soilless production systems should or should not be labeled 

organic.

The NOSB Crops Committee Recommendation "Production Standards for 

Terrestrial Plants in Containers and Enclosures"1

 

1 (January 23, 2010

 underscores this point. The 

http://www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELPRDC5084677) 

National Organic Coalition

www.NationalOrganicCoalition.org

NOC MEMBERS

Beyond Pesticides

Center for Food 

Safety

Consumers Union

Equal Exchange

Food & Water Watch

Maine Organic 

Farmers and 

Gardeners Association

Midwest Organic and 

Sustainable Education 

Services

National Cooperative 

Grocers Association

Northeast Organic 

Dairy Producers 

Alliance

Northeast Organic 

Farming Association -

Interstate Council

Ohio Ecological Food 

and Farm Association

Organic Seed

Alliance

Organically Grown 

Company

Rural Advancement 

Foundation 

International -USA

Union of Concerned 

Scientists

Liana Hoodes

Liana@NationalOrganicCoalition.org (b) (6)
recommendation stresses that organic farmers are not just tillers of the soil, but also 

stewards of the soil ecology on the farm and shepherds of the myriad 

organisms that support thriving soil ecosystems. They do not just open bags of 

nutrients to feed crops and then become certified organic farmers. 

The USDA National Organic Program recognized this foundation of organic when they 

wrote the Organic Rule. At the heart of the regulation of organic production (7 CFR Part 

205 National Organic Program; Final Rule) is the definition:

Organic Production- A production system that is managed in accordance with 

the Act and regulations in this part to respond to site-specific conditions by 

integrating cultural, biological, and mechanical practices that foster cycling of 

resources, promote ecological balance, and conserve biodiversity.

In organic agriculture, soils are valued for the multiple functions a biologically diverse 

soil food web provides, not just as a substrate for holding plant roots so the plant grows 

upright.

Many soilless systems, including hydroponics, represent the antithesis of organic 

production systems because they aim to diminish the ecological complexity of the 

natural production systems. By reducing the living organisms in a hydroponic system to 

solely the crop, the ecological balance is lost. Such a ‘system’ merely feeds the crop with 

simple inputs of ‘required’ nutrients. On the other hand, some soilless crop production 

that is part of a complex ecological system may fit the definition of organic as laid out in 

the Rule (for example, transplants which eventually are planted in soil, or a system of 

aquaponics that cycles nutrients from fish through plants and back, and adds 

wormcastings and compost). 

Until a clear definition has been provided by the NOP, certifiers should not be allowed 

to certify hydroponic systems. Certifiers need to be directed as to which systems may be 

certified, and which do not meet the criteria and are not eligible for organic 

certification. NOC urges the NOP to write “NOP Instruction to Certifiers” that leads to 

Rulemaking. The instruction should include clear criteria that follow the NOSB 2010 

recommendation, and adhere to the definition of organic production presented in the 

Rule. 
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: NODPA Interview

Date: Monday, September 01, 2014 12:25:21 PM

Attachments: NODPA interview.doc

Hi Miles

NODPA interview.

Thanks

Jean
From: McEvoy, Miles - AMS

To: Nora Owens; "Jean Richardson"; "Henry Perkins"

Subject: RE: NODPA Field Days program information for presenters

Date: Wednesday, September 17, 2014 3:57:50 PM

Hi Nora,

I’ll arrive Thursday afternoon and leave before lunch on Friday.

I’ll have a powerpoint presentation.

Look forward to seeing everyone next week.

Miles McEvoy

Deputy Administrator

National Organic Program

From: Nora Owens [mailto:

Sent: Wednesday, September 17, 2014 3:19 PM

To: McEvoy, Miles - AMS; 'Jean Richardson'; 'Henry Perkins'

Subject: RE: NODPA Field Days program information for presenters

Good afternoon Miles, Jean and Henry,

The 14th annual NODPA Field Days are a week away and I wanted to check in with you all to see if

 there are any questions or if I can assist you in your travel plans. I sent the program information

 email in July (below) but thought a refresher might be useful. Please take a look and let me know if

 you will have any AV needs. Also, it would be very helpful if you could let me know whether you

 will be attending the whole meeting—both days, with lunch and dinner on Thursday, and breakfast

 and lunch on Friday, or portions of it. Please let me know which meals you’d like; this will help me

 provide an accurate meal count to our caterer.

Thanks and I look forward to hearing from you at your earliest convenience.

Looking forward to seeing you next week, 

Nora

From: Nora Owens [mailto:

Sent: Tuesday, July 22, 2014 11:13 AM

To: McEvoy, Miles - AMS (Miles.McEvoy@ams.usda.gov); 'Jean Richardson'; 'Henry Perkins'

Cc: 'Ed Maltby'

Subject: NODPA Field Days program information for presenters

Dear Miles, Jean and Henry,

Thank you for agreeing to present at the 14th annual NODPA Field Days on September 25 & 26, 2014

 at Stonewall Farm, Keene, NH. For your information, I have attached the most up-to-date program,

 and am available at any time to answer your questions-the best number is We’ve

 already received very positive feedback on this strong educational program from folks planning to

(b) (6) (b) (6) (b) (6)
 attend.

Your first session, “The Future of Organic Certification” is scheduled for Friday, September 26th,

 7:00 – 9:00 pm, following NODPA’s Annual Meeting. We are planning to have the format set up as a

 panel, with a table and microphones (if necessary), and each person has up to 30 minutes to

 present, with 30 minutes for Q&A and discussion at the end. The order of presentation will likely be

 Miles first, Jean, second, and Henry as the final presenter. I’d be happy to consider any format

 changes or thoughts on the presentation if you have them. NODPA board members or staff will

 moderate your session. While we are able to provide the necessary projector and laptop if you have

 a PowerPoint presentation, we’ve found that direct conversations with the audience works very

 well, too. If you have technical needs, please let me know. One word of caution, the room we will be

 using does not have black-out curtains, so please plan your presentation accordingly. You will still be

 able to see a screen but the details might be muted, depending on the weather that day.

Miles and Jean, you are also being asked to answer questions that may come up in the session

 entitled “What’s Happening in Washington?” a session led by Ed Maltby, NODPA Executive

 Director, on Friday from 10:30 to 11:00 am. We anticipate that this will be a fairly informal process

 but will ask that you join Ed at the front of the room. Please let me know if you have any questions. 

Thanks again for generously providing your time and effort to making NODPA’s Field Days

 educational and enjoyable for all that attend.

Best regards,

Nora Owens

NODPA Field Days Coordinator

Nora Owens

30 Keets Road

Deerfield, MA 01342

P: 413-772-0444

F: 866-554-9483

C: 

This electronic message contains information generated by the USDA solely for the intended

 recipients. Any unauthorized interception of this message or the use or disclosure of the

 information it contains may violate the law and subject the violator to civil or criminal

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 delete the email immediately.

(b) (6) (b) (6)


N: The USDA NOP has mandated a change in the relationship between the NOP and the Board, 

what is your opinion of this, and what steps will the Board be taking under your leadership to try to 

reclaim its independence and ensure the integrity of the Organic Seal?

JR: Many will remember that one of the hard fought compromises in establishing the NOP was that the 

NOSB should be more than the typical Federal Advisory Committee (FACA), and have greater 

independence. There was concern that the government would take over organics and the role of public 

input, especially small farmers would be diminished or lost. So from 2002-2013 the NOSB had 

considerable independence, developed and took public comment on policies and procedures, wrote 

annotations for materials at Sunset, and put items on its Workplan. In 2013 and early 2014, that changed. 

The AMS determined that it would be more efficient and streamlined, given the cumbersome nature of 

Rule Making in Washington, to have a new Sunset Policy, and the NOSB should have the same scope of 

responsibility as all other FACA committees. Much of this change was probably pushed by the fastgrowing big farms and food manufacturers who, understandably, need predictability to run their 

businesses. A volunteer board, like many aspects of democracy, is messy and time consuming and not 

always predictable. Please note here that some aspects of the new Sunset procedure are an excellent 

improvement over the previous Sunset procedure, requiring that the highly complex reviews start early, 

with increased opportunity for public input. How the final step will work will be seen in October as we 

complete some of our first reviews under the new Sunset process. It is not a perfect procedure, but we will 

try to make it work well. As Chair I talk regularly with the Deputy Administrator, Miles McEvoy, and I 

have met with Senator Leahy and continue to interact with his staff. I am concerned that some of these 

changes have decreased the ability of the NOSB to carry out the mandate of the original OFPA. But I am 

hopeful that we will see an increase again in the collaboration between the NOP and the NOSB. 

N: The NOSB and its two meetings a year is seen by many organic stakeholders as their only 

avenue for commenting on and influencing the future of organic certification. What potential do 

you see for ensuring that there is transparency and accountability in how the NOP operates, and 

what role does the NOSB play in this process?

JR: It is unfortunate that stakeholders perceive that the two meetings a year are the only way to get their 

opinions heard. This is really not the case. Anyone can contact board members or the NOP staff by phone 

or e-mail. The NOSB has recommended many times that we set up an ongoing Blog for comment but this 

keeps coming up with problems to set up and staff. I would encourage you to keep asking questions, and 

sending out your NODPA News publication, which is influential and read by the NOP staff. I would also 

encourage you to give regular feedback to your Washington Congressional Delegation. 

N: Organic certification is the biggest growth area in agriculture and a billion dollar industry. 

What are your thoughts about the dynamic and inevitable conflict between the need for more 

synthetic materials to assist the growth of manufactured organic products while maintaining the 

integrity and uniqueness of organic certification?

JR: When it comes to the subject of synthetics, and the increase in demand for synthetics from companies 

proposing new organic products, I would ask everyone to have confidence in the NOSB’s work on this 

issue. You will see quite a few synthetics being proposed by the NOSB to be removed from the National 

List this year, next year and 2017; we are working on all these right now. Every substance gets reviewed 

in minute detail, and certainly in far more depth than when many of them were placed on the National 

List in 1995. There will be rigorous debate and more transparency.

N: Under the leadership of Deputy Secretary, Kathleen Merrigan, the Board was encouraged to 

look at issues like animal welfare which is so important to producers and consumers alike. The new 
leadership at USDA AMS is more inclined towards marketing and expansion of organics as a 

brand.

JR: The USDA is a huge agency. The Agricultural Marketing Service (AMS) component is small, and 

the NOP is a tiny part of AMS. It is unfortunate in some ways that organics were placed in marketing, but 

that is what we have to work with, and yes the present message from AMS to NOP is marketing related 

and lobbied by big business. Organics is a 35 billion dollar industry and marketing is critically important 

for all of us, local and national, big and small. That is how US agriculture works. And we have a cheap 

food policy in the U.S., which reduces slim profit margins and increases competition. So if marketing is 

the present emphasis, we need to determine what we can do to get the most out of it for our farm 

businesses. We do need to boost consumer confidence, improve labels on products, reduce consumer 

confusion, and have clear signs at Farmers’ markets. And I would suggest you look at what AMS has to 

offer and take advantage of the opportunities to do better marketing for your products. Pick your battles!. 

Working together, building partnerships is the only way to go.

N: Would it not be a better use of NOP staff and resources to have all meetings in DC, perhaps have 

3 meetings a year, so there could be more time for them to conduct business rather than to travel 

around the country? Perhaps the money saved could be put into a competitive grant program for 

producers to obtain travel grants to attend NOSB meetings?

JR: Actually, I think it is a good idea to move the national public meetings to different locations around 

the country. It helps the NOSB and NOP get a flavor of the geographic diversity of organics. Washington 

is a good location for politics and lobbying opportunities, but it is a much more expensive location to hold 

meetings. Even though NOP staff would not have to fly, there would be no cost savings in holding 

meetings in DC. Our NOSB budget is tiny. The annual total is only $190,000, the ceiling set by USDA, 

based on total allowed funding across all USDA committees. This must cover staff salary and benefits, 

Board travel, and all meeting costs. Please note that we are hoping to hold the late October 2015 

meeting in Stowe, Vermont and I encourage a huge turnout! Maybe I will still be chair! 

Dr Jean Richardson will be on a panel on Thursday evening, talking about ‘The Future of Organic 

Certification’ and on Friday morning she will be participating in the panel ‘What’s happening in

Washington?’ See the full NODPA Field Days Agenda on page ______. To reach Jean, you can email her 

at: 

(b) (6)
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Re: NOP power point slides

Date: Sunday, March 01, 2015 1:56:45 PM

Of course.

Miles V McEvoy

Deputy Administrator

USDA National Organic Program

> On Mar 1, 2015, at 10:58 AM, "Jean Richardson" < wrote:

>

> Hi Miles

> Harold is giving a presentation on NOSB this spring.

> I am assuming I can share with him the power point which I have put together for IOIA Training?

> This is based on your power point used at NODPA.

> I like the idea of consistency in the song sheet!

> Thank you

> Jean

This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

(b) (6)
From: Jean Richardson

To: Wonnacott Enid

Cc: McEvoy, Miles - AMS; enid@nofavt.org; Rachel Fussell; nicole dehne

Subject: Re: NOP Discussion at the NOFA-VT Winter Conference

Date: Wednesday, September 24, 2014 1:17:36 PM

Do you need me on this call?

If so I will try to fit around whatever works for Miles and Enid

Jean

On Sep 24, 2014, at 8:29 AM, Wonnacott Enid wrote:

I have a tentative meeting with the Attorney General’s office to discuss VT 

GMO strategy from 1-3pm, so better hold that time. I am available 10/1 

before noon, or 10/2 between 12-3pm, or Friday (10/3) 10-3pm. Thanks, 

Enid

On 9/24/14 7:15 AM, "McEvoy, Miles - AMS" 

<Miles.McEvoy@ams.usda.gov> wrote:

How about next Tuesday, the 30th, at 1 pm for the conference call?

Miles V McEvoy

Deputy Administrator

National Organic Program

From: Wonnacott Enid [mailto:elila@sover.net] 

Sent: Monday, September 22, 2014 8:58 AM

To: McEvoy, Miles - AMS; enid@nofavt.org

Cc: Jean Richardson; Rachel Fussell; nicole dehne

Subject: Re: NOP Discussion at the NOFA-VT Winter Conference

Great, Miles, Rachel Fussell (attached) is our Winter 

Conference Workshop Coordinator. She will follow up with 

you to develop a description of your workshop, and the

scheduling (Saturday or Sunday). In addition, please think 

about if there is anyone you would like to present your

workshop with – Nicole Dehne? Jean Richardson? Organic 

farmer?

As for meeting to discuss the NOSB, I coach field hockey in the 

fall, so have to end any meeting by 3pm. Are there any days 

next week you can have a discussion earlier in the day?

Thanks, Enid

Enid Wonnacott, Executive Director
Northeast Organic Farming Association of Vermont (NOFAVT)

PO Box 697

Richmond, VT 05477

(802) 434-4122

(802) 434-4154 (fax)

enid@nofavt.org

www.nofavt.org <http://www.nofavt.org> 

On 9/22/14 8:34 AM, "McEvoy, Miles - AMS" 

<Miles.McEvoy@ams.usda.gov> wrote:

Hi Enid,

I like option 1. Looking forward to it.

Are you available for a conference call next week? 

Tuesday, the 30th at 4pm?

Miles

Miles McEvoy

Deputy Administrator

National Organic Program

From: Wonnacott Enid [mailto:elila@sover.net] 

Sent: Thursday, September 18, 2014 2:05 PM

To: McEvoy, Miles - AMS; enid@nofavt.org

Cc: Jean Richardson; Rachel Fussell; nicole dehne

Subject: NOP Discussion at the NOFA-VT Winter Conference

Dear Miles, 

I apologize for my delay in replying to your e-mail. It sounds 

as if we have two things to discuss:

NOSB concerns – it would be great to have a conference 

call with Nicole Dehne, Jean Richardson and myself, if 

that seems appropriate to you. Please suggest another 

time, as we failed to meet the 9/16 suggested date.

Our Winter Conference – there are several options. 1) 

You can speak at a workshop session (1 hr 15 min) and 

then follow that with a 1 hr roundtable discussion which 

would be more of a question and answer opportunity. 

That would be facilitated by Jean Richardson. 
 2) you could do just the workshop, or 3) just the roundtable. 

Our conference is Saturday-Sunday, February 14-15th, and you

 could speak 

 either Saturday or Sunday. 

Please let me know what makes sense for you. Thanks, Enid

Enid Wonnacott, Executive Director

Northeast Organic Farming Association of Vermont (NOFAVT)

PO Box 697

Richmond, VT 05477

(802) 434-4122

(802) 434-4154 (fax)

enid@nofavt.org

www.nofavt.org <http://www.nofavt.org> 

<http://www.nofavt.org> 

On 9/4/14 12:35 PM, "McEvoy, Miles - AMS" 

<Miles.McEvoy@ams.usda.gov> wrote:

Hi Enid and Dave,

I’d like to set up a time to talk about the National Organic 

Standards Board (NOSB). I understand you may have concerns that

 I’d like to hear. I’d also like to discuss some ideas we have about 

organic hydroponics. Are you available on Tuesday, September 16 

at 3 pm eastern time for a conference call?

I’d also like to see if there could be a session at the NOFA-VT 

winter conference to discuss the National Organic Program and 

NOSB. 

Miles McEvoy

Deputy Administrator

National Organic Program

This electronic message contains information generated by the 

USDA solely for the intended recipients. Any unauthorized 

interception of this message or the use or disclosure of the 

information it contains may violate the law and subject the 
violator to civil or criminal penalties. If you believe you have 

received this message in error, please notify the sender and 

delete the email immediately.
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: NOP Discussion at the NOFA-VT Winter Conference

Date: Tuesday, September 30, 2014 10:49:42 AM

Miles

Looks like NOFA and VOF intend using this as a time to discuss Sunset.

I am assuming they are reacting to the NOC White paper

Jean

On Sep 24, 2014, at 5:46 PM, McEvoy, Miles - AMS wrote:

How about 11:30 on October 1?

Conference line number – 

Passcode – 

Miles McEvoy

Deputy Administrator

National Organic Program

From: Wonnacott Enid [mailto:elila@sover.net]

Sent: Wednesday, September 24, 2014 8:30 AM

To: McEvoy, Miles - AMS; enid@nofavt.org

Cc: Jean Richardson; Rachel Fussell; nicole dehne

Subject: Re: NOP Discussion at the NOFA-VT Winter Conference

I have a tentative meeting with the Attorney General’s office to discuss VT 

GMO strategy from 1-3pm, so better hold that time. I am available 10/1 

before noon, or 10/2 between 12-3pm, or Friday (10/3) 10-3pm. Thanks, 

Enid

On 9/24/14 7:15 AM, "McEvoy, Miles - AMS" 

<Miles.McEvoy@ams.usda.gov> wrote:

How about next Tuesday, the 30th, at 1 pm for the conference call?

Miles V McEvoy

Deputy Administrator

National Organic Program

From: Wonnacott Enid [mailto:elila@sover.net]

Sent: Monday, September 22, 2014 8:58 AM

To: McEvoy, Miles - AMS; enid@nofavt.org

Cc: Jean Richardson; Rachel Fussell; nicole dehne

Subject: Re: NOP Discussion at the NOFA-VT Winter Conference

(b) (6) (b) (6)
Great, Miles, Rachel Fussell (attached) is our Winter Conference 

Workshop Coordinator. She will follow up with you to develop a 

description of your workshop, and the scheduling (Saturday or Sunday). 

In addition, please think about if there is anyone you would like to present 

your workshop with – Nicole Dehne? Jean Richardson? Organic farmer?

As for meeting to discuss the NOSB, I coach field hockey in the fall, so 

have to end any meeting by 3pm. Are there any days next week you can 

have a discussion earlier in the day? Thanks, Enid

Enid Wonnacott, Executive Director

Northeast Organic Farming Association of Vermont (NOFA-VT)

PO Box 697

Richmond, VT 05477

(802) 434-4122

(802) 434-4154 (fax)

enid@nofavt.org

www.nofavt.org <http://www.nofavt.org>

On 9/22/14 8:34 AM, "McEvoy, Miles - AMS" 

<Miles.McEvoy@ams.usda.gov> wrote:

Hi Enid,

I like option 1. Looking forward to it.

Are you available for a conference call next week?

Tuesday, the 30th at 4pm?

Miles

Miles McEvoy

Deputy Administrator

National Organic Program

From: Wonnacott Enid [mailto:elila@sover.net]

Sent: Thursday, September 18, 2014 2:05 PM

To: McEvoy, Miles - AMS; enid@nofavt.org

Cc: Jean Richardson; Rachel Fussell; nicole dehne

Subject: NOP Discussion at the NOFA-VT Winter Conference

Dear Miles,

I apologize for my delay in replying to your e-mail. It sounds as if we have 

two things to discuss:
NOSB concerns – it would be great to have a conference call with 

Nicole Dehne, Jean Richardson and myself, if that seems appropriate

 to you. Please suggest another time, as we failed to meet the 9/16 

suggested date.

Our Winter Conference – there are several options. 1) You can speak

 at a workshop session (1 hr 15 min) and then follow that with a 1 hr 

roundtable discussion which would be more of a question and 

answer opportunity. That would be facilitated by Jean Richardson. 

 2) you could do just the workshop, or 3) just the roundtable. Our 

conference is Saturday-Sunday, February 14-15th, and you could speak 

 either Saturday or Sunday.

Please let me know what makes sense for you. Thanks, Enid

Enid Wonnacott, Executive Director

Northeast Organic Farming Association of Vermont (NOFA-VT)

PO Box 697

Richmond, VT 05477

(802) 434-4122

(802) 434-4154 (fax)

enid@nofavt.org

www.nofavt.org <http://www.nofavt.org> <http://www.nofavt.org>

On 9/4/14 12:35 PM, "McEvoy, Miles - AMS" 

<Miles.McEvoy@ams.usda.gov> wrote:

Hi Enid and Dave,

I’d like to set up a time to talk about the National Organic Standards Board 

(NOSB). I understand you may have concerns that I’d like to hear. I’d also like 

to discuss some ideas we have about organic hydroponics. Are you available on 

Tuesday, September 16 at 3 pm eastern time for a conference call?

I’d also like to see if there could be a session at the NOFA-VT winter conference 

to discuss the National Organic Program and NOSB.

Miles McEvoy

Deputy Administrator

National Organic Program

This electronic message contains information generated by the USDA 
solely for the intended recipients. Any unauthorized interception of this 

message or the use or disclosure of the information it contains may violate 

the law and subject the violator to civil or criminal penalties. If you believe 

you have received this message in error, please notify the sender and 

delete the email immediately.

Vilsack hasn't budged. So it's time to move up the governmental food

 chain, to President Obama.

We're joining the Cornucopia Institute in asking consumers to appeal

 to both Vilsack and the President to back off their power grab and 

return to the NOSB its rightful powers and authority. Because 

without a strong, independent NOSB, the integrity of organics is at 

risk.

TAKE ACTION: President Obama: Don't Let the USDA Undermine the Governance and 

Integrity of Organic Food and Agriculture 

[https://petitions.whitehouse.gov/petition/president-obama-dont-let-usda-underminegovernance-and-integrity-organic-food-and-agriculture/9q8kG08S
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: NOP Budget request

Date: Wednesday, July 02, 2014 7:14:26 AM

Hi Miles

I will be in my car at 7.30 but should be able to talk fine

so call me on my cell - 

Jean

On Jul 1, 2014, at 9:05 PM, McEvoy, Miles - AMS wrote:

> How about tomorrow morning - Wednesday. I'm up early though still adjusting from west coast time. How about

 7:30?

> Next week we could talk on Friday at 7:30 as well if that works for you.

>

> Miles V McEvoy

> Deputy Administrator

> USDA National Organic Program

>

>> On Jun 30, 2014, at 9:39 PM, "Jean Richardson" < wrote:

>>

>> Hi Miles

>> I have a livestock inspection on Thursday this week, leaving the house by 6 am so that would not work. And

 inspections scheduled every day next week. But I am available early on Friday July 11. What time works for you.? I

 am normally up by 5.30 or 6 am

>> Hot here this week

>> Jean

>>

>>> On Jun 30, 2014, at 8:00 PM, McEvoy, Miles - AMS wrote:

>>>

>>> Hi Jean

>>> I can call you Thursday morning at the same time. I'll be out on an audit next week so it may be hard for make

 an 8:30 call on the 11th. Could you do it earlier on the 11th?

>>> I'll get back to you on your budget info request.

>>> Nice to be back - great vacation but now lots to catch up with.

>>>

>>> Miles V McEvoy

>>> Deputy Administrator

>>> National Organic Program

>>>

>>> -----Original Message-----

>>> From: Jean Richardson [mailto

>>> Sent: Monday, June 30, 2014 10:03 AM

>>> To: McEvoy, Miles - AMS

>>> Subject: NOP Budget request

>>>

>>> Hi Miles

>>> Welcome back from vacation!

>>> Will you be calling me on Friday July 4 or not till July 11?

>>>

>>> While you were away I asked Jenny to send me the NOP budget, but she e-mailed me a note with a simple

 NOSB narrative budget. So let me try again by requesting from you a print out of a detailed NOP budget, preferably

 in the format of comparison with last years budget and future projections.

>>> I am trying to get a detailed understanding of NOP budget constraints as well as impact of Farm Bill.

(b) (6) (b) (6) (b) (6)
>>>

>>> Many thanks,

>>> Jean

>>>

>>>

>>>

>>>

>>>

>>> This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

>>
From: Jean Richardson

To: Tucker, Jennifer - AMS

Cc: McEvoy, Miles - AMS

Subject: Re: NOP Budget

Date: Thursday, July 10, 2014 1:32:43 AM

Hi Jenny and Miles

If my mum was still around she would say "Oh just give Jean what she is requesting because it will be much easier

 in the long run! She will just keep asking till she gets what she wants".

I chatted with Miles as to why I need the NOP and NOSB budgets for 2013, 2014 and projections, but I am not

 making progress with getting the printout data. Obviously I need to articulate my request more clearly, so I will

 write a more formal e-mail to Miles tomorrow.

Just a gentle reminder of the public nature of these tax dollars at work, regardless of "agency practice". If I cannot

 get the printout of data from my friends at the NOP, I will simply try another path.

Thank you

Best regards from Vermont

Jean

On Jul 7, 2014, at 12:25 PM, Tucker, Jennifer - AMS wrote:

> Hi Jean - My apologies for the delay in response on this..... I am assuming that your request relates to upcoming

 needs related to Technical Reports? We have set aside a solid pot of funds for these reports, and I am in close

 communication with Lisa Brines and Emily about the subcommittee prioritization efforts in this area - I am

 confident that we will be able to fund a good number of reports to support the Board's work over the coming

 months. If there are other needs that you would like to discuss, we are happy to take those into consideration as

 well.

> It is agency practice not to release program-level budget breakdowns, as decisions related to budget needs are

 made internally both the program and agency, and are all part of an overarching appropriation for AMS Marketing

 Services.

> Thanks -

> Jenny

>

> -----Original Message-----

> From: Jean Richardson [mailto

> Sent: Thursday, June 26, 2014 12:47 PM

> To: Tucker, Jennifer - AMS

> Subject: Re: NOP Budget

>

> Hi Jenny

> Thank you, but can you give me the rough NOP budget breakdown Thank you Jean

>

> On Jun 26, 2014, at 11:54 AM, Tucker, Jennifer - AMS wrote:

>

>> Hello Jean - I hope you are well! USDA has allocated $190,000 for NOSB operations - that allocation comes

 out of the overall NOP budget. The $190,000 ceiling is set by USDA based on total allowed funding across all

 USDA Committees. Approximately $100,000 of that goes to Michelle's salary, overhead, and benefits;

 approximately $40,000 goes to contracts to support NOSB meetings and materials (facilities, A/V, supplies, etc),

 and approximately $50,000 goes to Board travel - those have been consistent levels over the past 3 years, with

 slight variability depending on where the meetings are. The technical support that NOP provides the Board comes

 from our general NOP budget, including the labor time for technical staff, the costs of transcripts, and the technical

 reports.

>>

>> Best -

(b) (6)
>> Jenny

>>

>> ---------------------------------------

>> Jennifer Tucker, Ph.D.

>> Associate Deputy Administrator

>> USDA National Organic Program

>> 1400 Independence Ave SW; Room 2642 (Stop 0268) Washington, DC

>> 20250-0268

>> Phone: (202) 720-3252

>> Jennifer.Tucker@ams.usda.gov

>>

>>

>> -----Original Message-----

>> From: Jean Richardson [mailto:

>> Sent: Thursday, June 26, 2014 10:58 AM

>> To: Tucker, Jennifer - AMS

>> Subject: NOP Budget

>>

>> Hi Jenny

>> Could you send to me the most recent NOP budget, with breakdown so that I can assess our NOSB needs.

>> Thank you

>> Cheers

>> Jean

>>

>>

>>

>>

>> This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

>

(b) (6)
From: Jean Richardson

To: Colehour Bondera

Cc: Tracy Favre; Stone, Mac (AGR); Jennifer Taylor; Brown Rosen, Emily - AMS; McEvoy, Miles - AMS; Arsenault,

 Michelle - AMS; harolda@zirklefruit.com; Tucker, Jennifer - AMS

Subject: Re: Non live NOSB public meeting participation

Date: Monday, July 20, 2015 7:08:53 AM

Colehour

Could you clarify please.

Do you object to Harold attending the October meeting by virtual presence?- just a yes or no!

Thank you

Jean

Sent from my iPhone

On Jul 20, 2015, at 1:47 AM, Colehour Bondera < wrote:

Aloha again PDS,

This message is about the “decision” to permit electronic phone, rather than live participation/voting of an NOSB

 member in a public meeting. My concerns were raised, to the degree permitted, at the La Jolla meeting. But it

 appears that the intent of the ES and the NOP is to continue forth with the same conclusion, without full

 consideration.

So I reached out last week (after checking with Jean) to former NOSB members Kevin Englebert, and his reply tells

 me that NOP told him that they were unwilling to pay for non-air transportation to a 2010 NOSB meeting in CA,

 and when asked if he could participate/vote via electronic phone communication, was told that it would not be

 permitted. This is sad because it confirmed my understanding that in the past it has NOT been permitted when

 requested to participate in a public NOSB meeting via electronic (phone) connection instead of live.

While this subject was brought to the ES (and I am happy to forward this to that list [sorry that I just got a changed

 computer yesterday and am slow to locate things...]), it is my request that this history be directly acknowledged and

 dealt with and addressed, since this(Kevin) is the only recent example that I am aware of...if an error in judgement

 was made with Kevin; that must be so stated, and so accommodated in a public manner.

Coming up with a new policy because a present member cannot (or should not) fly is not something that should be

 done randomly, but rather with an agreement and policy that can and will be followed in the future, rather than

 individual personalities and opinions, since that is not how to set policies.

Again, it is my request that this determination (that somehow an NOSB member, Harold, can participate via a

 phone/electronic connection in our Vermont meeting) be seriously and completely reviewed and considered again,

 since it was told to Kevin that it was NOT an option to so participate (Skype and other programs are the same as a

 phone connection, and we cannot use that minor communication difference as why one would be refused and

 another would be accepted) then it would appear that there is legal precedent already in place, and a shift must have

 a policy change to enact (according to my understanding of not simply Roberts’ Rules, but more-so of FACA).

Perhaps we (NOSB or NOP) could act super fast and put a policy in some record to be followed, but at this time

 there is in no place that I am aware (like I raised at the La Jolla meeting as a Point of Order) which states that such

 an option can be allowed. The precedent in place shows that it is not permitted. While I do not hold a JD, and have

 not consulted with a lawyer, it is important that the NOP is sure that the precedent set in 2010 is reviewed by legal

 advisors in terms of action which do not have any other history to work from...

Thank you for your attention and consideration.

Sincerely,

(b) (6)
Colehour
From: Jean Richardson

To: Colehour Bondera

Cc: Tracy Favre; Stone, Mac (AGR); Jennifer Taylor; Brown Rosen, Emily - AMS; McEvoy, Miles - AMS; Arsenault,

 Michelle - AMS; Austin Harold; Tucker, Jennifer - AMS

Subject: Re: Non live NOSB public meeting participation

Date: Tuesday, July 21, 2015 9:38:16 AM

Hi Colehour

My preference is always to move to solution of a problem as quickly as possible.

So can you come up with a policy we can vote on right away, July 28, in PDS?

Such as : " In cases of a medical situation preventing attendance in person, a virtual presence is permitted"

We can vote at next meeting and take it to Board? But we need to plan for the meeting too, and Harold has worked

 much harder than many NOSB members and he deserves our support.

How do you feel about this suggestion.

Jean

On Jul 21, 2015, at 12:34 AM, Colehour Bondera wrote:

> Thank you for your thoughts.

>

> Yes, Jean, my opinion is that it is NOT ok to have someone participate in a NOSB public meeting except in

 person, unless there is a policy (in some by-laws somewhere) which permits.

>

> As FACA tells us, a by-law can permit such an option, and so we (the NOSB) take responsibility.

>

> Since I called a point of order in La Jolla because action was being taken with no agreement in place (and none

 was cited in any of the replies at the meeting) so permitting, there has been plenty of time to take this on, and it

 seems that no one else sees this as time sensitive or important to put some kind of "flexible policy" in place.

>

> We all agree to follow the same policies, and none in place means that any can be created by whoever so

 needs/desires and that is not appropriate (perhaps verges on arbitrary).

>

> We cannot and should not ignore decisions made in the past and a decision made regarding a similar request

 should be addressed and not administratively dismissed as not relevant. I see the Kevin example as quite relevant,

 and in fact virtually identical.

>

> Happy to discuss on PDS, but I also believe that the NOP should be sure that they are not allowing actions that

 have no policy in place to follow. We must have policies that apply across the board (and yes the whole of the

 NOSB) and across time, and it is not clear to me what is being followed or members are being held to in terms of

 electronic participation being declared equivalent to live with no discussion or consideration by the public we claim

 to be representing but are not allowing to participate.

>

> Talk soon,

>

> Colehour

>

>> On Jul 20, 2015, at 6:17 AM, Tracy Favre <tfavre@favrehouse.com> wrote:

>>

>> Colehour,

>> I agree that a conversation should take place about how to craft the policy, but I disagree with your comment

 about “legal precedent” being set.

>>

>> Policies are just that, policies and do not really have the same weight of law as something like legislation. The

 distinction is one that I think is important, as policies should allow for flexibility to changing circumstances and
 technologies.

>>

>> IMO, the ability to participate via Skype is NOT the same as participating via phone call. Skype allows for

 video communication and as such is much more akin to physical presence during a meeting. Regardless, I think it’s

 ridiculous to disallow a member to participate because of the inability to be physically present. Whether or not that

 was a reasonable decision at the time of Kevin’s tenure on the board is not the point...

>>

>> As has been pointed out MULTIPLE TIMES, other FACA committees allow for remote participation at a

 meeting... so clearly there is conflicting “precedent” regarding the allowance for this at a FACA board meeting.

>>

>> Let’s make sure we have a robust conversation about this on a PDS call so that we can discuss it to everyone’s

 contentment.

>> T

>>

>>

>>

>>> On Jul 20, 2015, at 12:47 AM, Colehour Bondera < wrote:

>>>

>>> Aloha again PDS,

>>>

>>> This message is about the “decision” to permit electronic phone, rather than live participation/voting of an

 NOSB member in a public meeting. My concerns were raised, to the degree permitted, at the La Jolla meeting. But

 it appears that the intent of the ES and the NOP is to continue forth with the same conclusion, without full

 consideration.

>>>

>>> So I reached out last week (after checking with Jean) to former NOSB members Kevin Englebert, and his reply

 tells me that NOP told him that they were unwilling to pay for non-air transportation to a 2010 NOSB meeting in

 CA, and when asked if he could participate/vote via electronic phone communication, was told that it would not be

 permitted. This is sad because it confirmed my understanding that in the past it has NOT been permitted when

 requested to participate in a public NOSB meeting via electronic (phone) connection instead of live.

>>>

>>> While this subject was brought to the ES (and I am happy to forward this to that list [sorry that I just got a

 changed computer yesterday and am slow to locate things...]), it is my request that this history be directly

 acknowledged and dealt with and addressed, since this(Kevin) is the only recent example that I am aware of...if an

 error in judgement was made with Kevin; that must be so stated, and so accommodated in a public manner.

>>>

>>> Coming up with a new policy because a present member cannot (or should not) fly is not something that should

 be done randomly, but rather with an agreement and policy that can and will be followed in the future, rather than

 individual personalities and opinions, since that is not how to set policies.

>>>

>>> Again, it is my request that this determination (that somehow an NOSB member, Harold, can participate via a

 phone/electronic connection in our Vermont meeting) be seriously and completely reviewed and considered again,

 since it was told to Kevin that it was NOT an option to so participate (Skype and other programs are the same as a

 phone connection, and we cannot use that minor communication difference as why one would be refused and

 another would be accepted) then it would appear that there is legal precedent already in place, and a shift must have

 a policy change to enact (according to my understanding of not simply Roberts’ Rules, but more-so of FACA).

>>>

>>> Perhaps we (NOSB or NOP) could act super fast and put a policy in some record to be followed, but at this

 time there is in no place that I am aware (like I raised at the La Jolla meeting as a Point of Order) which states that

 such an option can be allowed. The precedent in place shows that it is not permitted. While I do not hold a JD, and

 have not consulted with a lawyer, it is important that the NOP is sure that the precedent set in 2010 is reviewed by

 legal advisors in terms of action which do not have any other history to work from...

>>>

>>> Thank you for your attention and consideration.

>>>

>>> Sincerely,

>>>

(b) (6)
>>> Colehour

>>

>
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Nominations for next batch of NOSB

Date: Friday, March 13, 2015 2:30:51 PM

Hi Miles

I have been thinking a lot about future Board members.

Qualities which seem vital based on my experience over the last 3 years:

* Highly intelligent, Quick learner;

* Demonstrated bility to clearly articulate issues in writing and verbally.

* Good knowledge of Chemistry - which is our primary materials work, (Knowing how to ask the right questions!)

* Very knowledgeable in at least 3 of the following: organic certificaction, processing/handling, livestock, crops,

 inspections.

 Board members should be encouraged to take part in inspections so as to be able to understand the implications

 of Board recommendations on organics.

* Every group brought on must include at least 2 and preferably 3 people who could be potential NOSB Chair, Vice

 Chair -

* Ability and desire to work with others, team player, not a knight in shining armor ! 

* Every person must be able to articulate trust in the NOP/USDA, and manage their biases professionally.

OK, all for now,

Jean
From: McEvoy, Miles - AMS

To: "Jean Richardson"; "Rachel Fussell"

Subject: RE: NOFA-VT Winter Conference Roundtable

Date: Tuesday, January 20, 2015 8:56:49 AM

Jean – that description looks fine, thanks.

Miles

Miles McEvoy

Deputy Administrator

National Organic Program

From: Jean Richardson [mailto:

Sent: Monday, January 19, 2015 4:18 PM

To: Rachel Fussell

Cc: McEvoy, Miles - AMS

Subject: Re: NOFA-VT Winter Conference Roundtable

How about:

Miles McEvoy, NOP Deputy Administrator and Dr Jean Richardson, Chair, National Organic

Standards Board and Organic Inspector, will convene a round table discussion on organic

production of crops, livestock and processed organic foods. Come with your concerns and

questions. 

Miles, what do you think?

Jean

On Jan 19, 2015, at 3:39 PM, Rachel Fussell wrote:

Hello Miles and Jean,

Hope you are both doing well on this Monday afternoon.

I wanted to email you because I realized that I do not have a description for the roundtable

 discussion to be held on Saturday, Feb. 14 from 1:00pm to 2:00pm. Could you please send me a

 description on what topics and conversations you hope to have with the roundtable participants. It

 only needs to be few sentences long.

Thank you for your help in this matter.

Sincerely,

Rachel Fussell

Rachel Fussell

Education Coordinator

Northeast Organic Farming Association of Vermont

PO Box 697, Richmond, VT 05477

(b) (6)
802-434-4122 x28

rachel@nofavt.org

This electronic message contains information generated by the USDA solely for the intended

recipients. Any unauthorized interception of this message or the use or disclosure of the

information it contains may violate the law and subject the violator to civil or criminal

penalties. If you believe you have received this message in error, please notify the sender and

delete the email immediately.
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: NOFA-VT Winter Conference

Date: Monday, October 20, 2014 5:08:13 PM

I am not clear on time frames or sessions here. I thought Saturday there would be an hour 

long workshop followed by a "Listening Session" type informal round table, not a "panel" at 

all and that I am to moderate both of these and provide some comments with Miles at the 

Workshop from the volunteer NOSB perspective. I am not sure who Grace is?

Jean

On Oct 20, 2014, at 4:52 PM, McEvoy, Miles - AMS wrote:

There are two sessions, correct?

The first is a general session on organic agriculture at USDA, USDA organic standards, 

organic hydroponics, National Organic Standards Board, and the revised sunset 

process.

The second session is more of a discussion with Jean Richardson. It seems that Grace 

may be a good addition to the second session. Jean – what do you think of having 

Grace join our discussion panel?

Miles McEvoy

Deputy Administrator

National Organic Program

From: Rachel Fussell [mailto:Rachel@nofavt.org]

Sent: Friday, October 17, 2014 11:46 AM

To: McEvoy, Miles - AMS

Subject: NOFA-VT Winter Conference

Hello Miles and Happy Friday,

I just spoke with Grace Gershuny who was very interested in joining your 

workshop presentation as a panelist. She believes that she would offer a lot of 

historical insight and context, which she believes would be very beneficial to your

 audience. What is your opinion on this collaboration and would this be beneficial

 for your presentation?

Thanks for your help,

Rachel

Education Coordinator

NOFA-VT
This electronic message contains information generated by the USDA 

solely for the intended recipients. Any unauthorized interception of 

this message or the use or disclosure of the information it contains 

may violate the law and subject the violator to civil or criminal 

penalties. If you believe you have received this message in error, 

please notify the sender and delete the email immediately.
From: McEvoy, Miles - AMS

To: Rachel Fussell

Cc: Jean Richardson (

Subject: Re: NOFA-VT Winter Conference

Date: Wednesday, October 22, 2014 7:56:30 PM

Better to keep it as Jean and me for the roundtable. Thanks.

Miles V McEvoy

Deputy Administrator

USDA National Organic Program

On Oct 22, 2014, at 1:21 PM, "Rachel Fussell" <Rachel@nofavt.org> wrote:

Hello Miles,

Thanks for considering Grace for the Roundtable. I think this would be a great

 idea.

I have you scheduled for two events, one being a workshop on said topics, and the

 other will be an hour long roundtable.

Let me know what Jean and you think of adding Grace to the round table.

Thanks so much

Rachel

On Oct 20, 2014, at 4:52 PM, McEvoy, Miles - AMS

 <Miles.McEvoy@ams.usda.gov> wrote:

There are two sessions, correct?

The first is a general session on organic agriculture at USDA, USDA organic

 standards, organic hydroponics, National Organic Standards Board, and

 the revised sunset process.

The second session is more of a discussion with Jean Richardson. It seems

 that Grace may be a good addition to the second session. Jean – what do

 you think of having Grace join our discussion panel?

Miles McEvoy

Deputy Administrator

National Organic Program

From: Rachel Fussell [mailto:Rachel@nofavt.org]

Sent: Friday, October 17, 2014 11:46 AM

To: McEvoy, Miles - AMS

Subject: NOFA-VT Winter Conference

(b) (6)
Hello Miles and Happy Friday,

I just spoke with Grace Gershuny who was very interested in joining

 your workshop presentation as a panelist. She believes that she

 would offer a lot of historical insight and context, which she believes

 would be very beneficial to your audience. What is your opinion on

 this collaboration and would this be beneficial for your

 presentation?

Thanks for your help,

Rachel

Education Coordinator

NOFA-VT

This electronic message contains information generated by the USDA solely for the

 intended recipients. Any unauthorized interception of this message or the use or

 disclosure of the information it contains may violate the law and subject the violator

 to civil or criminal penalties. If you believe you have received this message in error,

 please notify the sender and delete the email immediately.

From: McEvoy, Miles - AMS

To: Jean Richardson

Cc: "Nicole Dehne"

Subject: RE: NOFA Winter Conference

Date: Wednesday, January 21, 2015 8:34:38 PM

Yes, I will have slides

From: Jean Richardson [mailto:

Sent: Wednesday, January 21, 2015 10:11 AM

To: McEvoy, Miles - AMS

Cc: 'Nicole Dehne'

Subject: Re: NOFA Winter Conference

That sounds perfect. I will explain how the NOSB works and how the public can be involved

in the mix of NOP/NOSB/Certifier etc.

Miles will you bring a few slides on a thumb drive for power point?

Jean

On Jan 21, 2015, at 10:06 AM, McEvoy, Miles - AMS wrote:

During the workshop we could each explain the role and projects for NOP, NOSB and NOFA-VT. We

 could each include information about upcoming projects (e.g. sound and sensible, transitional

 certification, NOSB topics, organic hydroponics). We should leave time for some Q&A.

The roundtable could be more of a conversation and discussion. We could start with some back and

 forth between us as certifier (Nicole), accreditor (Miles), advisory board (Jean), scheme owner

 (Miles with advice from NOSB), enforcer (NOP, Nicole as certifier, Jean as inspector). We could then

 open it up with questions/comments from participants.

Miles

From: Nicole Dehne [mailto:nicole@nofavt.org]

Sent: Wednesday, January 21, 2015 9:40 AM

To: McEvoy, Miles - AMS; 'Jean Richardson'

Subject: RE: NOFA Winter Conference

Well let me just be super clear.

Saturday at 10:45-12:00 we have a workshop entitled "USDA National Organic Program: What

 Does the Future Hold?" This is typically more of a presentation with questions and discussion of

 course.

Then from 1-2 there is the round table discussion entitled "National Organic Program Discussion

 with Miles McEvoy, NOP Administrator". This is typically a discussion about hot topics. I believe

 Jean is moderating this discussion.

I think we can explain what the NOP, NOSB and certifiers do but the title is also “What does the

 future hold?”. Not sure how we want to incorporate that theme exactly. Obviously the sound

 and sensible initiative will be of interest to folks as well as the future of Chilean Nitrate,

 Biodegradable Mulch (I know it is out of the hands of the NOP at the moment but I wouldn’t be

(b) (6)
 surprised if people ask questions about its use), Origin of Livestock, etc.

Thoughts?

-Nicole

Nicole Dehne

Certification Administrator

Vermont Organic Farmers LLC

P.O. Box 697

Richmond, VT 05477

www.nofavt.org

802-434-3821

802-434-4154 (fax)

-----Original Message-----

From: McEvoy, Miles - AMS [mailto:Miles.McEvoy@ams.usda.gov]

Sent: Tuesday, January 20, 2015 2:33 PM

To: Nicole Dehne; 'Jean Richardson'

Subject: RE: NOFA Winter Conference

If we only have and hour and fifteen minutes I think we should keep the opening remarks short -

 say 5-10 minutes each. That will provide more time for questions and discussion.

Thanks and looking forward to this!

Miles

-----Original Message-----

From: Nicole Dehne [mailto:nicole@nofavt.org]

Sent: Tuesday, January 20, 2015 11:25 AM

To: Jean Richardson; McEvoy, Miles - AMS

Subject: RE: NOFA Winter Conference

Sounds good all. The workshops are an hour and fifteen minutes-fairly short if you leave time for

 questions. I can do as much or as little as you all want. I think however that the audience is

 going to want to hear from Miles and Jean. At this point, I can just prepare a 10-15 minute

 powerpoint/presentation about the role of the certifier. If that cuts into Miles presentation

 however, I would almost rather let him do his thing and I can be there to answer questions. Let

 me know.

Thanks all!

-Nicole

Nicole Dehne

Certification Administrator

Vermont Organic Farmers LLC

P.O. Box 697
Richmond, VT 05477

www.nofavt.org

802-434-3821

802-434-4154 (fax)

-----Original Message-----

From: Jean Richardson [mailto

Sent: Saturday, January 17, 2015 8:08 AM

To: Nicole Dehne; Miles - AMS McEvoy

Subject: NOFA Winter Conference

Hi Nicole and Miles

In looking at our NOFA Winter Conference slot I note that we have one presentation at 10.45 till

 noon on Saturday Feb 14 (Sarah's Birthday!).

I am assuming we will then do a roundtable but I do not see where those are listed. I will ask the

 coordinator.

Miles -, you could do the same fairly short presentation that you did at NODPA essentially and I

 will do mine the same too, just explaining what NOSB does. Nicole can follow by a simple

 explanation of what the certifier organization does. Then we take questions, and if there are not

 many questions we can ask each other questions!

I am happy to moderate the session.

Cheers

Jean

This electronic message contains information generated by the USDA solely for the intended

 recipients. Any unauthorized interception of this message or the use or disclosure of the

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 If you believe you have received this message in error, please notify the sender and delete the

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(b) (6)
From: McEvoy, Miles - AMS

To: Sarah Flack; jean

Subject: RE: NOFA Meeting

Date: Wednesday, February 11, 2015 8:12:30 AM

Hi Sara,

Yes, it sounds like it is going to be super cold. I'm don't think I'm ready for that. I brought some warm clothes but

 I'm not prepared for the single digits or colder. I'm in Arkansas now and fly directly from here to Vermont - so I

 don't have time to pick up warmer clothes at home in DC.

I think given the forecast that we should skip the ski outing. I really appreciate all of the work you've done to set this

 up but the frigid temperatures don't seem conducive to the trip.

Also, not going skiing will provide more time to spend at the NOFA conference.

Sorry for any inconvenience, thanks again for setting this up, look forward to seeing you.

Miles

-----Original Message-----

From: Sarah Flack [mailto

Sent: Tuesday, February 10, 2015 9:26 PM

To: jean

Cc: McEvoy, Miles - AMS

Subject: Re: NOFA Meeting

Hello Miles

The good news it that the snow conditions here in Vermont are great. The bad news is that the weather for this

 weekend is going to be chilly!

The high temperature on Saturday is only 6 degrees! And if we decide to go up to Bolton to ski it will be colder up

 there...

We have boots and skis and poles for you to borrow. If it is windy I have an extra pair of goggles.

If the cold doesn't seem too daunting, then be sure to bring layers and let me know if there is any other gear we

 should organize for you?

Sarah

On Feb 10, 2015, at 5:50 PM, Jean Richardson < wrote:

> Hi Miles

> This is to introduce you to my daughter, Sarah Flack, who will be facilitating your X country ski this weekend

 after your presentations on Saturday Feb 14 and before your dinner meeting.

> She has some suggestions and questions.

> Thank you

> Jean

Sarah Flack

(b) (6) (b) (6) (b) (6)
This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: RE: NODPA -video Lisa McCrory

Date: Thursday, September 18, 2014 7:34:39 AM

Really nice. Thanks for sharing.

Miles V McEvoy

Deputy Administrator

National Organic Program

From: Jean Richardson [mailto:

Sent: Sunday, September 14, 2014 12:35 PM

To: McEvoy, Miles - AMS

Subject: NODPA -video Lisa McCrory

Hi Miles

Lisa McCrory has a certified OG farm, did her Masters on pasture rotation as part of my EPIC

Kellogg Grant in the 90's, works with NODPA and will be at the NODPA conferecne.

Thought you might enjoy this educational video on tracking organic pastures.

Best

Jean

http://youtu.be/m7XzJgPCs2A

This electronic message contains information generated by the USDA solely for the intended

recipients. Any unauthorized interception of this message or the use or disclosure of the

information it contains may violate the law and subject the violator to civil or criminal

penalties. If you believe you have received this message in error, please notify the sender and

delete the email immediately.

(b) (6)
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Re: NODPA News

Date: Monday, June 09, 2014 9:03:44 AM

Yes - though I'll be on vacation from the 18th to the 29th.

Miles V McEvoy

Deputy Administrator

USDA National Organic Program

> On Jun 9, 2014, at 9:02 AM, "Jean Richardson" < wrote:

>

> OK

> I have some ideas how I might work on these PR related issues.

> Are we scheduled to chat every Friday at 8.30 ?

>

>> On Jun 9, 2014, at 8:34 AM, McEvoy, Miles - AMS wrote:

>>

>> Yes, also page 2 - President Liz Bawden's message.

>>

>> -----Original Message-----

>> From: Jean Richardson [mailto:

>> Sent: Sunday, June 08, 2014 4:40 PM

>> To: McEvoy, Miles - AMS

>> Subject: NODPA News

>>

>> Miles

>> I looked at the May - June NODPA News . Is it the Maltby article on p 3?

>> Jean

>>

>> Sent from my iPhone

>>

>>

>>

>>

>> This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

>

(b) (6) (b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: NODPA News

Date: Tuesday, December 16, 2014 7:11:31 AM

Hi Miles

NODPA News for November includes my opening comments from the Kentucky meeting, and they want an NOSB

 update for the January edition (deadline Dec 22). I am drafting it today. I thought I would add a few notes about

 your recent work in a "so what is the Deputy Administrator up doing and what has he accomplished recently?" ! so

 how about sending me a few bullet type notes to brag about your recent accomplishments! International or

 whatever. I can brag for you. I will, of course, send you the short article before I send it on to NODPA.

Cheers

Jean
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: NODPA News

Date: Tuesday, December 16, 2014 7:15:19 PM

Great

I will work on this Thursday

Jean

Sent from my iPad

> On Dec 16, 2014, at 6:31 PM, "McEvoy, Miles - AMS" <Miles.McEvoy@ams.usda.gov> wrote:

>

> Thanks so much

> Sorry the day got away from me. See if this is useful -

> Attached is a rather long list that you may be able to pull from. Also some USDA organic accomplishments

 below.

>

> Best,

> Miles

>

> Organic Agriculture

> October 2012 marked the 10th anniversary of the USDA organic seal, which has become a leading global

 standard. In the United States, there are now 18,513 certified USDA organic operations, representing nearly a 245%

 increase since 2002. In 2013 alone, USDA helped an additional 763 producers and handlers become certified

 organic, an increase of 4.2%. Worldwide, there are over 25,000 certified organic operations in more than 120

 different countries.

>

> Growing Markets for Organic Products

> * As of 2013, organic products are a $35 billion industry in the United States.

>

> * USDA continues to expand markets for American organic products abroad. We work aggressively to break

 down barriers to trade and assist U.S. farmers and businesses with the resources needed to reach consumers in a

 global marketplace.

>

> * Equivalence arrangements are important for small and mid-sized operations that want to export products but

 cannot afford the time and money necessary for duplicative certifications, fees, and inspections. They allow organic

 products certified in one country to be sold as organic in each respective market.

>

> o In 2009, USDA signed an organic equivalence arrangement with Canada. The United States exports close to

 $2 billion in organic products to Canada each year.

>

> o In February 2012, we established a similar equivalence arrangement with the European Union, the second

 largest organic market in the world after the United States. In 2012, the United States exported organic products

 worth approximately $73 million to the European Union.

>

> o In January 2014, we implemented the U.S. - Japan organic equivalency arrangement, opening up an

 emerging Asian organic market for U.S. farmers and processors. U.S. organic exports to Japan are currently

 estimated at $80 million, with growth due to the arrangement expected to reach at least $250 million in 10 years.

>

> * To make sure consumers can trust the organic seal, in fiscal year 2013 USDA completed 260 complaint

 investigations and issued 18 civil penalties for willful violations of National Organic Program regulations.

>

> * To keep mislabeled products out of the marketplace, USDA launched a new way to notify buyers when

 fraudulent organic certificates are identified. USDA also regularly conducts surveillance audits of certifiers and
 operations certified in foreign countries. In 2014, NOP will conduct foreign audits of certifiers in Mexico, Taiwan,

 South Korea, Australia, Turkey, France, England, Peru, Argentina, and Bolivia.

>

> Strengthening Support for Organic Producers

>

> * To make organic certification accessible, attainable, and affordable for all operations, USDA has

 implemented a 'Sound and Sensible' approach to organic certification, which includes identifying and removing

 barriers to certification, streamlining the certification process, focusing enforcement, and working with farmers and

 processors to correct small issues before they become larger ones. USDA has also established an online "one-stopshop" to help producers access information on organic programs and opportunities, including:

>

> o Reimbursements for up to 75% of the costs of organic certification. In 2012, USDA issued 9,593

 reimbursements to assist organic producers and handlers, for a total of over $6.5 million.

>

> o Market and pricing information free of charge for approximately 250 organic products through USDA's

 Market News. USDA plans to expand its offerings in the future.

>

> o Financial and technical conservation assistance to farmers to help address certain natural resource concerns

 in their existing organic systems and to help producers transitioning to organic crop and livestock production. Since

 2009, more than 6,000 farms have benefitted from $106 million in assistance through the Environmental Quality

 Incentives Program Organic Initiative.

>

> * USDA has also taken steps to provide effective insurance coverage for organic crops and better risk

 management tools for organic producers.

>

> o In 2011, for the first time ever, USDA began offering crop insurance for organic producers that reflects

 organic pricing of cotton, corn, soybeans, and processing tomatoes.

>

> o In 2014, USDA eliminated the historical 5% surcharge on organic policy premiums for all crops, added

 more crops with organic prices for losses, and added a contract pricing option.

>

> o A new Whole-Farm Revenue protection policy, recently approved by the Federal Crop Insurance

 Corporation Board of Directors, will be available as a pilot program in 2015. This policy option is designed to meet

 the needs of specialty crop growers and producers with highly diversified farms, including organic producers.

>

> * Since 2009, USDA has supported internal and university researchers with nearly $160 million in funding for

 research focused on improving the productivity and success of organic agriculture, including a number of

 successful seed-breeding projects.

>

> * In September 2012, USDA launched the Organic Literacy Initiative, a training and outreach program to help

 USDA employees better understand and serve organic operators. By spring of 2014, over 30,000 USDA employees

 had taken the "Organic 101" course and over 8,000 had taken the "201" course.

>

> -----Original Message-----

> From: Jean Richardson [mailto

> Sent: Tuesday, December 16, 2014 7:11 AM

> To: McEvoy, Miles - AMS

> Subject: NODPA News

>

> Hi Miles

> NODPA News for November includes my opening comments from the Kentucky meeting, and they want an

 NOSB update for the January edition (deadline Dec 22). I am drafting it today. I thought I would add a few notes

 about your recent work in a "so what is the Deputy Administrator up doing and what has he accomplished

 recently?" ! so how about sending me a few bullet type notes to brag about your recent accomplishments!

 International or whatever. I can brag for you. I will, of course, send you the short article before I send it on to

 NODPA.

> Cheers

(b) (6)
> Jean

>

>

>

>

> This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

> <2014 accomplishments.docx>
From: McEvoy, Miles - AMS

To: Arsenault, Michelle - AMS; Barry Flam; Carmela Beck (carmela.beck@driscolls.com); Colehour Bondera

 (colemel@efn.org); Harold Austin; Jay Feldman; Jean Richardson ( Jennifer

 Taylor ( JFoster@ebfarm.com; joe.dickson@wholefoods.com; Nicholas Maravell

 ( Robert Mac Stone (mac@elmwoodstockfarm.com); Rueben Walker

 ( Tracy Favre (tfavre@favrehouse.com); wendy.fulwider@organicvalley.com; Zea

 Sonnabend (zea@well.com)

Cc: Coke, Lorraine - AMS; Bailey, Melissa - AMS; Brines, Lisa - AMS; Tucker, Jennifer - AMS; Brown Rosen, Emily -

 AMS

Subject: NOP response to Savannah NOSB mtg

Date: Wednesday, March 21, 2012 6:25:51 PM

Attachments: NOP Resp to NOSB Dec 2011 Recs-final.pdf

image001.png

Attached is the NOP’s response to the Savannah NOSB meeting recommendations. The response

 will be posted on the NOP website tomorrow.

Thank you for all of your work. Looking forward to our meeting in Albuquerque.

Miles V. McEvoy

Deputy Administrator

National Organic Program

U.S. Department of Agriculture

Room 2646-So. (Stop 0268)

1400 Independence Ave SW

Washington, DC 20250-0268

202-720-3252

www.ams.usda.gov/nop

Organic Integrity from Farm to Table, Consumers Trust the Organic Label

Register for the NOP Organic Insider, the National Organic Program’s email notification service, by

 visiting http://bit.ly/NOPOrganicInsiderRegistration.

(b) (6) (b) (6) (b) (6) (b) (6)
From: Jean Richardson

To: Arsenault, Michelle - AMS

Cc: McEvoy, Miles - AMS

Subject: Re: NOSB Group photo

Date: Thursday, November 13, 2014 10:28:21 AM

Thank you!

Sent from my iPhone

> On Nov 13, 2014, at 10:01 AM, "Arsenault, Michelle - AMS" <Michelle.Arsenault@ams.usda.gov> wrote:

>

> Hi Jean,

> I know! I've been trying to do that for years! Who wants a picture when everyone is tired and racing off to catch a

 plane!?

> I will make it an official part of the agenda from now on.

>

> Thanks,

> Michelle

>

> -----Original Message-----

> From: Jean Richardson [mailto

> Sent: Thursday, November 13, 2014 9:37 AM

> To: Arsenault, Michelle - AMS

> Cc: McEvoy, Miles - AMS

> Subject: NOSB Group photo

>

> Hi Michelle

> As we plan for next NOSB meeting let's add in a time immediately BEFORE the meeting starts to get a good

 group photo. These scrambling at the end of the week photos are not great for many reasons.

> I will also mark it on my draft agenda to remind me.

> Thanks Jean

>

>

>

>

> This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

(b) (6)
From: McEvoy, Miles - AMS

To: "Karen Archipley (karen@archisacres.com)"; "Colin Archipley"

Cc: Arsenault, Michelle - AMS; "Jean Richardson"

Subject: NOSB field trip

Date: Monday, March 02, 2015 12:44:02 PM

Hi Karen and Colin,

The spring NOSB meeting is scheduled for April 27-30, 2015 in La Jolla, California. The NOSB will be

 reviewing hydroponic and aquaponic operations over the next year and we’d like to get them out on

 field trips to visit these type of operations. Would it be possible for the NOSB members to come by

 Archi’s Acres to see your operation on Sunday, April 26? They have to be back in La Jolla for a late

 afternoon meeting.

I’ve copied Michelle Arsenault, NOSB Advisory Board Specialist, and Jean Richardson, NOSB chair.

 Michelle will be making the travel arrangements if this works out.

Thanks and Best regards!

Miles McEvoy

Deputy Administrator

National Organic Program

This electronic message contains information generated by the USDA solely for the intended

 recipients. Any unauthorized interception of this message or the use or disclosure of the

 information it contains may violate the law and subject the violator to civil or criminal

 penalties. If you believe you have received this message in error, please notify the sender and

 delete the email immediately.
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: NOSB February DC dates

Date: Monday, December 29, 2014 10:30:45 AM

Thank you

On Dec 29, 2014, at 10:22 AM, McEvoy, Miles - AMS wrote:

> Happy December 29,

> I'd suggest coming in Tuesday morning for meetings on Tuesday afternoon. Leaving later on Friday provides you

 with flexibility for additional meetings. We can also fit in meetings on Wednesday and Thursday if necessary.

>

> Cheers and best to you and your family,

>

> Miles V McEvoy

> Deputy Administrator

> USDA National Organic Program

>

>> On Dec 26, 2014, at 6:16 AM, "Jean Richardson" < wrote:

>>

>> Hi Miles

>> The new member training is Wednesday and Thursday (Feb 4 and 5). I should make plane bookings and reserve

 Monday at hotel.

>> You mentioned that you would like me to meet with some one in the Secretary's office? Others? - and I plan on

 meeting with Adrienne in Leahy's office, if she is around.

>> I would also like to work on the PPM with Emily.

>> So I am assuming I should fly down Monday evening to do Tuesday visits with staff? and stay till 3 pm flight

 home on Friday?

>> This seem OK?

>>

>> Happy Boxing Day

>> Cheers

>> Jean

>>

>

>

>

>

> This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

(b) (6)
From: McEvoy, Miles - AMS

To: Zea Sonnabend; Arsenault, Michelle - AMS

Cc: Calvin Walker; Carmela Beck; COLEHOUR BONDERA; Francis Thicke; Harold Austin; Jay Feldman; Jean

 Richardson; Jennifer Taylor; joe.dickson@wholefoods.com; John Foster; Mac Stone; Nick Maravell; Tracy Favre;

Wendy Fulwider

Subject: RE: NOSB February 2014 training agenda

Date: Thursday, November 07, 2013 6:22:00 AM

Hi Zea,

We hope to have OGC contribute to some of the training sessions. It is not possible to have

 OMB/OIRA participate although we may be able to have someone from USDA Office of Budget and

 Program Analysis provide perspective on the tortuous path of clearing rules, guidance, notices. We

 can discuss more during next week’s Executive call.

Miles V McEvoy

Deputy Administrator

National Organic Program

202-720-3252

From: Zea Sonnabend [mailto:zea@well.com] 

Sent: Wednesday, November 06, 2013 8:38 PM

To: Arsenault, Michelle - AMS

Cc: Calvin Walker; Carmela Beck; COLEHOUR BONDERA; Francis Thicke; Harold Austin; McEvoy, Miles -

 AMS; Jay Feldman; Jean Richardson; Jennifer Taylor; joe.dickson@wholefoods.com; John Foster; Mac

 Stone; Nick Maravell; Tracy Favre; Wendy Fulwider

Subject: Re: NOSB February 2014 training agenda

Hello,

I respectfully request that we hear from the OGC or OMB as Miles indicated might be

possible, and that there be time set aside for subcommittee meetings. I know Crops needs one

and there might be others.

Zea

On Nov 6, 2013, at 12:22 PM, Arsenault, Michelle - AMS wrote:

Hello team,

Attached, please find the draft training agenda for our February 4-5, 2014 meeting. We are working

 on travel and hotel logistics and as soon as I have any information I will send that to you. I am also

 thinking big thoughts about a Board dinner and some sort of reception or meet and greet event

 with the staff.

As I understand it, Jenny and Mac will be facilitating the meeting, and various NOP staff members

 (like Melissa) will present certain components.

Let me know if you have any questions!
Michelle

Michelle Arsenault

Advisory Board Specialist

USDA National Organic Program

1400 Independence Ave SW; Room 2640S

Washington, DC 20250-0268

Office phone: (202) 720-0081

Mobile: 

michelle.arsenault@ams.usda.gov

This electronic message contains information generated by the USDA solely for the

intended recipients. Any unauthorized interception of this message or the use or

disclosure of the information it contains may violate the law and subject the

violator to civil or criminal penalties. If you believe you have received this

message in error, please notify the sender and delete the email

immediately. <NOSB-Feb2013TrainingAgenda.docx>

(b) (6)
From: Jean Richardson

To: Zea Sonnabend; Mac Stone; John Foster; joe.dickson@wholefoods.com; Tracy Favre; Harold Austin; Fulwider

 Wendy; Jennifer Taylor; Nick Maravell; Walker Calvin; Thicke Francis; Carmela Beck; Colehour Bondera; Jay

 Feldman

Bcc: McEvoy, Miles - AMS; Brown Rosen, Emily - AMS

Subject: NOSB Ethics

Date: Wednesday, October 22, 2014 8:24:55 PM

Hi Everyone:

As most of you are aware, this week Zea found out, when reading public comments, that Jay had passed on

 confidential information concerning inert ingredients under discussion in the Inerts Working Group, of which he is

 a member, and this information was distributed to the public before even the rest of the Board has received any

 report. This is in violation of our NOSB professional and Ethical Standards. Zea has referred this matter to the

 NOSB Chair and requested that the PDS develop an NOSB censure policy.

As a gentle reminder to us all I have pasted below page 8 of our NOSB PPM which clearly indicates that members

 shall not allow non-authorized disclosure of nonpublic information. Please re-read this entire page and be sure that

 it is clear to you all.

This is the second time such an action has occurred in the last year, and it is very troubling.

It is important to remember that we can only be successful in our endeavors on the board if we work together for the

 good of the organic community as a whole.

Thank you

Jean

PPM Page 8:

Maintaining Professional and Ethical Standards

As appointees of the Secretary, NOSB members must maintain high professional and ethical

standards for the conduct of all activities within and outside of the NOSB. Areas of particular

concern include professional conduct and conflict of interest.

• Professional Conduct

o Public service is a public trust, requiring ethical principles above private gain.

o NOSB members shall put forth honest effort in the performance of their NOSB duties.

o NOSB members shall make no commitments or promises of any kind purporting to bind

the Government.

o NOSB members shall act impartially and not give preferential treatment to any

organization or individual.

o NOSB members, committee members and task force members shall not engage in a

financial transaction using nonpublic information, not allow the improper use of

nonpublic information to further his/her own private interest or that of another, whether

through advice or recommendation, or allow the unauthorized disclosure of nonpublic

information.

o Nonpublic information is defined as information that the board member gains by reason

of participation in the NOSB and that he/she knows, or reasonably should know, has not

been made available to the general public. This includes information that is “routinely

exempt from disclosure in 5 U.S.C. 552 (Freedom of Information Act) or otherwise

protected from disclosure by statute, Executive Order or regulation; is designated as

confidential by the agency or program; or has not actually been disseminated to the

general public and is not authorized to be made available to the public upon request.”

o NOSB members, committee members and task force members shall keep confidential

all information identified by petitioners as confidential business information.

1

o To the maximum extent possible, NOSB members should speak with one voice.

Although there may be disagreements within NOSB committee or working group
sessions, once NOSB members leave the session, they have the responsibility to

support the integrity of the process, whether or not they agree with the final outcome.

While NOSB members retain the right to express minority opinions, the public airing of

dissension could strain interpersonal relationships and create distrust and conflict

among NOSB members. Such stresses could undermine the NOSB’s ability to

effectively carry out its role as a governmental advisory board.

o NOSB members with diverse backgrounds are recruited to provide balance to the

Board. While individual NOSB members represent the segments of the population from

which they were selected, they also represent the greater good of the population as a

whole
From: Jean Richardson

To: McEvoy, Miles - AMS

Cc: Arsenault, Michelle - AMS; Calvin Walker; Carmela Beck; Colehour Bondera; Francis Thicke; Harold Austin; Jay

Feldman; Jennifer Taylor; joe.dickson@wholefoods.com; John Foster; Mac Stone; Nick Maravell; Tracy Favre; 

Wendy Fulwider; Zea Sonnabend; Brown Rosen, Emily - AMS

Subject: Re: NOSB ES Agenda for October 17, 2014

Date: Monday, October 20, 2014 1:58:59 PM

Miles,

Thank you for this weeks's "Word from Washington"!

I am very impressed that you survive with all that stuff.

We shall work to expunge the worrisome Workplan word and replace it with "Agenda Items"

Thank you

Jean

On Oct 20, 2014, at 1:21 PM, McEvoy, Miles - AMS wrote:

Within USDA workplans are part of a rule making or guidance development package. 

Workplans have to go through USDA departmental clearance and review by the Office 

of Management and Budget. It’s a long process with many offices that review and 

approve workplans. I’m concerned that when the NOSB uses the term “workplans” that

 it will attract the interest of USDA departmental clearance offices.

I’d suggest that we utilize a different term for NOSB workplan items so that these items

 don’t get dragged through the USDA departmental review process. I’d suggest that we 

refer to them as agenda items since these topics end up on the NOSB meeting agenda.

We can discuss next week at the board meeting. Thanks,

Miles V. McEvoy

Deputy Administrator

National Organic Program

1400 Independence Ave. SW

Washington, DC 20250-0268

202-720-3252

www.ams.usda.gov/nop

Organic Integrity from Farm to Table, Consumers Trust the Organic Label

From: Arsenault, Michelle - AMS

Sent: Friday, October 17, 2014 11:49 AM

To: Calvin Walker; Carmela Beck; Colehour Bondera; Francis Thicke; Harold Austin; Jay 

Feldman; Jean Richardson; Jennifer Taylor; joe.dickson@wholefoods.com; John Foster; 

Mac Stone; Nick Maravell; Tracy Favre; Wendy Fulwider; Zea Sonnabend

Cc: McEvoy, Miles - AMS; Brown Rosen, Emily - AMS

Subject: FW: NOSB ES Agenda for October 17, 2014
Hello all,

Draft workplans now attached. I have some outstanding questions highlighted in 

yellow. If the Subcommittee Chairs could take a look and give me an update, I’d 

appreciate that.

Thanks,

Michelle

From: Arsenault, Michelle - AMS

Sent: Thursday, October 16, 2014 3:51 PM

To: 'Calvin Walker'; 'Carmela Beck'; 'Colehour Bondera'; Francis Thicke; 'Harold Austin'; 

'Jay Feldman'; Jean Richardson; 'Jennifer Taylor'; 'Joe Dickson'; 'John Foster'; Mac Stone; 

'Nick Maravell'; 'Tracy Favre'; Wendy Fulwider; 'Zea Sonnabend'

Cc: Brown Rosen, Emily - AMS; McEvoy, Miles - AMS

Subject: NOSB ES Agenda for October 17, 2014

Hello all,

Below, please find the agenda for the ES call this Friday, October 17. I’ve attached the 

last set of notes (September12) and the sunset review template which we will discuss 

on the call. I will send the draft workplans as soon as I can.

Thanks!

ES call 1-2:30 ET (10-11:30 PT)

Agenda

Call to Order - JR

Approval of Notes: September 12, 2014 (attached)

Chairs Report

Advisory Board Specialist (ABS) update – MA

Comments/oral and written

Travel plans/logistics

NOP news and update – MM

Workplans (attached)

Sunset review final template (attached)

Subcommittee Reports (5 minutes each)

o Crops (CS) - ZS

o Livestock (LS) - TF

o Handling (HS) - HA

o Materials/GMO ad hoc (MS/GMO) - CW

o Compliance, Accreditation, & Certification (CACS) - CBe

Additional Items

(b) (6)
Adjourn     

Michelle Arsenault

Advisory Committee Specialist

USDA National Organic Program

1400 Independence Ave SW; Room 2641S

Washington, DC 20250-0268

Temporary office phone: (202) 260-8209

Office voicemail only: (202) 720-0081

Mobile: 

michelle.arsenault@ams.usda.gov

This electronic message contains information generated by the USDA 

solely for the intended recipients. Any unauthorized interception of 

this message or the use or disclosure of the information it contains 

may violate the law and subject the violator to civil or criminal 

penalties. If you believe you have received this message in error, 

please notify the sender and delete the email immediately.

(b) (6)
From: Jean Richardson

To: Arsenault, Michelle - AMS

Cc: Calvin Walker; Carmela Beck; Colehour Bondera; Francis Thicke; Harold Austin; Jay Feldman; Jennifer Taylor; 

joe.dickson@wholefoods.com; John Foster; Mac Stone; Nick Maravell; Tracy Favre; Wendy Fulwider; Zea

Sonnabend; McEvoy, Miles - AMS; Brown Rosen, Emily - AMS; Brines, Lisa - AMS; Jones, Samuel - AMS; Ricci,

Carrie - OGC

Subject: Re: NOSB Dinner Wednesday Oct 29

Date: Thursday, October 23, 2014 3:12:44 PM

sounds tasty to me

Thank you

Jean

On Oct 23, 2014, at 2:56 PM, Arsenault, Michelle - AMS wrote:

Hello folks,

Please see below for details about the Board dinner, Wednesday October 29 at 6:30p. 

If you plan on NOT attending, please let me know so I can adjust the count for the 

restaurant. Since this is a private room and it is family style, we will split the bill based 

on the total number of people. We provided the restaurant with the list of food 

allergies that I was aware of, but if anyone has others please let me know. They are 

very accommodating! I think the cost will be ~40.00/person but I am not sure about 

that yet.

Ramsi's Cafe On the World

1293 Bardstown Road

Louisville, KY 40204

(~ 5 miles (a 10 minutes cab ride) SE of hotel. We will congregate in the hotel lobby so 

we can taxi over in small groups between 6:00 and 6:15).

Private dining room in the main bar area.

Appetizers (to be served family style at each table of six or eight guests)

Fried green tomatoes (from Raising Hope Organic Farm) with sweet chili basil glaze and

 melted mozzarella

Charred shisitos (from our farm) in garlic and citrus mojo

Stuffed eggs (also from our farm) with a tomato jam underneath

Main course (buffet style)

Beef brisket, braised in Achiote sauce, served sliced (Achiote is a Mexican spice that is a

 beautiful red hue. The sauce has other sweet spices and some chilies, but it's not spicy)

Roasted whole chickens, rubbed in garlic, lemon and fall herbs.

Mashed potatoes, traditional

Roasted sweet potatoes, beets, peppers, orange and sage

Mixed lettuces with poached organic pears, shaved fig bread, with shaved white cheese

 in a bourbon pear vinaigrette

Bread?
Dessert (plated for each guest)

Chocolate pate (flourless chocolate torte) topped with fresh organic raspberries and 

blackberries, chocolate beet sauce, vanilla ice cream with raspberry beet swirl

Coffee/soda/tea/other beverages/gratuity separate. 

“We will be happy to create a special drink list highlighting our organic wine, beer and 

spirit selections. Everyone can order from the regular menu, of course.”

Michelle Arsenault

Advisory Committee Specialist

USDA National Organic Program

1400 Independence Ave SW; Room 2641S

Washington, DC 20250-0268

Temporary office phone: (202) 260-8209

Office voicemail only: (202) 720-0081

Mobile: 

michelle.arsenault@ams.usda.gov

This electronic message contains information generated by the USDA 

solely for the intended recipients. Any unauthorized interception of 

this message or the use or disclosure of the information it contains 

may violate the law and subject the violator to civil or criminal 

penalties. If you believe you have received this message in error, 

please notify the sender and delete the email immediately.

(b) (6)
From: Jean Richardson

To: Tom Chapman

Cc: Arsenault, Michelle - AMS; Ashely Swaffar; Calvin Walker; Carmela Beck; Colehour Bondera; Francis Thicke; 

Harold Austin; Jennifer Taylor; Lisa de Lima; Mac Stone (mac@elmwoodstockfarm.com); Nick Maravell; Paula

Daniels; Tracy Favre; Zea Sonnabend; McEvoy, Miles - AMS; Brown Rosen, Emily - AMS; Brines, Lisa - AMS; 

Barnes, Rex - AMS; Walden, Jessica - AMS

Subject: Re: NOSB dinner - Monday April 27, 2015

Date: Wednesday, April 22, 2015 4:11:02 PM

Could be salmon from Scotland...

On Apr 22, 2015, at 3:48 PM, Tom Chapman wrote:

Is that organic Salmon?..... what, not funny? 

Tom

From: Arsenault, Michelle - AMS [mailto:Michelle.Arsenault@ams.usda.gov]

Sent: Wednesday, April 22, 2015 12:39 PM

To: Ashely Swaffar; Calvin Walker; Carmela Beck; Colehour Bondera; Francis Thicke; 

Harold Austin; Jean Richardson; Jennifer Taylor; Lisa de Lima; Mac Stone

(mac@elmwoodstockfarm.com); Nick Maravell; Paula Daniels; Tom Chapman; Tracy 

Favre; Zea Sonnabend

Cc: McEvoy, Miles - AMS; Brown Rosen, Emily - AMS; Brines, Lisa - AMS; Barnes, Rex - 

AMS; Walden, Jessica - AMS

Subject: NOSB dinner - Monday April 27, 2015

Hello folks!

Below, please find the information for the Board dinner. Based on the current 

headcount (22) the dinner will be ~$58/person (inclusive of tax and tip). In order to 

meet our minimum we must also spend a total of $233.00 in cash sales (read: drink 

sales) or be charged a service fee. We have 3 birthdays this week, and Monday is Zea’s, 

so if everyone buys her a drink we should be good! If we have less than 22 people, the 

cost per person will increase a little bit. Please let me know if you cannot come, but I

hope everyone will!

Monday April 27, 2015 7:30 pm

Seasons52

4505 La Jolla Village Drive Suite C-1

Napa Room

Menu (see attached brochure for very enticing photographs!)

Organic field greens salad (Cucumbers, tomatoes, sunflower seeds, white balsamic 

vinaigrette

Entrees:

Cedar plank roasted salmon & veggies and crushed potatoes
Wood roasted Portobello & Pork tenderloin w/sweet potato mash, green beans

 and cipollini onions

Hone & herb All Natural Roasted half chicken with spring veggies

Vegetarian option

Mini Indulgence desserts, including fresh berries with organic whipped cream

Miscellaneous beverages (iced tea, coffee, raspberry lemonade, etc)

Michelle Arsenault

Advisory Committee Specialist

USDA National Organic Program

1400 Independence Ave SW; Room 2638S

Washington, DC 20250-0268

Office: (202) 720-0081

Mobile: 

michelle.arsenault@ams.usda.gov

(b) (6)
From: McEvoy, Miles - AMS

To: Jean Richardson (

Subject: NOSB check in

Does this time work for you? 

Topic – review NOSB agenda

This electronic message contains information generated by the USDA solely for the intended recipients. Any unauthorized interception of this message

 or the use or disclosure of the information it contains may violate the law and subject the violator to civil or criminal penalties. If you believe you have

 received this message in error, please notify the sender and delete the email immediately.

(b) (6)
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Re: NOSB check in

Date: Wednesday, September 03, 2014 8:01:44 AM

Ok. Let's skip this week. Things are moving along well

I plan to speak with all NOSB folks but it will take me a few weeks.

Miles V McEvoy

Deputy Administrator

USDA National Organic Program

On Sep 3, 2014, at 6:42 AM, "Jean Richardson" < wrote:

I will be starting an inspection in Syracuse at that time.

I could do 7.30 am on my cell phone? Or we could wait?

Jean

On Sep 3, 2014, at 6:00 AM, McEvoy, Miles - AMS wrote:

Thursday morning at 8.

Miles V McEvoy

Deputy Administrator

USDA National Organic Program

On Sep 2, 2014, at 9:10 PM, "Jean Richardson"

 < wrote:

computer wont read this

Day, time?

I have several calls because you have talked to people.

all good

Keep up the good work!

cheers

Jean

On Sep 2, 2014, at 7:48 PM, McEvoy, Miles - AMS

 wrote:

Does this time work for you?

Topic – review NOSB agenda

(b) (6) (b) (6)
This electronic message contains

 information generated by the USDA solely

 for the intended recipients. Any

 unauthorized interception of this message or

 the use or disclosure of the information it

 contains may violate the law and subject the

 violator to civil or criminal penalties. If you

 believe you have received this message in

 error, please notify the sender and delete the

 email immediately.

<Mail Attachment.ifb>
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: RE: NOSB Charter

Date: Friday, September 19, 2014 8:10:39 AM

We are working on it. We should have an announcement soon.

Miles V McEvoy

Deputy Administrator

National Organic Program

-----Original Message-----

From: Jean Richardson [mailto

Sent: Friday, September 19, 2014 6:38 AM

To: McEvoy, Miles - AMS

Subject: NOSB Charter

Hi Miles

I believe there were recent changes again to the Charter?

Has this happened yet?

Thanks

Jaen

This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

(b) (6)
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: RE: NOSB Chair"s Opening Comments - not for circulation

Date: Friday, October 24, 2014 12:46:29 PM

Thanks Jean for your confidence in me for reviewing your comments.

They look great - nice tone.

I'll send you my draft presentation and comments by the end of the day,

Best,

Miles

-----Original Message-----

From: Jean Richardson [mailto

Sent: Thursday, October 23, 2014 9:13 AM

To: McEvoy, Miles - AMS

Subject: NOSB Chair's Opening Comments - not for circulation

Hi Miles

Draft of my opening comments - using only a cartoon of a few cows discussing Kentucky Blue grass as an

 overhead.

to be delivered in an English accent at about 11 am Tuesday after Lisa Brines, and before Public comment Working

 with Sam to add it to the Blog he is working on to go out next week.

Cheers

This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

(b) (6)
From: McEvoy, Miles - AMS

To: Haines, Lindsay - NRCS, Washington, DC; Brown Rosen, Emily - AMS; Jean Richardson; Tracy Favre; White,

 Jeffrey - NRCS, Washington, DC

Subject: NOSB chairs and NRCS

Topics

NOSB work on conservation practices

CAP 138

EQIP 

This electronic message contains information generated by the USDA solely for the intended recipients. Any unauthorized interception of this message

 or the use or disclosure of the information it contains may violate the law and subject the violator to civil or criminal penalties. If you believe you have

 received this message in error, please notify the sender and delete the email immediately.
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: NOSB call in number and password

Date: Saturday, January 31, 2015 10:39:40 AM

Hi Miles

there is some concern among several NOSB members about retaining the same call in number and password with

 the change over in Board members.

We would appreciate your thoughts on this.

Thank you

Jean
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: Nosb board turn over

Date: Wednesday, November 05, 2014 8:13:33 PM

That could work

3 year terms perhaps

Let me try the math

Sent from my iPhone

> On Nov 5, 2014, at 8:12 PM, "McEvoy, Miles - AMS" <Miles.McEvoy@ams.usda.gov> wrote:

>

> Challenging - more likely to make shorter appointments to even out appointment process.

>

> -----Original Message-----

> From: Jean Richardson [mailto

> Sent: Wednesday, November 05, 2014 3:48 PM

> To: McEvoy, Miles - AMS

> Subject: Nosb board turn over

>

> Miles

> I wonder if we should discuss how to get better balance in cohorts coming on the board? Only 1 in Francis year.

> Would the Secretary consider extending a board member or 2 by a year for example?

> Tough to set up subcommittees and work distribution with 5 person turn over two years in a row Jean

>

> Sent from my iPhone

>

>

>

>

> This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

(b) (6)
From: Jean Richardson

To: Tracy Favre; Harold Austin; Carmela Beck; Calvin Walker; Zea Sonnabend; Mac Stone

Cc: Arsenault, Michelle - AMS; Brown Rosen, Emily - AMS; McEvoy, Miles - AMS

Subject: NOSB April Meeting

Date: Tuesday, November 11, 2014 10:53:03 AM

Dear Chairs

As you will have noticed from Michelle's e-mail yesterday, she has set February 7th as the date when the Tentative

 Agenda for the April meeting should be ready. - About 11 weeks from now. ! With Thanksgiving, Christmas, New

 Year and 4 new Board members to train up! And make it mostly fun!

My self imposed theme for the Kentucky meeting was building trust, seeking common ground and getting back our

 community sense of humor!. For the San Diego Meeting my personal goal as Chair is to show that we can work

 together with NOP, and stakeholders, and between ourselves to actually get a lot of work accomplished - pass

 proposals, vote on Sunset materials, send nothing back to subcommittee unless we really have to. ....

As sub committee Chairs I hope you can review all the items you have to bring forward at this upcoming meeting,

 make sure each lead person is on track, and push to get work done sooner. The last minute scrambles only lead to

 sloppy work as we know. What TR's are we missing.? Do we need to anticipate additional conference calls?

As leaders we set the tone! Cheerful in our volunteer work!

If there is anything at all that I can do to help, let me know.

The Executive meeting is this Friday, November 14th.

Talk with you then

Cheers

Jean
From: Jean Richardson

To: Arsenault, Michelle - AMS

Cc: McEvoy, Miles - AMS; Tucker, Jennifer - AMS

Subject: Re: NOSB April 2015 Declaration of Interests/COIs

Date: Thursday, April 02, 2015 8:11:23 AM

Excellent work Michelle

Everyone, including all our new members should be able to understand this.

Thank you

Jean

On Apr 1, 2015, at 9:19 PM, Arsenault, Michelle - AMS wrote:

Hello All, 

Attached (and in Dropbox), please find the spreadsheet with a list of all proposals and 

discussion documents, which I hope will serve two functions: 1) a place for you to 

indicate any Declarations/Conflicts of Interest, and 2) as a summary document to help 

you prepare for the meeting.

A few notes about the spreadsheet:

· Each of the proposals is hyperlinked to supporting information such as the 

actual proposal (all bundled in the same pdf and linked in Column D), the 

petition, and the TR (if applicable). If the petitioner is your 

wife/brother/business partner, you could have a COI, so make sure to take a 

look!

· Column F contains the date of discussion or vote in Subcommittee, so you can 

refer to that set of Subcommittee notes if you would like to familiarize yourself 

with the discussion. (Link to Subcomm notes provided)

· Columns I - W are where you will indicate any COIs. Note the fields I already 

populated with NA. Generally if people have a COI it’s with a material and not a

 general document like the CACS’s Peer Review. I have also placed NA after 

each one of the 2017 sunset materials, because this is posting 1 and we are not

 voting on any of these materials.

Conflicts of Interest (COIs). As per the COI memo (linked in the spreadsheet and 

attached here as well), the NOP is asking Board members to self-report any conflicts of 

interest (COIs) so we can compile recusals in advance of the meeting. If you know you 

need to recuse yourself due to an actual COI, please place an X on the spreadsheet in

the column under your name next to the appropriate proposal(s). If you are unsure if 

you should recuse yourself, please contact Jenny Tucker, NOP’s Associate Deputy 

Administrator (copied here), to discuss your possible COI. After that conversation, 

complete the spreadsheet as needed. Once you have finished, please send your

completed spreadsheet back to me. At the meeting the NOP will state who is recusing 

themselves. When it is time to vote, you can simply state “recuse” with no further 

explanation.
A snippet from the training slides presented February 2015:

Board members are appointed in part because of their interests. As such, 

finding the line between an acceptable interest and a conflict of interest is 

important.

Conflict of Interest: Interest that directly and disproportionally benefits the 

NOSB member (or a person associated with that member). Many of the 

interests that you hold are acceptable interests. An interest is acceptable if you

 carry it on behalf of a represented group, and if you receive no 

disproportionate benefit from expressing the interest. Interests can create 

appearance problems when an interest: directly and disproportionally benefits 

you or a person associated with you; could impair your objectivity in

representing your group; or has the potential to create an unfair competitive 

advantage. Be alert for situations when one of the following persons or entities 

will be specifically affected by your committee’s activities: a member of your 

household; a former employer or a prospective employer; a client of yours or 

your spouse; a person or organization with which you have some kind of 

business or contract relationship; or your spouse’s employer.

Please return the worksheet to me by Friday April 15, so I can compile the info in 

advance of the meeting. If you have no COIs that warrant recusal, you may reply with 

an email stating so, instead of returning the worksheet with no X’s. 

If you have any questions, you know where I live!

Thanks!

Michelle Arsenault

Advisory Committee Specialist

USDA National Organic Program

1400 Independence Ave SW; Room 2638S

Washington, DC 20250-0268

Office: (202) 720-0081

Mobile: 

michelle.arsenault@ams.usda.gov

<Spr 2015 DOI_COI List.xlsx><NOSB-NOP-COI-FINAL.pdf>

(b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: NOSB 2015

Date: Wednesday, April 16, 2014 6:31:01 PM

sounds good

I will call you Thursday

Jean

On Apr 16, 2014, at 5:36 PM, McEvoy, Miles - AMS wrote:

Hi Jean,

Got your message. I was in Korea last week. Just getting back and catching up. We are 

planning on moving the 2015 NOSB meetings to June/November. Love to have the June

 meeting in Vermont – after black fly season is over. I’ll be around the next few days if 

you’d like to discuss further.

Miles McEvoy

Deputy Administrator

National Organic Program

This electronic message contains information generated by the USDA 

solely for the intended recipients. Any unauthorized interception of 

this message or the use or disclosure of the information it contains 

may violate the law and subject the violator to civil or criminal 

penalties. If you believe you have received this message in error, 

please notify the sender and delete the email immediately.
From: Jean Richardson

To: COLEHOUR BONDERA

Cc: Tracy Favre; Harold Austin; Arsenault, Michelle - AMS; McEvoy, Miles - AMS

Subject: NOSB - New member training

Date: Friday, December 12, 2014 11:07:34 AM

Hi Colehour

I got back from India yesterday and am catching up on e-mails.

Your November 19 e-mail to me came literally as I was headed out the door to the plane for India.

As you recall, Miles could not be on our last ES call and thus details on the NOP's new member training in February

 were not available.

This morning I discussed your concerns with Miles in my regular phone conversation with him and asked that he

 describe the new member training on the ES call today, and the possible date for the Ethics part of the required

 annual NOSB /FACA training.

To clarify one of the concerns you raise in your e-mail to me, the NOSB Officers are not going to be training new

 members, only the NOP staff does that. I hope that the NOSB leadership Team can listen carefully to the training

 provided to the new members by the NOP and ensure that we all understand the roles that we have to play and the

 rules we have to play by.

Now that I am home I would be happy to chat with you about this training and other matters of concern to you.

Best Regards

Jean
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: NOSB

Date: Monday, September 01, 2014 1:28:33 PM

Hi Miles

forgot to let you know that Nick and Wendy and Mac are active again on the Board. And if you are calling around

 members be sure to chat with both Tracy and Harold

Thanks,

Jean
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: NOSB

Date: Thursday, September 04, 2014 5:45:58 PM

Hi Miles

Dave retired at the beginning of September. I am not sure if NOFA has hired another policy 

person

Jean

On Sep 4, 2014, at 12:35 PM, McEvoy, Miles - AMS wrote:

Hi Enid and Dave,

I’d like to set up a time to talk about the National Organic Standards Board (NOSB). I 

understand you may have concerns that I’d like to hear. I’d also like to discuss some 

ideas we have about organic hydroponics. Are you available on Tuesday, September 16 

at 3 pm eastern time for a conference call?

I’d also like to see if there could be a session at the NOFA-VT winter conference to 

discuss the National Organic Program and NOSB.

Miles McEvoy

Deputy Administrator

National Organic Program

This electronic message contains information generated by the USDA 

solely for the intended recipients. Any unauthorized interception of 

this message or the use or disclosure of the information it contains 

may violate the law and subject the violator to civil or criminal 

penalties. If you believe you have received this message in error, 

please notify the sender and delete the email immediately.
From: McEvoy, Miles - AMS

To: Brines, Lisa - AMS; Jean Richardson

Subject: FW: NOSB

Date: Thursday, April 30, 2015 2:13:34 PM

fyi

-----Original Message-----

From: Dinh, Mai - OGC

Sent: Tuesday, April 28, 2015 11:36 AM

To: McEvoy, Miles - AMS

Subject: RE: NOSB

Hi Miles -

I hope the meeting is going well. The minutes for the meeting should note that he is participating by phone and

 make sure his votes are recorded especially if the others are voting by show of hands. The Chair should announce

 that he is participating by phone and give him opportunities to be recognized and speak when appropriate.

Thanks,

Mai Dinh

Assistant General Counsel

Marketing, Regulatory, and Food Safety Programs Division Office of the General Counsel U.S. Department of

 Agriculture Room 2343, South Building

1400 Independence Ave., SW

Washington, DC 20250

202-720-5935

-----Original Message-----

From: McEvoy, Miles - AMS

Sent: Tuesday, April 28, 2015 10:16 AM

To: Dinh, Mai - OGC

Subject: NOSB

Harold Austin, on of the NOSB members, fell last night and broke his hip. He is having surgery this morning and

 won't be back at the NOSB meeting today. He will most likely be at the hospital the rest of this week. We would

 like to set up a phone line with him so that he could listen and participate in the meeting on Wednesday and

 Thursday. Are there any protocols or considerations that we need to consider regarding his participation and voting

 through a phone connection?

Miles V McEvoy

Deputy Administrator

USDA National Organic Program
From: Jean Richardson

To: Nick Maravell

Cc: Arsenault, Michelle - AMS; Tracy Favre; Brown Rosen, Emily - AMS

Bcc: McEvoy, Miles - AMS

Subject: NOSB

Date: Friday, June 26, 2015 4:40:31 PM

Hi Nick

We have not heard from you since San Diego meeting

Are you planning on being on any of the calls this summer? And are you planning on being on the public comment

 Webinars in September? Are you coming to the October meeting (26-29 in Vermont).?

Let me know if you would like to chat about any of the NOSB issues and progress on Sunset materials etc.

Very Best Regards

Jean

(b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Fwd: North East veg and berry news

Date: Friday, July 18, 2014 8:28:20 AM

Hi Miles

I know most of the folks who send these in to Dr Grubinger our Extension person for veg and 

Berry. They are primarily organic growers.

It gives a nice flavor (sorry for the pun) of growing season conditions. At the end of the farm 

reports are some notes on pests and diseases from the other staff

Jean

Begin forwarded message:

From: Vern Grubinger <vernon.grubinger@uvm.edu>

Date: July 18, 2014 7:52:10 AM EDT

To: Vern Grubinger <vernon.grubinger@uvm.edu>

Subject: VT veg and berry news

Vermont Vegetable and Berry News – July 18, 2014

compiled by Vern Grubinger, University of Vermont Extension

(802) 257-7967 ext. 303, vernon.grubinger@uvm.edu

www.uvm.edu/vtvegandberry

REPORTS FROM THE FIELD

(Guilford) This might be our latest strawberry season ever, we picked some 

Cavendish and Sparkle this week. Still no sign of SWD, but we want to order 

large amounts of Proteknet for blueberries and raspberries. Great pea crops, but 

why can't they get quality control up on pea seed? Always shell peas in with 

sugarsnaps. Weeds are loving the weather and took advantage of all those 

harvesting days so we're battling our way out. Deer and woodchucks hitting us 

hard this year. It may go down as Year of the Mammalian Pest for us, after Year 

of the Snail, Year of the Slug, and Year of the SWD.

(Plainfield NH) Wrapping up PYO this weekend. Had a better season than 

expected after an initial onslaught of leaf spot disease and plants getting off to a 

real slow start vegetatively after the long winter. Harvest got off to a slow and late

 start for us as well, but good picking weather helped. Old workhorse varieties 

performed the best: Cavendish, Annapolis, Valley Sunset and Lamour. Will miss 

Noreaster from Nourse which was a dependable for PYO on our soils. Now 

picking raspberries, black caps and blueberries while harvesting summer 

vegetables and greenhouse tomatoes for the farmstand and accounts. Plants that 

should be transplanted out in the field are backing up in the greenhouse and the 

weeding and cultivations are less than timely. Weeds have exploded the last 10 

days, put on tremendous growth making cultivation challenging. Have a potato 

leaf blight (currently being diagnosed at UNH) and one of the heavy hatches of 

Jap Beetles in many years. Some thrips injury and purple blotch in one onion 

plantings. The 7-member field crew is swamped, putting in 12 to14 hour days 
now that blueberries are ready. This time of year always puts a hole in our labor 

strategy and is extremely tiring for all of us as we try to hold it together. Can’t say

 enough good things about the dedication my guys (male and female) have been 

showing.

(Wolcott) Red and black currants are heavy with fruit. Blueberries are in the green

 stage so time to get the netting ready, this helps us to allow them to get to their 

full sweet flavor without worrying that we better pick them before the birds do. 

Looks like a great plum year. We fruited Rubicon strawberry and happy with the 

size and flavor. Kolomitka kiwis are loaded and stores love them. Still very dry up

 here in elmore, even with the hard rains and thunderstorms, not sure why.

(Westminster West) Greenhouse raspberries starting to come in and are very large

 so far. We haven't run drip in the houses until now just too busy but it doesn't 

seem to have made any difference. Thinned and cut back heavily this year might 

have helped. Winter squash running and setting lots of fruit but as always won't 

know the yields until harvest time. Very few squash bugs so far. Onions looking 

good, trying to keep up with copper applications as well as thrips control, also 

haven't had to run drip yet but will commence as I need to fertigate. Garlic harvest

 starting today, some varieties really large and no signs of last year’s problems. 

Tunnel tomatoes coming in heavy now and selling all we can pick. Lettuce from 

tunnels looks great and moving fairly well. Just finished planting fall carrots and 

beets on raised beds a bit earlier than last year so I guess ‘on time’ for a change! 

Mostly winning the war on weeds. Potatoes looking great too, no bugs yet? Gotta 

find time to enjoy summer a bit more is this year’s resolution.

(Waterbury Center) Wrapped up our strawberry harvest last week. It lasted about 

three weeks, with sunny weather for harvesting. Still happiest with Jewel. 

Extrapolated to a per acre basis we harvested about 8,000 lbs/acre on certified 

organic land. Yields were affected by some as yet unidentified problem, possibly 

winter injury coupled with disease. Constructed low tunnels with 4 mil plastic 

over six 250 foot beds in case of rain like we had last year, which didn't happen, 

but they were insurance anyway and did seem to help with gray mold. Now we’ll 

try to get a second fruiting season from June bearers on plastic by removing 

plastic, renovating, and hoping plants will fill in the beds. Mother plants just seem

 exhausted. Started harvesting Prelude raspberries two weeks ago inside high 

tunnel, nice big berries. Problems with mites but overhead irrigating has gotten 

them under control. Garlic, peppers, cantaloupe, and watermelons all looking 

good.

(Hampton NY) Squash bugs, deer and hail Oh My! What started off as a really 

good May and June has rapidly gone downhill in July. The crops were looking 

good with first harvest of peas and string beans anticipated for end of June. Then 

the deer came. Gone are all the peas, a 125’double row of string beans, the tops of

 all Early Girl and Lemon Boy tomatoes and most leaves on half the sunflower 

plants. I have since cubed bars of Irish Spring Soap around the crops that they 

prefer which is keeping them away for now. On July 3rd the hail came. Summer 

and winter squash plants will recover but the remaining tomatoes have split stalks.

 I think they’ll survive but will be delayed. Now the squash bugs. No one ever 

said farming was easy. Have been picking cucumbers for a week but yields are 
down. Burpless cucumber should be producing in early September. Second 

sowing of string beans are flowering; third sowing leafing out; fourth sowing just 

went in. Should start harvesting frying peppers next week; bell peppers in two 

weeks. Butta yellow zucchini are doing poorly this year. Zinnias and Daisies 

going on the stand this weekend.

(Warren) No major disasters, all crops looking good so far. Markets are steady 

and I have enough product to fill every order. High tunnel peppers and tomatoes 

are looking great, loaded with fruit. Kind of the calm before the storm. With the 

exception of salad greens successions and turnips everything is in the ground. 

Weeds are as under control as they are going to get and there is a week or so 

before bulk carrot, beet and onion harvests begin so I'm off on vacation for a 

week. A big lesson I've learned is that if you happen to stumble across employees 

worth keeping, do whatever you can to keep them around. An extra couple bucks 

an hour is a fantastic investment when you figure the cost of retraining folks each 

year. My guys are over the moon about having the place to themselves for a week 

and I'm equally happy about becoming non-essential in terms of day to day 

operation.

(Burlington) Strawberries were outstanding. Best crop in 22 years of growing. 

Chalk it up to no frost after early April, unexplained lack of TPB, and a nice 

balance of sun and rain beginning in mid-May. Only complaint is that our tertiary 

fruit didn't have great flavor, while the king and secondary berries were delicious, 

and so were the quaternaries. Only guess is not enough leaves and reserves to 

support good sugar production, because the weather cooperated. My favorite part 

of the farm right now is a cover crop section we intend to crop next year that has 

serious compaction, and it has a super stand of 6' sweetclover, red clover, rye, and

 vetch with a wonderful scent.

(Marlboro) Both raspberries and blueberries are starting. Blueberries are loaded 

and all the rain coupled with the fruit load has the canes bent right to the ground. 

Spraying will be a challenge! So far, no confirmed SWD. Have captured some 

flies in the traps, but they don't seem to be laying eggs in berries. It is so nice 

picking before the SWD arrives. Vegetables are making up for lost time, now that 

the nights are finally out of the 40's. Just started to harvest garlic and the heads are

 huge.

(Rochester) The long and cold winter didn't seem to impede the insect pests: 

raspberry cane borer is more widespread this year; rose chafers chafed the 

raspberry foliage at the same rate; and Japanese beetles are now out in force. New

 cane growth in the raspberries is very vigorous and the fall bearers might do very 

well. Winter damage will leave us with a weak yield in the earliest blueberries but

 the later varieties look strong. We were given an on-farm demonstration of a 

compact sawdust/mulch spreader from Quebec company called A. Therrien & 

Fils, and were very impressed. Growers with small plantings or narrow alleys 

might be interested. They have a YouTube video of it in action on their site 

http://atherrien.net

(Monkton) Great strawberry season, over twice the yield of last year, only a trace 

of fungal diseases, and hardly any tarnished plant bug damage. PYO demand also 
seems to be up. Blueberries, currants, and raspberries look good and the traps are 

out for SWD. Garlic harvest has begun and bulbs look great although a few rogue,

 mysterious (even to the plant diagnostic lab) virus specimens have appeared. 

Other crops look good although we over-planted summer squash. Anyone need 

extra zucchini? Overall, a pleasure to work in good weather!

(New Haven) All crops are on target. We are picking summer squash, cukes, 

onions, greens, carrots, beets and beans. Corn is slow to mature but we will be 

picking by next week. Pumpkins and winter squash all on target. We will start 

planting fall cole crops next week. A little rain would be nice.

(Hinesburg) Partway through garlic harvest. There is some minor leek moth 

damage, but overall the bulbs are significantly larger and of much better quality 

than last year.

(Williston) Japanese beetles are on the rise. Hand picking daily seems to be 

keeping them under control. Potato beetle on the eggplant have been doing 

damage but more hand picking has decreased numbers. I found a hornworm moth 

2 weeks ago in my hoop house tomatoes and will spray Dipel. Wholesale market 

sales are picking up after a slow late May/June. Hoping basil will be okay for a 

while before mildew shows up. Had trouble with my Mazzie fertilizer system and 

found the in-line filter was plugged up from fish/seaweed fertilizer. Need to put 

whole system before sand/gravel filter. Last few quick heavy rains of up to 2" rain

 mean I need to get fertilizer in fields.

(Grand Isle) We will finally be picking sweet corn tomorrow. We are using 

Trichograma wasps this year for corn borer in our sweet corn. So far, so good. 

Also we are trialing Malwina strawberries. We didn't have time to clip the flowers

 from the new plants, and the fruit is large, good looking and very sweet. Very 

little bug pressure so far. Good weather to work in; life is good!

(Argyle NY) Our annual bed strawberry season was better than average with 

Chandler, but heavy rains did cause some loss of production. We think about 

putting them in tunnels to control the weather! They are scheduled to be turned 

under tomorrow. We have some experimental ever-bearing varieties that we are 

keeping data on and will be working at keeping out insects. The first week of 

August we will get our new Chandler tips in Canada and root them in our 

greenhouse for the Sept planting. Blueberries have lots of winter-kill and we have 

zero apples. Over-wintered Bridger and Forum onions have surprisingly been our 

best crop ever; the Forum we planted in early December from sets now have their 

tops over and they are ready for drying down or fresh onion sales; we just finished

 selling the earlier Bridgers. We have never had disease on these onions and they 

store for many months. Most crops are doing well, except the greens that had a 

little hail damage last week. Leafhoppers just appeared in a flurry 2 days ago so 

we had to break out the Pyganic. Markets are a little slower this summer and we 

will be searching for fall farm workers.

SWD INFORMATION

The first few spotted wing drosophila adults of the year have been captured in CT,
 NH, RI and Hudson Valley - but as Alan Eaton of UNH says “Don’t get too 

excited.” Yet. Populations are expected to rise a lot in August in most parts of 

Vermont, as in past years. It will be interesting to see if SWD shows up in 

northern-most areas. The time to set out traps is just before fruits starts to color; 

but low traps catches are not a guarantee the pest has not attacked fruit. There is 

no need to spray a crop for SWD until fruit is first turning ripe – they do not 

attack unripe fruit. Details on traps, netting, sprays and cultural management are 

posted at: http://www.uvm.edu/vtvegandberry/SWDInfo.html.

UPDATE FROM THE UVM PLANT DIAGNOSTIC CLINIC – Ann Hazelrigg

Field tomatoes: Septoria (little black spots with gray centers) and Alternaria (early

 blight-larger brown spot with target appearance and advancing yellow margin) 

leafspot diseases showing up now on lower leaves. Stake tomatoes, keep up 

adequate fertility and protect new tissue with a fungicide on a 7-10 day schedule 

into the fall. Closest late blight is in Maine on potatoes. Tomato hornworm 

feeding noted.

No late blight reported yet in VT but it’s been confirmed in western NY, Long 

Island, and southeast ME. Plan to protect tomato and potato crops; depending on 

the weather it may appear here soon. You can track progress of the disease on a 

map and read management info at: http://usablight.org/

GH Tomatoes: Lots of Botrytis (gray fuzzy spores on dying tissue) and leaf mold 

(yellow spots on upper side of leaves with brown spores on undersides) showing 

up after the rainy weather. Keep RH below 85%, prune lower leaves up to first 

fruit cluster and clean up fruit and infected leaves. Also seeing ghost spot (small 

white rings on green fruit) where Botrytis spores have infected fruit and stopped. 

https://negreenhouseupdate.info/photos/botrytis-greenhouse-tomato-ghost-spot. 

Add fans, open up ends, etc. Also seeing hot spots of two spotted spider mites. 

Look for off-colored/bronzing foliage and check leaf undersides with hand lens. 

https://extension.umass.edu/vegetable/insects/mite-twospotted-spider. Can spot 

treat and use predators.

Cucurbits: No downy mildew in the area as yet and we are still at low risk at this 

point. To track progress, look at the national map 

http://cdm.ipmpipe.org/scripts/map.php. Powdery mildew showing up. Squash 

bugs hatching and feeding, see: 

https://extension.umass.edu/vegetable/insects/squash-bug. Use 

azadirachtin/Neemix for nymphs for organic growers and acetamiprid (Assail 5.3 

oz/A) for others. Squash vine borer trap captures have hit 100 at one farm in CH 

Co, but no damage in the field seen.

Brassicas: The second peak of flea beetle damage may occur on newly planted 

fall brassicas. Alternaria is showing up in brassicas, and adequately fertilized 

crops are less susceptible. Black rot diagnosed in kale. ‘V’-shaped yellow lesions 

are the main symptom. Both pathogens can be seed borne and hot water seed 

treatment is effective for both. Swede midge damage seen in growing points of 

broccoli with severe tell-tale scarring on petioles/stems in Chittenden County. All 

stages of imported cabbage worm in brassicas now; adults, pupae and young 
larvae feeding in crops. Easier to control/manage when larvae are small.

Beans: Lots of Mexican bean beetle spiky yellow larvae seen feeding on beans. 

Feeding occurs on the underside of leaves, but causes death of leaf tissue in a 

lace-like pattern. Feeding damage over 10-20% can cause yield loss. High 

numbers cause circular spots/feeding damage on pods. Potato leafhopper may be 

causing hopper burn on leaf edges.

Onions: Botrytis and purple blotch seen. Lots of damage from onion leek moth 

destroying garlic scapes and leaves. Thrips numbers increasing.

Basil: Downy mildew not found in VT so far but it is coming soon. Get as much 

basil grown, harvested and turned into pesto ASAP since once it shows up, it is 

hard to keep it disease-free.

Mint: Four-lined plant bug damage seen on mints causing disease-like angular 

black spots on foliage.

Parsley: Septoria leaf spot on flat leaf parsley diagnosed. Look for brown spots 

with black dots inside the spots.

Corn: for discussion of European corn borer and earworm trap captures from 

scouting in MA and VT see:

https://extension.umass.edu/vegetable/publications/vegetable-notes-newsletter/

UPCOMING EVENTS See: http://www.uvm.edu/vtvegandberry/?

Page=meetlist.html
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Automatic reply: NOSB Oct 2015

Date: Thursday, December 18, 2014 6:23:59 PM

I am out of the office. Please contact Desiree Lee at 202-720-3252, desiree.lee@ams.usda.gov

 if you need immediate assistance.

This electronic message contains information generated by the USDA solely for the intended

 recipients. Any unauthorized interception of this message or the use or disclosure of the

 information it contains may violate the law and subject the violator to civil or criminal

 penalties. If you believe you have received this message in error, please notify the sender and

 delete the email immediately.
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: RE: NOSB Oct 2015

Date: Friday, December 19, 2014 5:50:05 AM

Understood

-----Original Message-----

From: Jean Richardson [mailto

Sent: Thursday, December 18, 2014 6:24 PM

To: McEvoy, Miles - AMS

Subject: Re: NOSB Oct 2015

The Tuesday evening event will be run by NOFA VT, not by NOSB Jean

On Dec 18, 2014, at 4:54 PM, McEvoy, Miles - AMS wrote:

> Hi Jean,

> The general schedule looks good. I will need to run the Tuesday evening idea by the USDA Office of

 Congressional Relations.

>

> Miles

>

> -----Original Message-----

> From: Arsenault, Michelle - AMS

> Sent: Thursday, December 18, 2014 9:36 AM

> To: Jean Richardson; McEvoy, Miles - AMS

> Subject: RE: NOSB Oct 2015

>

> Hi Jean,

> This sounds like a great itinerary. And I'm glad I'm not responsible for organizing it all! The only thing I would

 insist on is that the public meeting begin at 8:30. It's pretty tough on the West Coasters to start so early, unless we

 are allowing them to fly in a couple days early to acclimate to the time zone.

>

> Looking forward to it.

> Thanks!

> Michelle

>

>

> -----Original Message-----

> From: Jean Richardson [mailto

> Sent: Thursday, December 18, 2014 9:17 AM

> To: McEvoy, Miles - AMS; Arsenault, Michelle - AMS

> Subject: NOSB Oct 2015

>

> Hi Miles and Michelle

> I had an initial meeting yesterday with folks at NOFA VT to plan the October NOSB Meeting organic Celebration

 in Vermont.

> Here is our initial plan:

>

> Sunday October 25, Optional Field trips to a dairy farm, veg farm and processor including a drive over the Notch

 (top of Mountain). scenic drive.

> NOFA will provide a van working with the Youth Conservation Corps.

>

> Sunday early evening NOFA and farmer/producer, sponsored Welcoming Reception featuring local organic wines

(b) (6) (b) (6)
 and cheeses etc.

>

> NOSB Meeting starts 8 am Monday morning - Miles we may wish to give NOC a heads up that for both San

 Diego and Stowe we will be having 4 day meetings starting on the Monday, given that NOC typically uses the

 Monday for their meeting. Let me know if you wish to make that contact, or if I should.

>

> Monday night nothing planned

>

> Tuesday afternoon, end the formal meeting at 4 pm (I added in buffer time) so that we can have the BIG

 COMMUNITY CELEBRATION OF ORGANIC Tuesday evening starting early so we can get families and

 children. (We may change our minds on this, but this is our initial thinking).

> This will have a number of sponsors and invited guests including Senators Leahy and Sanders and Rep Welch, our

 Governor and Chuck Ross, VT Secretary of Agriculture (how to keep their remarks short!!!).

>

> Planned activities - Regional Organic food and beverages, so many to choose from. If family oriented we may do

 a huge sit down meal or a Reception style with producer sponsored tables,...

> Music (NOFA has already asked the BEST band), and an old fashioned public Barn Dance Huge Puppets (Bread

 and Puppets if you have heard of them) and juggling as called for!........

>

> NOFA is immediately looking to reserve the best Barn space, real barn

> close by or at Conference Center

>

> Board Dinner Wednesday night - with goodbyes to outgoing Board members.

>

> Thursday - work all day probably!

>

>

> We have a NOFA meeting with our VT Congressional staffers on Monday Dec 22 and will get this date on their

 calendars.

>

> Hope this sounds OK to you?

>

> Thank you

> Jean

>

>

>

>

> This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Re: NOSB Oct 2015

Date: Monday, December 22, 2014 11:18:34 AM

This event will be fine. I just need to keep everyone informed. Thanks.

Miles V McEvoy

Deputy Administrator

USDA National Organic Program

> On Dec 18, 2014, at 3:23 PM, "Jean Richardson" < wrote:

>

> The Tuesday evening event will be run by NOFA VT, not by NOSB

> Jean

>

>> On Dec 18, 2014, at 4:54 PM, McEvoy, Miles - AMS wrote:

>>

>> Hi Jean,

>> The general schedule looks good. I will need to run the Tuesday evening idea by the USDA Office of

 Congressional Relations.

>>

>> Miles

>>

>> -----Original Message-----

>> From: Arsenault, Michelle - AMS

>> Sent: Thursday, December 18, 2014 9:36 AM

>> To: Jean Richardson; McEvoy, Miles - AMS

>> Subject: RE: NOSB Oct 2015

>>

>> Hi Jean,

>> This sounds like a great itinerary. And I'm glad I'm not responsible for organizing it all! The only thing I would

 insist on is that the public meeting begin at 8:30. It's pretty tough on the West Coasters to start so early, unless we

 are allowing them to fly in a couple days early to acclimate to the time zone.

>>

>> Looking forward to it.

>> Thanks!

>> Michelle

>>

>>

>> -----Original Message-----

>> From: Jean Richardson [mailto:

>> Sent: Thursday, December 18, 2014 9:17 AM

>> To: McEvoy, Miles - AMS; Arsenault, Michelle - AMS

>> Subject: NOSB Oct 2015

>>

>> Hi Miles and Michelle

>> I had an initial meeting yesterday with folks at NOFA VT to plan the October NOSB Meeting organic

 Celebration in Vermont.

>> Here is our initial plan:

>>

>> Sunday October 25, Optional Field trips to a dairy farm, veg farm and processor including a drive over the Notch

 (top of Mountain). scenic drive.

>> NOFA will provide a van working with the Youth Conservation Corps.

>>

(b) (6) (b) (6)
>> Sunday early evening NOFA and farmer/producer, sponsored Welcoming Reception featuring local organic

 wines and cheeses etc.

>>

>> NOSB Meeting starts 8 am Monday morning - Miles we may wish to give NOC a heads up that for both San

 Diego and Stowe we will be having 4 day meetings starting on the Monday, given that NOC typically uses the

 Monday for their meeting. Let me know if you wish to make that contact, or if I should.

>>

>> Monday night nothing planned

>>

>> Tuesday afternoon, end the formal meeting at 4 pm (I added in buffer time) so that we can have the BIG

 COMMUNITY CELEBRATION OF ORGANIC Tuesday evening starting early so we can get families and

 children. (We may change our minds on this, but this is our initial thinking).

>> This will have a number of sponsors and invited guests including Senators Leahy and Sanders and Rep Welch,

 our Governor and Chuck Ross, VT Secretary of Agriculture (how to keep their remarks short!!!).

>>

>> Planned activities - Regional Organic food and beverages, so many to choose from. If family oriented we may do

 a huge sit down meal or a Reception style with producer sponsored tables,...

>> Music (NOFA has already asked the BEST band), and an old fashioned public Barn Dance Huge Puppets (Bread

 and Puppets if you have heard of them) and juggling as called for!........

>>

>> NOFA is immediately looking to reserve the best Barn space, real barn close by or at Conference Center

>>

>> Board Dinner Wednesday night - with goodbyes to outgoing Board members.

>>

>> Thursday - work all day probably!

>>

>>

>> We have a NOFA meeting with our VT Congressional staffers on Monday Dec 22 and will get this date on their

 calendars.

>>

>> Hope this sounds OK to you?

>>

>> Thank you

>> Jean

>>

>>

>>

>>

>> This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

>
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Automatic reply: NOSB meetings 2015

Date: Tuesday, July 08, 2014 9:09:35 AM

I am out of the office. Please contact Joan Avila at 202-720-3252, joan.avila@ams.usda.gov if

 you need immediate assistance.

This electronic message contains information generated by the USDA solely for the intended

 recipients. Any unauthorized interception of this message or the use or disclosure of the

 information it contains may violate the law and subject the violator to civil or criminal

 penalties. If you believe you have received this message in error, please notify the sender and

 delete the email immediately.
From: Jean Richardson

To: Arsenault, Michelle - AMS

Cc: McEvoy, Miles - AMS

Subject: Re: NOSB meetings 2015

Date: Tuesday, July 08, 2014 12:57:28 PM

Yes I will follow up. So glad you are onto it for 2016 and 17

Sooner we get these set in place the better in terms of good choices with pleasant atmosphere.

On Jul 8, 2014, at 10:16 AM, Arsenault, Michelle - AMS wrote:

> Hi jean,

> Thanks for doing some extra legwork. It's very helpful to get a "boots on the gound" view. Two notes; I couldn't

 find anything on the Stowe hotel website regarding the free shuttle. Can you find out more info about it and get

 back to me? The hospitality company has already scouted locations for us for 2016 and 2017.

>

> Thanks,

> Michelle

>

>

>

> -----Original Message-----

> From: Jean Richardson [mailto

> Sent: Tuesday, July 08, 2014 9:09 AM

> To: McEvoy, Miles - AMS

> Subject: NOSB meetings 2015

>

> Hi Miles

> You will be pleased to hear that we have been able to find two locations and hotels for 2015 NOSB Meetings.

> Late April: SanDiego - Carmela approved the choice of hotel October (28, 29, 30) - Vermont- Stowe Conference

 Center - we tried to get Burlington but most hotels are either not big enough or do not take Government per diem

 until late November. The Sheraton near the interstate may be a possibility, but there are no restaurants close by for

 lunches outside hotel. I did consult with the local organic community and the strong preference was for Stowe at

 that time of year and no-one likes the Sheraton. Stowe Conference is 40 minutes in shuttle from airport. Lots of

 close by restaurants. On a walking/bicycle path. The location should be conducive to a pleasant meeting where we

 can build partnerships amongst stakeholders (Jen is ever optimistic!). Vermonters, as you know, will come out and

 help make this a memorable week.

>

> We might want to start work on 2016 meeting locations and hotels when the flurry of summer hard work slows

 down. Because we choose smaller cities our choices are limited. But I think it is still a great idea to go around the

 US this way. And DC is very expensive anyway.

>

> Off to work!

> Dairy farm inspection

> Cheers,

> Jean

>

>

>

>

> This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

(b) (6)
From: McEvoy, Miles - AMS

To: "Jean Richardson"; "Zea Sonnabend (zea@well.com)"; "Harold Austin"; "Tracy Favre (tfavre@favrehouse.com)";

"Tom Chapman"

Cc: Arsenault, Michelle - AMS; Brown Rosen, Emily - AMS; Brines, Lisa - AMS

Subject: NOSB workplan

Date: Friday, August 21, 2015 6:25:16 PM

Dear NOSB,

At the August 14 Executive Subcommittee meeting we discussed a number of new agenda items

 that have been submitted to NOP for inclusion on the NOSB work agenda. The NOP agrees that the

 following items will be added to the work agenda:

Handling Subcommittee:

Reclassification proposals for: Alginic Acid, Xanthan Gum, Carnauba Wax, and Tocopherols-

 approved for the Oct 2015 meeting agenda

Ancillary Substance proposals: Dairy Cultures (will be part of microorganisms), Pectin, Yeast-

 approved for the Oct 2015 meeting agenda

Discussion document- Annotation change proposals for Nutrient Vitamins and Minerals- this is

 a complex topic, and the document needs more work, can be presented at the Spring 2016

 meeting if ready

Crops Subcommittee

Annotation change proposal for List 4 inerts – approved for the Oct 2015 meeting agenda

Annotation change for micronutrients - approved for Oct 2015 meeting agenda

Discussion document proposing annotation change to prohibit NPEs as inerts – this item has

 not been requested formally, we need a request for this and suggest it be presented at the

 Spring 2016 meeting if ready

NOP notes that the petition for hypochlorous acid is directed toward both crops and handling,

 so it will be added to the Crops meeting agenda for Spring 2016.

Livestock Subcommittee

NOP requests that the LS also review the hypochlorous acid petition for the Spring 2016 meeting,

 since it has uses in livestock facilities as well.

Please forward to other NOSB members.

Thank you,

Miles McEvoy

Deputy Administrator

National Organic Program

Petition against Organic Check-off: https://nofa.wufoo.com/forms/online-petitionorganic-checkoff-program/

The other side to the organic check-off: www.noorganiccheckoff.com

Website: www.nodpa.com or www.organicmilk.org

Please support NODPA's efforts! http://www.nodpa.com/donate.shtml

Find us on Facebook! www.facebook.com/pages/Organic-DairyFarmers/237021992104?ref=hl#
From: Jean Richardson

To: Brines, Lisa - AMS; Brown Rosen, Emily - AMS; McEvoy, Miles - AMS

Subject: Nosb voting style

Date: Thursday, May 14, 2015 7:22:42 AM

I would like to consider using simple hand voting in October .

Why do we do roll call?

Are we required to have a record by individual name?

Any legal reason not to do hand vote and just totals?

Cornucopia won't be able to rate our voting record!

Save time

Let me know

Thank you

Jean

Sent from my iPhone
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Automatic reply: Nosb voting style

Date: Thursday, May 14, 2015 7:22:42 AM

I am out of the office. Please contact Joan Avila at 202-720-3252, joan.avila@ams.usda.gov if

 you need immediate assistance.
From: Jean Richardson

To: COLEHOUR BONDERA

Cc: Arsenault, Michelle - AMS; tchapman@clifbar.com; ashley@arkansasegg.com; Paula Daniels

(pdaniels@goodfoodla.org); lisa@momsorganicmarket.com; Calvin Walker; Carmela Beck; Francis Thicke; Harold

Austin; Jay Feldman; Jennifer Taylor; joe.dickson@wholefoods.com; John Foster; Mac Stone; Nick Maravell; 

Tracy Favre; Wendy Fulwider; Zea Sonnabend; Brown Rosen, Emily - AMS; McEvoy, Miles - AMS; Brines, Lisa -

AMS

Subject: Re: NOSB training meeting

Date: Wednesday, November 19, 2014 7:37:48 AM

Good Grief Colehour!

Here I am trying to build collaboration.!

It seems to me to be a sensible thing to have at least the Officers of the NOSB in DC to hear 

and take part in NOP training of new board members.

New member training in DC has been done in the past.

It seems to me it would be a complete waste of valuable resources to bring 19 people to DC in 

February, not to mention a waste of their time because we were all just "trained" a year ago in 

DC.

It seems courteous and appropriate to allow the new members the same opportunity that we all

 had last February.

Regards

Jean

On Nov 19, 2014, at 12:31 AM, COLEHOUR BONDERA wrote:

Aloha Michelle,

Thank you for this message. Since I sat in on the Executive Subcommittee (ES) call of 

November 14, 2014, I was able to learn a little more about the "training meeting" mentioned

in your email (below), and would like to request some points of clarification.

It is stated (please see below) that a decision has been made to hold, "The NOSB training 

meeting for new Board members". However it is not familiar to me that this is an agreed 

upon collaborative policy, or that this exists in the NOSB Policy Procedure Manual (PPM).

Further it is not clear why the word "the" is used, which suggests that this is somehow 

standard or even required. Where is this stated as a required NOP action? Please refer us all 

to said policy.

My understanding was that in February, 2013, when NOSB members were brought to

Washington, DC, that was the first such training (at least in recent history), and that no one 

was aware of a plan to replicate. It was discussed that it might be done with some regularity, 

and several of us indicated that it might make sense for us to all (ie, the whole NOSB) get

together if legally permitted where decisions or serious opinions on subjects were not 

exchanged, which require public transparency if more than two NOSB members at one time 

in one place.

However, if there is a plan (as it appears) to provide such a training to each new NOSB 

member, then it seemed to me that the most important component in February, 2013 was 
for all of the NOSB members to be together in a non-decision making gathering. We were all 

provided with the most up-to-date and current information available from the NOP and AMS. 

That way we all could and would be on the same page for both working with one another, 

and also working with the NOP. 

Realistically any new staff at NOP, and/or any even minor changes in presentations are not 

best filtered through only some of the NOSB members and not to all. We all are aware that 

these changes happen regularly (staffing, positions, etc.) and there are several examples that 

can be cited in both Policy Memos from the NOP to the public and/or to the NOSB since the

February, 2013 training. These changes, and limitation of NOSB participation in an annual 

meeting suggests potential discrimination, which we should avoid at all costs, in my opinion.

This last point was brought home for me during the ES call when it was stated that the 

elected NOSB Officers would also be attending the training. If there is some rationale for this 

beyond representation, it is not clear, at least not to myself. There is no precedent of NOSB 

Officers providing this kind of learning and communication in a formal manner from a 

training, other than as recorded in meetings of subcommittees and at public meetings.

So then it leaves me with significant concerns, since there is no NOSB methodology in place

to be sure that all NOSB members are brought up to speed of Officer representation, and 

therefore, again, potential intended or unintended discrimination comes forth and it is a 

serious enough concern of mine that I request that any agreement of collaboration between 

the NOSB and NOP on this subject area and decisions be shared with all NOSB members 

promptly and directly, so that we are all, "playing at the same table", so to speak. Honestly 

the table is in a room and not just a phone call away as we all know through experience in 

terms of informal conversations which happen and we are all full aware would happen

without all perspectives present, as this seems to be laid forth. Required vs. Optional 

participation is a whole additional concept to consider, as well.

With sincere hopes that this makes sense, and is not seen as an attempt by myself to force all 

ongoing NOSB members to participate in a formal process that they do not see the utility or

benefits of, it is my hope to ensure that the positive and team building and working together 

aspects of such publicly-announced, all NOSB member trainings, are best able to be taken 

advantage of through efforts to meet the shared goals of the NOP and the NOSB, who can 

and will be working collaboratively, as put forth in the formation Statute, and also within 

Section V of the NOSB PPM.

Sincerely,

Colehour Bondera

 cell/text

From: "Arsenault, Michelle - AMS" <Michelle.Arsenault@ams.usda.gov>

Date: Mon, 10 Nov 2014 16:57:53 +0000

Subject: NOSB Spring 2015 Milestones

(b) (6)
Hello everyone,

I hope you are all feeling well and rested after the meeting, and for some of you, the 

looong journey home. I’m still getting caught up from last semester while trying to look 

ahead to the next. In preparation for that, below, please find the Spring 2015 

milestones. I will add this table to the Subcommittee notes.

FYI: The NOSB training meeting for the new Board members is scheduled for February

4-5 in DC. During this two day period we are planning on holding a 1 hour 

teleconference/webinar for the annual ethics training for the entire Board. I will let 

you know as soon as possible when that is scheduled.

Let me know if you have any questions, comments or corrections,

Thanks!

Michelle
From: Jean Richardson

To: Alonzo, Anne - AMS

Cc: McEvoy, Miles - AMS; Tucker, Jennifer - AMS; Brown Rosen, Emily - AMS; Tracy Favre; Harold Austin; Arsenault,

 Michelle - AMS; Swaffar Ashley; Tom Chapman; Lisa de Lima; Daniels Paula

Bcc: Eckhouse, Sara - AMS

Subject: NOSB Training

Date: Sunday, February 08, 2015 2:44:40 PM

Hi Anne

Thank you so very much indeed for kicking off the New Board Member Training for the NOSB.

Your comments were empowering, and served to remind us all of the importance of our work in maintaing the

 integrity of the organic seal and the opportunities provided by the expanding national and international organic

 markets. I know that these trainings are expensive and time consuming for NOP, but I believe that they will bring

 greater consistency to our work and foster vital collaboration between NOP and NOSB. I hope that they become an

 annual event.

Tracy and Harold and I, as the present NOSB Officers, are determined to improve our stakeholder outreach efforts

 and we have been talking at Workshops and with organizations and we make ourselves available for interviews.

 We believe that our efforts are already showing good results. Similarly, we applaud the NOP efforts to build

 partnerships with other agencies, such as EPA and NRCS. These partnerships are vital to our shared vision of a

 better future for our children and grandchildren.

Working together we can make a difference.

We look forward to a productive 2015.

Thank you

Jean
From: McEvoy, Miles - AMS

To: "Jean Richardson"

Subject: RE: NOSB time donation per week

Date: Tuesday, July 28, 2015 8:47:07 AM

Thanks. Quite variable in terms of individual time involved.

-----Original Message-----

From: Jean Richardson [mailto

Sent: Tuesday, July 28, 2015 8:44 AM

To: McEvoy, Miles - AMS

Subject: NOSB time donation per week

Hi Miles

I did a quick e-mail poll of board time to give you some idea for your NOSB new member interviews. Here is what I

 have:

Paula: I did not poll Paula, but 0 time really

Nick: an hour now and then. Attends the 2 weeks of meetings

Mac: 0 for last two years of term, except for attending meetings. Probably 12- 15 hours week while Chair.

Jennifer: No response to 2 e-mails, appears to spend an hour or so each week.

Calvin: 5-20 depending on subcommittee workloads.

Carmela: 10-15 per week, plus more time in the week before the two meetings in order to read all 1000 plus

 comments.

Lisa: She is on vacation this week, so I can only estimate about the same time as Carmela.

Francis : 3-5 hours typically, plus 10 hours week pre meeting to read comments.

Colehour: about 20 hours a week

Tracy: I'd say average 10 hrs per week on non-sunset years. It's been more than that lately. Pre meeting about the

 same but the final days before the meeting probably more like 20 hours that week. If I am lead on something big

 you can probably double that time

Zea: I tend to agree with Tracy that it has averaged about 10 hours a week in non-sunset 2017 years. This doesn't

 include things like travel time, random phone calls, networking with the stakeholders on various issues, etc. And

 then the month of the meeting it is about 20 and at the meeting itself usually 50 or more.

In this sunset 2017 year (being a subcommittee chair), that workload is about double, and especially because the

 change in the sunset process has created more work for us (especially chairs). See more about this in a subsequent

 email from me.

Harold:Let Miles know my average is between 12 - 15 in the light duty weeks (not many of these) ), 20-25 when we

 are busier & and when I was Chair of Handling (and also during open public comment period and weeks leading

 up to spring or fall meeting) it would average around 30-35 hours. If I look back an overall average for me

 personally would be 25 hrs probably on the whole per week.

Last week and a half of public comment busy, but the last two weeks going into a meeting is just crazy the time that

 is needed to try and go through all the comments properly, document prep for the meeting, question prep for oral

(b) (6)
 presenters, and final review of documents and supporting background information. Also, preparation of ensuring I

 am completely up to date on other subcommittees meeting documents ( that I am not on) to be as well informed as

 possible.

Tom: Have not heard back, but he appears to work very hard and thus he will be putting in about the same as Tracy

 and Zea, but not as much as Harold (who should get the prize!)

Jean: Typically same as Tracy and Zea, but as Chair of course there are many weeks of 20-30 hours with a couple of

 weeks of 39 hours. Reading through all of the more than 1000 public comments before each meeting, and

 synthesizing them to be able to vote sensibly, is incredibly time consuming.

There is a seasonality to the years work load but the new Sunset is a considerable increase in our workload, and so

 we have not seen as much down time.

Hope this helps.

Cheers

Jean
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Automatic reply: NOSB time committment

Date: Friday, November 07, 2014 4:38:10 PM

I am out of the office. Please contact Desiree Lee at 202-720-3252, desiree.lee@ams.usda.gov

 if you need immediate assistance.

This electronic message contains information generated by the USDA solely for the intended

 recipients. Any unauthorized interception of this message or the use or disclosure of the

 information it contains may violate the law and subject the violator to civil or criminal

 penalties. If you believe you have received this message in error, please notify the sender and

 delete the email immediately.
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Re: NOSB time committment

Date: Friday, November 07, 2014 6:15:20 PM

Yes we talked about it.

Miles V McEvoy

Deputy Administrator

USDA National Organic Program

> On Nov 7, 2014, at 1:38 PM, "Jean Richardson" < wrote:

>

> Hi Miles

> Ashley is concerned about time commitment being on 2 subcommittees.! During interview you did explain typical

 time commitment of 8 hours a week, sometimes more sometimes less, and 2 subcommittees, and maybe ad hoc and

 working groups etc/ ?... I know you did when you interviewed me. Just checking?

> Thank you

> Jean

This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

(b) (6)
From: Jean Richardson

To: Ashley Swaffar; tchapman@clifbar.com Chapman; Paula Daniels (pdaniels@goodfoodla.org);

lisa@momsorganicmarket.com de Lima

Cc: Arsenault, Michelle - AMS; Tracy Favre; Zea Sonnabend; Harold Austin; Carmela Beck

Bcc: Brown Rosen, Emily - AMS; McEvoy, Miles - AMS

Subject: NOSB subcommittee assignments

Date: Friday, November 07, 2014 5:16:54 PM

Hi Ashley, Paula, Tom and Lisa:

Thank you for your responses about subcommittees.

We should be able to get complete NOSB Subcommittee lists out on Monday or Tuesday, but in the meanwhile, I

 know you are anxious to get a better understanding of your NOSB workload, so here are you subcommittee

 assignments.

Ashley- Handling (HS) and Livestock/Aquaculture (LS)

Paula - Crops (CS) and Livestock/Aquaculture

Tom - Certification Accreditation (CACS) and Handling

Lisa - Certification and Accreditation, and Handling.

While you do not officially start your terms until January 24 2015, you may wish to sit in on the subcommittee calls

 to get a sense of what the agendas are - especially for Handing which has so many Sunset materials. November 11

 is a Federal holiday, so the first set of conference calls for these subcommittees will be November 18. Thereafter

 the calls will be as follows, with times being in ET:

1st and 3rd Tuesday

1.00 pm Handling

2.00 pm Crops

3.00pm Livestock/Aq

2nd Tuesday

1.00 pm Materials/GMO ad hoc

2.00 pm Policy Development

3.00 pm Certification

Calls start and end promptly so you can block out Tuesday afternoons accordingly.

The chairs of your subcommittees are copied here, Tracy LS; Harold HS; Carmela CACS and Zea CS.

If you choose to listen in (observer status) just announce your name so that Michelle and the Chair know you are

 there, and typically we all keep our phones on mute unless talking.

I am assuming that you have read the Policy and Procedures Manual (PPM) and are familiar with the policies on non

 public information (PPM page 8)

The PPM allows incoming members to receive subcommittee e-mails (page 21)

The call in phone number is : Passcode 

Contact any of us if you have questions at any time.

We want you to have fun!

Jean

(b) (6) (b) (6)
From: McEvoy, Miles - AMS

To: Jean Richardson; Bailey, Melissa - AMS; Brines, Lisa - AMS

Subject: RE: NOSB Public meeting feedback

Date: Wednesday, May 14, 2014 11:29:08 AM

Nice talking with you. I will schedule 8:30 am on Friday mornings (starting May 30) to check in with you on all

 things NOSB.

Let's use the term Designated Federal Officer or DFO for my position. We can more completely describe the DFO

 and NOSB chair's role as we move forward.

Miles

-----Original Message-----

From: Jean Richardson [mailto

Sent: Wednesday, May 14, 2014 11:08 AM

To: McEvoy, Miles - AMS; Bailey, Melissa - AMS; Brines, Lisa - AMS

Subject: NOSB Public meeting feedback

Hi Miles, Lisa and Melissa

I am on the phone every day with various stakeholder groups and NOSB members. Feedback on Miles' "co-chair"

 concept is actually quite good. People in the audience liked to see NOP leadership up front and available to handle

 NOP questions and rule on procedure. Is co-chair the right phraseology?. There are two functions and one chair

 for each function. Can we say that the NOP and NOSB will Chair the meeting in collaboration / collaboratively? --

--- That way we could move back and forth with chairing duties, and the NOP information pieces can be scattered

 through the 3 or 4 days with the sub committee reports.

I will be sending out e-mails to NOSB members to remind them to intervene now at sub committee levels if they

 want input into substance review or guidance etc because changes at the public meeting cannot be substantive and I

 do not want to send everything back to subcommittee!.

All for now

Jean

This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

(b) (6)
From: Jean Richardson

To: Arsenault, Michelle - AMS

Cc: Jay Feldman; John Foster; Mac Stone; Nick Maravell; McEvoy, Miles - AMS; Brown Rosen, Emily - AMS

Subject: Re: NOSB PDS meeting Monday Oct 27

Date: Friday, October 17, 2014 10:23:50 AM

Michelle 

Nick does not land till about then so let's move the PDS meeting till later that week if possible

Sorry to keep making changes but it would be good to have us all present

Thank you 

Jean

Sent from my iPad

On Oct 17, 2014, at 9:58 AM, "Arsenault, Michelle - AMS"

<Michelle.Arsenault@ams.usda.gov> wrote:

Hello folks,

On the last PDS call we discussed gathering the Subcommittee for a brief meeting at

 the fall NOSB meeting in Louisville. I have reserved the Willis Room Monday October

 27, 2014 from 3:00 - 4:00 ET.

This electronic message contains information generated by the USDA solely for

the intended recipients. Any unauthorized interception of this message or the use

or disclosure of the information it contains may violate the law and subject the

violator to civil or criminal penalties. If you believe you have received this

message in error, please notify the sender and delete the email immediately.

<mime-attachment.ics>
From: Jean Richardson

To:

Cc: Tracy Favre; Brown Rosen, Emily - AMS; Stone Mac; Jennifer Taylor; McEvoy, Miles - AMS; Arsenault, Michelle -

 AMS

Subject: Re: NOSB PDS meeting extra

Date: Thursday, July 23, 2015 8:00:37 PM

Let's at least complete our ppm review

Jean

Sent from my iPad

On Jul 23, 2015, at 7:53 PM, wrote:

Will be on call. But cannot prepare at all due to other obligations, so nothing else

 written and just talk about thoughts shared before.

Aloha,

Colehour

Sent from my iPhone

On Jul 23, 2015, at 13:12, Jean Richardson < wrote:

Yes I can be there

Jean

Sent from my iPad

On Jul 23, 2015, at 6:52 PM, Tracy Favre <tfavre@favrehouse.com>

 wrote:

Thanks. I was going to check as I hadn't heard from

 Colehour, Jennifer or Mac.

Folks please try to be on the call Tuesday.

Thanks

T

Sent from my iPad

On Jul 23, 2015, at 10:51 AM, Brown Rosen, Emily -

 AMS <Emily.BrownRosen@ams.usda.gov> wrote:

Hi, my understanding is that the LS call for the

 28th is cancelled, so we are using that slot.

 Tracy, let me know if there is any change in

 plan. Michelle is off today so I am sending this

(b) (6) (b) (6) (b) (6)
 one time invite -

Thanks,

Emily

<mime-attachment.ics>
From: McEvoy, Miles - AMS

To: Jean Richardson

Cc: Jay Feldman; Mac Stone; Nick Maravell; John Foster; Arsenault, Michelle - AMS; Brown Rosen, Emily - AMS;

Tucker, Jennifer - AMS

Subject: RE: NOSB PD-ad hoc call?

Date: Tuesday, August 12, 2014 8:44:15 AM

Hi Jean,

I will be sending out more information about this call soon. I wanted to get it on everyone’s schedule

 to start with. Thanks,

Miles McEvoy

Deputy Administrator

National Organic Program

From: Jean Richardson [mailto:

Sent: Monday, August 11, 2014 4:36 PM

To: McEvoy, Miles - AMS

Cc: Jay Feldman; Mac Stone; Nick Maravell; John Foster; Arsenault, Michelle - AMS; Brown Rosen, Emily

 - AMS; Tucker, Jennifer - AMS

Subject: Fwd: NOSB PD-ad hoc call?

Hi Miles:

Thank you for your request to consult with the Policy Development (ad hoc)

subcommittee. 

The PDS (ad hoc) has no Work plan items and no agenda. To be efficient of our

time, I would appreciate it if you could send out an agenda, attach any written

material you wish us to review, and provide an indication of your goals or

expected outcomes, before we schedule a conference call . This will help us be

able to provide you with our best advice.

Thank you

Jean

Begin forwarded message:

From: "Arsenault, Michelle - AMS"

 <Michelle.Arsenault@ams.usda.gov>

Date: August 11, 2014 2:09:09 PM EDT

To: Jay Feldman <jfeldman@beyondpesticides.org>, Jean

 Richardson < John Foster

 <jfoster@ebfarm.com>, Mac Stone <

 Nick Maravell < "Tucker, Jennifer -

 AMS" <Jennifer.Tucker@ams.usda.gov>

Cc: "Brown Rosen, Emily - AMS"

(b) (6) (b) (6) (b) (6) (b) (6)
 <Emily.BrownRosen@ams.usda.gov>

Subject: NOSB PDS call

Hello all,

Miles wanted to gather the PDS for a call, but is not available tomorrow, August 12,

 which is when we had our placeholder meeting scheduled, so I’m proposing a different

 date and time. Let me know if this doesn’t work for you and I will search for

 alternatives.

Thursday August 28, 2014 @ 12:00 ET/9:00 PT

Policy Development call

Conf Line #: 

Passcode: 

This electronic message contains information generated by the USDA solely for

the intended recipients. Any unauthorized interception of this message or the use

or disclosure of the information it contains may violate the law and subject the

violator to civil or criminal penalties. If you believe you have received this

message in error, please notify the sender and delete the email immediately.

(b) (6) (b) (6)

From: Jean Richardson

To: McEvoy, Miles - AMS; Jones, Samuel - AMS

Cc: Arsenault, Michelle - AMS; Nicole Dehne; Kirsten Bower; Brown Rosen, Emily - AMS

Subject: NOSB October

Date: Friday, July 24, 2015 11:15:54 AM

Hi Miles and everyone

I have just heard back from Chuck Ross, Vermont Secretary of Agriculture, that he will be on hand to give a

 "Welcome to Vermont" at 9 am on Monday October 26, to kick off our week in Vermont and will also attend the

 Celebration of Organic, Taste of Vermont, 25 years of OFPA, from 6-9 pm on Tuesday October 27.

Let me know if you have any questions.

I am working on the Congressional Delegation, but given the timing it is not likely

Thank you

Jean
From: Jean Richardson

To: Tracy Favre; Tom Chapman; Calvin Walker; Zea Sonnabend; Carmela Beck; Harold Austin; Lisa de Lima; Ashley

 Green; Colehour Bondera; Francis Thicke; Nick Maravell; Mac Stone (mac@elmwoodstockfarm.com); Jennifer

 Taylor; Paula Daniels

Cc: Arsenault, Michelle - AMS; Brown Rosen, Emily - AMS; McEvoy, Miles - AMS

Subject: NOSB/ES-Public Comment

Date: Sunday, July 05, 2015 10:02:29 AM

Attachments: NOSBPublicComment.doc

Hi Everyone

On Friday July 10 one of the Agenda items on the ES call will be an update on how the two webinar days will work

 in September, and to look at time allotted for public comment at the Fall meeting. Getting early word out to all our

 stakeholders is important.

Our goal is to increase the mechanisms by which we receive public comment, hence the pre-meeting 6 hours of open

 public comment, and to ensure that we have adequate public comment time at the Fall meeting while still getting

 our work done on materials etc.

In preparation for our ES call I asked Michelle to prepare a rough table of data to compare the last few meetings,

 and I have extracted some of that data into the table attached below. You can see our workload at the Stowe

 meeting will take considerable time. Can we fit in enough public comment on the Monday so we can concentrate on

 our discussions and voting for the 3 following days?

It is never easy to estimate how many will want to present public comment in person. We assumed that in

 California, as Zea noted, we would have more people. So we allotted time for 130 commenters using 5 minute

 blocks, for a total of 11 hours allotted . We actually had 124 commenters for a total of about 10 hours. Typically

 (over the previous 5 meetings) we have had 74-92 oral presentations. If we estimate 80-90 presenters in Stowe we

 would need to allot roughly 6.6 - 7.5 hours of time. I am inclined to go with the 6.6 hours and have all public

 comment on the Monday when everyone is fresh. ? What do you think?

For the Webinars we are suggesting that each person could talk for 5 minutes each (more than the 3 minutes in

 Stowe) plus questions, and thus expand public comment time overall and attract public commenters who would like

 more time and/or who prefer so save on carbon footprint and expense and not attend Stowe in person. So each of

 the 3 hour Webinars could accommodate about 20 people (40 persons total), allowing for some "wasted" time with

 chit chat and technical challenges.

As Chair in my own back yard I am hoping that the Vermont meeting will be enjoyable for all stakeholders and we

 can celebrate 25 years since OFPA.

I would appreciate your ideas and help with this.

Thank you

Jean
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Automatic reply: NOSB/ES-Public Comment

Date: Sunday, July 05, 2015 10:02:30 AM

I am out of the office. Please contact Joan Avila at 202-720-3252, joan.avila@ams.usda.gov if

 you need immediate assistance.
Table to compare public comment at recent NOSB meetings

Spring 

2012 

Albuq. 

Fall 2012 

Providence 

Spring 

2013 

Portland 

Fall 2013

Gov. 

Shutdown 

cancelled

Spring 

2014 

San 

Antonio

Fall 

2014 

L’ville

Spring 

2015 

La Jolla

Fall 2015 

Stowe

Days of 

meeting

3.5 4 3 3 3.5 3 4 4

#Proposals 

including 

Sunset 

votes

18 21 13 16 22 12 25 198 ? 

Sunset 

plus? 16 

proposals

Discussion

Docs

10 4 5 4 3 3 3 3 ?

Reports 1 3 5 4 5 2 1 1 ?

Sunset 

First 

Meeting 

Summaries

N/A N/A N/A 7 9 12 19 15

Expert 

Panels

0 2 1 0 0 0 2 1

Oral 

Comments

79 74 92 N/A 87 86 124 ? 90

Written 

Comments

1670 620 3000 0 964 1049 1233
From: Jean Richardson

To: Zea Sonnabend

Cc: Tracy Favre; Harold V. Austin IV (harolda@zirklefruit.com); Carmela Beck; Mac Stone

 (mac@elmwoodstockfarm.com); Calvin Walker; Arsenault, Michelle - AMS; McEvoy, Miles - AMS; Brown Rosen,

 Emily - AMS

Subject: Re: NOSB-Exec-Minority Opinion

Date: Sunday, March 15, 2015 2:56:23 PM

Yes the next Exec call is Friday April 10, my error.

Thank you Zea

On Mar 15, 2015, at 2:27 PM, Zea Sonnabend wrote:

> Isn't the Exec call on April 10, Friday? I cannot attend on Monday 4/13.

> Zea

>

> On Mar 15, 2015, at 9:37 AM, Jean Richardson wrote:

>

>> Hi Exec.

>> I have received written or verbal comments on Minority Opinions from every member of the Executive

 Subcommittee.

>> Based on your comments and our discussion on the March Exec call, and our informal discussion on the PDS

 call on March 10, here is a draft Interim Internal Policy/Procedure on Minority Opinions .

>> I would like us to vote on this, or an edited version, at our next Exec call on April 13.

>> Let me know what you think.

>> Be sure to re-read the PPM page 8 paragraph which reminds us how important it is to work together.

>> Thank you

>> Jean

>>

>>

>> <Minority OpinionDraftMarch15.doc>

>


From: Jean Richardson

To: Tracy Favre; Mac Stone; John Foster

Cc: Arsenault, Michelle - AMS; Brown Rosen, Emily - AMS; McEvoy, Miles - AMS

Subject: NOSB-Aquaculture

Date: Monday, September 01, 2014 10:25:26 AM

Hi Tracy, Mac, John:

As you will note from the e-mail thread below, the proposed final rule is moving along and 

may be out by February to April 2015

I would like to put on our Executive Agenda a discussion of which NOSB subcommittee 

should be dealing with aquaculture materials.

Grouping them all together as we did certainly makes sense to consider them as part of a 

system. Tracy, looking ahead does it look as though Livestock (soil based) will have plenty to

 do with Sunset materials and new petitions etc. ? We put off a lot of items to review all those 

aquaculture materials. 

My feeling is that we should create a separate subcommittee called "aquaculture".

Let me know what you think.

Thank you,

Jean

On Aug 30, 2014, at 5:13 PM, Arsenault, Michelle - AMS wrote:

FYI

From: [mailto:

Sent: Saturday, August 30, 2014 1:00 PM

To: cnelson@bonsecourfisheries.com;

ralph@aquatechnics.com; Arsenault, Michelle - AMS;

kquagrai@purdue.edu; rmayo@cccatfish.com;

rhardy@uidaho.edu;

pecosbart@windstream.net

Cc:

Subject: Fwd: proposed final rule

AWG, here is the latest on the proposed final rule for aquaculture. I am very hopeful that 

USDA can shorten their two reviews and save at least one-month. If so, we will have a very 

meaningful session at Aquaculture Americas 2015 in New Orleans. George

George S. Lockwood

PO Box 345, 8 El Robledo

Carmel Valley, CA 93924

831-659-4145 (office)

 (cell)

From:

To: Miles.McEvoy@ams.usda.gov

CC: Mark.Bradley@ams.usda.gov,

Max.Holtzman@osec.usda.gov

Sent: 8/30/2014 9:47:57 A.M. Pacific Daylight Time

Subj: Re: proposed final rule

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Miles,

Thanks for this helpful information.

Hopefully the 30 days plus 60 days within the USDA can be shortened by a month 

or at least a few weeks. If that can happen, our February session at Aquaculture 

Americas 2015 in New Orleans will be very timely.

Having a proposed rule posted for public comment before our meeting would allow

 the aquaculture community the fullest possible opportunity to creatively participate

 in this very important process and to intelligently develop meaningful comments. I 

believe that this would bring the fullest amount of credit to USDA from the 

aquaculture community, retailers, and consumers who remain very disappointed in

 progress so far.

We have lined up a number of important people from different perspectives to 

participate in our session. We will hold back on canceling this session until we 

hear further from you if, in fact, the 90 days for groups within USDA to do their 

jobs. Please keep me informed since if we have to cancel the session, we would

like to give people as much notice as possible.

Thanks again.

George

George S. Lockwood

PO Box 345, 8 El Robledo

Carmel Valley, CA 93924

831-659-4145 (office)

 (cell)

In a message dated 8/29/2014 3:22:44 P.M. Pacific Daylight Time, Miles.McEvoy@ams.usda.gov writes:

Hi George,

The proposed rule has been drafted. We are in the clearance process 

where we do not control the time frame. First there is clearance from the 

Office of General Counsel - we expect this to be complete within the next 

30 days.Next is departmental clearance which generally takes 60 days.

After that we have clearance from the Office of Management and Budget.

 They have 90 days to complete their review.

Taken all together we hope to publish a proposed rule early next year - 

sometime between February - April. It is certainly possible that the 

proposed rule will not be published by February 19. We hope it is but as I 

explain above this is outside of our control. Please understand that we 

are doing what we can to move this as quickly as possible.

In regards to the February 19 meeting we really won't know the prospects

 of publication before February 19 until we complete departmental 

clearance. We still have a ways to go with that.

Best regards,

Miles V McEvoy

Deputy Administrator

USDA National Organic Program

(b) (6)

From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Re: NOSB-Annotations

Date: Sunday, July 13, 2014 7:04:09 PM

Sure

Miles V McEvoy

Deputy Administrator

USDA National Organic Program

> On Jul 13, 2014, at 12:14 PM, "Jean Richardson" < wrote:

>

> Hi Miles

> As you know Harold is pretty keen on doing a discussion document on Annotations via the CAS committee.

> I am concerned about this. Can we be sure to talk about this before you reply to him.

> Thank you

> Jean

This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

(b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: NOSB-Annotations

Date: Monday, July 14, 2014 5:17:23 PM

Miles if you cannot call today I can make it work to take your call on Wednesday 7.30 or8am?

Jean

Sent from my iPhone

> On Jul 14, 2014, at 3:39 PM, Jean Richardson < wrote:

>

> late today would be best given my work schedule

> I am chatting with Michelle at 4 pm for about 30 mins.

> then free till 6.30 pm when I have to go out.

>

>> On Jul 14, 2014, at 3:35 PM, McEvoy, Miles - AMS wrote:

>>

>> When are you available? Early tomorrow?

>> Late today or early Wednesday?

>>

>> -----Original Message-----

>> From: Jean Richardson [mailto:

>> Sent: Sunday, July 13, 2014 12:15 PM

>> To: McEvoy, Miles - AMS

>> Subject: NOSB-Annotations

>>

>> Hi Miles

>> As you know Harold is pretty keen on doing a discussion document on Annotations via the CAS committee.

>> I am concerned about this. Can we be sure to talk about this before you reply to him.

>> Thank you

>> Jean

>>

>>

>>

>>

>> This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

>

(b) (6) (b) (6)




Hello all,

It seems to be missing a key question below about the internal dynamics within the NOSB 

that can affect our work. I know I might be out of line here, but why would you ask question 9

 which really is none of our business to know and instead ask about what might be holding us 

back from within?

On Sep 19, 2013, at 6:07 AM, Arsenault, Michelle - AMS wrote:

Dear NOSB Members,

During our Executive Committee conference call on Friday, September 13,

 we introduced Kevin Bryan, Senior Mediator at Meridian Institute.

Meridian has been retained to conduct an assessment of the processes of 

the National Organic Standards Board and its relationship with the

National Organic Program. As part of this assessment, Meridian will 

gather data from NOSB board members, key staff, and a sampling of

external stakeholders through a series of individual interviews. Meridian 

will also attend and observe the October NOSB meeting in Louisville, KY.

From this information, Meridian will offer an assessment outlining the 

strengths of the NOSB’s process, structure, meetings, and relationship

with the NOP and external stakeholders, as well as improvements that can

 build upon those strengths.

Joining Mr. Bryan on the Meridian team will be Gary Decker, Mediator, 

and Selena Elmer, Project Associate, who will help to conduct the 

interviews; Liz Duxbury, who will work with you to schedule interviews; 

and John Ehrmann, Managing Partner, who will attend the Louisville 

meeting and help in the assessment process.

The Meridian team would like to conduct as many interviews as possible 

before the Louisville meetings. Over the next few days, Liz Duxbury 

(lduxbury@merid.org) will contact each NOSB board member to schedule 

the best date and time to talk with Meridian staff. We expect the 

interviews to last between 45 – 60 minutes. All of the information from 

the interviews will be treated as confidential, and while themes from

across interviews will be presented, comments made during interviews 

will not be attributed to interviewees in the final assessment report. 

Here are some of the questions Meridian developed to help shape their 

time with you – we hope they provide some starting points for your 

thinking as you look ahead to the interviews:

1. What is your understanding of the NOSB’s roles and 
responsibilities?

2. What is your perception of the NOSB’s authority?

3. What is your perception of the NOP’s authority?

4. How would you characterize the existing relationship between

 the NOSB and the NOP? What are the strengths of that 

relationship? What improvements can be made to build on 

those strengths?

5. What is your experience with external stakeholder 

engagement?

6. What do you think of the NOP’s current level of engagement 

in directing NOSB activities?

7. In your opinion, how effective are the NOSB meetings? What 

works particularly well in the NOSB meetings? What changes,

 if any, would you use to make the NOSB meetings more 

effective?

8. How is the time between NOSB meetings used? Could that 

time be used more effectively?

9. What is your understanding of the process for writing and 

clearing rules once USDA begins rulemaking?

10. What steps could NOSB take to better align recommendations

 with the rulemaking process?

11. How do you feel that the NOSB is supported by USDA and the 

Secretary’s office?

 12. How do you think the NOSB impacts the broader organic 

movement?

Miles McEvoy

Deputy Administrator

National Organic Program

202-720-3252

This electronic message contains information generated by the USDA

 solely for the intended recipients. Any unauthorized interception of 

this message or the use or disclosure of the information it contains 

may violate the law and subject the violator to civil or criminal 

penalties. If you believe you have received this message in error, 

please notify the sender and delete the email immediately.
From: Jean Richardson

To: Kevin T.Bryan

Cc: Harold Austin; Arsenault, Michelle - AMS; COLEHOUR BONDERA; Zea Sonnabend; Tucker, Jennifer - AMS; 

McEvoy, Miles - AMS; Calvin Walker; Jay Feldman; Nick Maravell; Carmela Beck; John Foster; Tracy Favre; 

Jennifer Taylor; Mac Stone; Wendy Fulwider; Francis Thicke; joe.dickson@wholefoods.com

Subject: Re: NOSB/NOP Assessment

Date: Thursday, September 26, 2013 5:41:24 PM

Hi Kevin:

Thank you for your comments, and for "listening" to our discussion.

As you can see, we all share a deep commitment to the integrity of the organic label.

Are you at liberty to share with us which stakeholders complained about us, and what the 

substance of their complaints is?

This might help some of us as we respond to questions during our upcoming interviews.

Kind Regards,

Jean

On Sep 23, 2013, at 11:10 AM, Kevin T. Bryan wrote:

Good Morning Everyone:

We have had a chance to review some of your comments regarding the interview 

process. Our goal is to engage the NOSB members and key stakeholders through the 

interviews, and through more informal interactions at the Louisville meeting, to learn

your sense of the NOSB’s effectiveness. From these interviews and other interactions, 

we should be able to provide the NOSB with a set of recommendations that the NOSB

can own going forward.

We are certainly interested in the internal dynamics within the NOSB, and the 

responses we have seen thus far make it clear that we will hear your viewpoints on 

those dynamics. We have developed the initial set of specific questions as a 

framework to guide the discussions. As we do in any interview process, we will adjust 

the questions before our first interviews to reflect our continued learning about your

specific concerns, and we will review the questions throughout the process to make 

sure we are gathering the best data possible. During the interviews, we expect to ask 

follow up questions that seek greater understanding on issues you raise during the

interview (like internal dynamics). We also expect that we will ask some questions to 

NOSB members that may not make sense to ask external stakeholders that we

interview, and vice versa; we will adjust the interviews so that they make sense for 

particular groups of interviewees.

Just a point of clarification on Question 9 - we understand that some of the 

interviewees will know more about the rulemaking process than others. Our interest is 

to understand the diversity of understanding among the interviewees on the

rulemaking process.

We are happy to hear your views on this process. If any of you have additional 

thoughts that you would like to share, please contact me by email or phone (that

information is listed below). We are looking forward to speaking with all of you 

throughout the interview process and at the Louisville meeting.

Regards,
Kevin T. Bryan

Senior Mediator and Program Manager

Meridian Institute

1920 L Street NW, Suite 500

Washington, DC 20036

202.354.6452 office

 cell

202.354.6441 fax

kbryan@merid.org

www.merid.org

<image001.gif>

From: Jean Richardson [mailto:

Sent: Sunday, September 22, 2013 8:59 PM

To: Harold Austin

Cc: Michelle - AMS Arsenault; COLEHOUR BONDERA; Zea Sonnabend; Jennifer - AMS 

Tucker; Miles - AMS McEvoy; Calvin Walker; Jay Feldman; Nick Maravell; Carmela Beck; 

John Foster; Tracy Favre; Jennifer Taylor; Mac Stone; Wendy Fulwider; Francis Thicke; 

Kevin T. Bryan; Joe Dickson

Subject: Re: NOSB/NOP Assessment

Thank you Harold

Eloquent as always

I am canning and making jam and pies etc and was just thinking of you as I was 

making a pear and apple pie.

Yes we must remember that we have a common goal of organic agriculture

And it is interesting how much this assessment is already helping us think through

 our roles

Hope your harvest is going well

I am drowning in pears and apples this year and will make hard cider after the 

first frost

Best

Jean

Sent from my iPhone

On Sep 22, 2013, at 8:41 PM, "Harold Austin" <HaroldA@Zirklefruit.com> 

wrote:

Zea,

I would agree with your assessment of the missing question 

pertaining to the working dynamic within the NOSB and the various 

sub-committees (this is probably one of the most significant areas 

that should be looked at,as Colehour eluded to). I also would concur 

with you regarding question 9, yet I do understand the probable logic 

for it being included in the questions.

(b) (6) (b) (6)
I will go on record at this point in time to say that I fully support the 

assessment as well as the need for one being conducted. This will 

allow for a thorough review of the process, the internal workings of 

the sub-committees and that of the board, as well as the external 

influences. Here too comes into play the balance between the NOP

and the NOSB and what that functionality should look like, in order 

for both to be effective in their individual areas of responsibility. 

Hopefully, this will shed some light on this for all of us.

I would say that I do not feel that this is something being done to us, 

but rather something being done to assist us in finding ways to make 

us more efficient and ultimately more effective. Let's allow the 

process to move forward before we pass judgement on it or the 

rationale of it's existence. I would be extremely surprised if when this

 is all said and done we are not better for it, in the long run.

Just passing on the thoughts from one "harvest weary" member. I 

would also ask us all to remember that at the end of the day we are 

all trying to what we each feels is best for the organic industry, 

community, and organic as a whole!

May you each have a wonderful rest of the evening and a great start 

to the new work week that lies ahead of us,

Harold

>>> COLEHOUR BONDERA <colemel@kanalanifarm.org> 

9/22/2013 12:23 PM >>>

Aloha All -

Thank you Zea, for your note.

I do think that both your general and specific points are right on, and 

I think that such an evaluation/assessment could and should seek 

internal analysis of self and group dynamics, with results to be

considered (and made use of) for consensual changes by those who 

are members of the process in question!

Very appropriate to hear others' group input at this stage, in my 

opinion; for those who are willing to so share... Otherwise this 

process can not belong to us, but rather is something being done to us

 - as might be done in a basic laboratory review! What would best 

help the NOSB to best achieve both our statutory and internal

missions?

Colehour

From: Zea Sonnabend <zea@well.com>

and John Ehrmann, Managing Partner, who will attend the Louisville 

meeting and help in the assessment process.

The Meridian team would like to conduct as many interviews as possible 

before the Louisville meetings. Over the next few days, Liz Duxbury 

(lduxbury@merid.org) will contact each NOSB board member to schedule 

the best date and time to talk with Meridian staff. We expect the 

interviews to last between 45 – 60 minutes. All of the information from 

the interviews will be treated as confidential, and while themes from

across interviews will be presented, comments made during interviews 

will not be attributed to interviewees in the final assessment report. 

Here are some of the questions Meridian developed to help shape their 

time with you – we hope they provide some starting points for your 

thinking as you look ahead to the interviews:

1. What is your understanding of the NOSB’s roles and 

responsibilities?

2. What is your perception of the NOSB’s authority?

3. What is your perception of the NOP’s authority?

4. How would you characterize the existing relationship between

 the NOSB and the NOP? What are the strengths of that 

relationship? What improvements can be made to build on 

those strengths?

5. What is your experience with external stakeholder 

engagement?

6. What do you think of the NOP’s current level of engagement 

in directing NOSB activities?

7. In your opinion, how effective are the NOSB meetings? What 

works particularly well in the NOSB meetings? What changes,

 if any, would you use to make the NOSB meetings more 

effective?

8. How is the time between NOSB meetings used? Could that 

time be used more effectively?

9. What is your understanding of the process for writing and 

clearing rules once USDA begins rulemaking?

10. What steps could NOSB take to better align recommendations

 with the rulemaking process?

11. How do you feel that the NOSB is supported by USDA and the 

Secretary’s office?

 12. How do you think the NOSB impacts the broader organic 

movement?

Miles McEvoy
Deputy Administrator

National Organic Program

202-720-3252

This electronic message contains information generated by 

the USDA solely for the intended recipients. Any 

unauthorized interception of this message or the use or 

disclosure of the information it contains may violate the law 

and subject the violator to civil or criminal penalties. If you 

believe you have received this message in error, please notify 

the sender and delete the email immediately.

From: Jean Richardson

To: Arsenault, Michelle - AMS

Cc: Calvin Walker; Carmela Beck; Colehour Bondera; Francis Thicke; Harold Austin; Jay Feldman; Jennifer Taylor;

joe.dickson@wholefoods.com; John Foster; Mac Stone; Nick Maravell; Tracy Favre; Wendy Fulwider; Zea

 Sonnabend; McEvoy, Miles - AMS; Bailey, Melissa - AMS; Rakola, Betsy - AMS

Subject: Re: October 16 Listening Session and Memo to the National Organic Standards Board

Date: Wednesday, October 08, 2014 9:06:37 AM

Hi Team!

If possible I think it would be great if as many of us NOSB members could listen in on this

 Session.

Thank you

Jean

Sent from my iPad

On Oct 8, 2014, at 8:58 AM, "Arsenault, Michelle - AMS"

 <Michelle.Arsenault@ams.usda.gov> wrote:

All – The attached memo and the following message will be sent out through the

Organic insider this afternoon – we wanted to give you an advanced look at what we

will be sending....

USDA’s Agricultural Marketing Service (AMS) is pleased to announce a memo from the

National Organic Program (NOP) to the National Organic Standards Board (NOSB) as

well  as an upcoming phone/online listening session.

NOP Hosts Listening Session on NOSB: October 16

On Thursday, October 16, 2014 from 3:00-5:00 PM Eastern Time, NOP will host a

listening session focusing on the NOSB, a federal advisory committee that provides

recommendations to USDA. The NOP is seeking comments on NOSB administrative

procedures including public participation opportunities, the petition process, and

sunset review process. More information on NOSB administrative procedures can be

found in the NOSB Policy and Procedures Manual, National Organic Standards Board

Presentation, Petition Process, and Sunset Review Process.

The NOP will open with a short presentation, afterwards participants will be able to

provide comments to the NOP. Participants wishing to provide comments will then

indicate to the call operator their interest in speaking. Each person will be given 3

minutes to share his or her comment. We will take as many comments as we can until

the call ends at 5 PM Eastern Time.  The NOP will issue a summary of the listening

session after the call. 

Pre-registration is not required for this listening session. To participate:
Thursday, October 16, 2014 – 3-5 PM Eastern

Memo to NOSB on Sunset Review Process

The NOP has issued a memo to the NOSB clarifying the process to be followed for the

Sunset Review of the National List of Allowed and Prohibited Substances (National

List).  (Attached)

This electronic message contains information generated by the USDA solely for

 the intended recipients. Any unauthorized interception of this message or the use

 or disclosure of the information it contains may violate the law and subject the

 violator to civil or criminal penalties. If you believe you have received this

 message in error, please notify the sender and delete the email immediately.

<2014-Sunset-Clarification-Final.pdf>

(b) (6)
From: Jean Richardson

To: Swaffar Ashley; Daniels Paula; Chapman Tom; Lisa de Lima

Cc: Tracy Favre; Harold Austin; Mac Stone; Francis Thicke; Walker Calvin; Colehour Bondera; Jennifer Taylor; Nick

 Maravell; Carmela Beck; Zea Sonnabend

Bcc: Brown Rosen, Emily - AMS; Arsenault, Michelle - AMS; McEvoy, Miles - AMS; Tucker, Jennifer - AMS

Subject: NOSB-New Year begins - Chair"s Welcome

Date: Saturday, January 24, 2015 1:10:38 PM

Hi Everyone:

First let me welcome Ashley, Tom, Lisa and Paula to the NOSB as the new term begins.

You will find us an opinionated, knowledgeable, outspoken, hardworking bunch who represent the organic

 community with passion and integrity. We work together with a good sense of humor! We try always to work

 toward consensus where possible, respecting and learning from the different perspectives we each bring to the table

 as we do Sunset Review and develop Advice for the Secretary. - Yes I sound like a Girl Scout!

You are joining the NOSB at a time when the volunteer Board has probably never had such a large and complex

 workload. All the easy work has been done - so to speak!. And, assuming we are Asking the Right Questions, there

 are no simple yes and no answers for us to quickly give. In addition, all of the procedures for Review of Sunset

 materials, our primary mandate under OFPA, have changed. Procedures and "templates" for tracking materials from

 past into the future are new and being piloted by us for the first time. So right now things may seem to you to be a

 bit overwhelming, time consuming to understand, and complex. The NOP and NOSB hope that the new procedures

 will provide a much more transparent process for the public. As you know, we now seek public comment in a two

 step process of Meeting One, Initial Review, with questions, and Meeting Two when we will vote as a whole Board

 on each material. Every material and topic for Discussion or Proposal and Recommendation, requires our careful

 and detailed analysis. The devil is in the details! We are still a "grass roots" kind of Board, not a "rubber stamp"

 Board!

This means that the Handling, Livestock and Crops subcommittees are meeting every week instead of every other

 week, and there are many e-mails and documents pouring into our e-mail boxes! We are working to a deadline of

 February 25 when all of the NOSB written documents must be in Michelle's hands in order for her and other NOP

 staff to get them all in the format for posting on the Federal Register on March 9 to bring us within the required 45

 days before the April meeting in San Diego.

So the NOSB has a lot of work to complete in the next 4 weeks. Then, from February 25 until April 13, while we

 wait for public comment, we will just do our regular committee work and it will seem more quiet and much less

 time consuming and even relaxed!. Then we read and analyze public comments in mid April and gear up for the

 week of the April Meeting. Then it will be somewhat quiet before we have to face all the Sunset materials to be

 readied for the Second meeting in order to vote on Sunset 17 materials and Petitions at the October Meeting in

 Vermont. Then it will be "relatively" slower as we move into Holiday Season and a new year with the next set of

 new members!

We all of us are assigned or volunteer as a lead person for materials or topics in our subcommittees with many

 weeks or months of notice. So, in theory, it should be easy to plan our time between paid work, volunteer work and

 family/recreation. We all understand that life can interfere with our best intentions! ... And so we try to function

 as a team of 15 where another person can take over some of the work of another board member when we have a

 Federal deadline which must be met.

Some board members assume that there will be an ice storm, power outage, sick cows, sick family member,

 computer crash, and that their work will always takes longer than initially thought! ... This type of person gets

 NOSB work done and sent out to the committee early. Other Board members appear to love that Adrenalin rush

 that comes from procrastination ! , and they turn stuff in at the 11th or 12th hour, which makes it very difficult for

 others to read it before the discussion on our very short calls. ! We each of us know our preferred style of

 operating! --- So please ask for help early rather than at the last minute, and please, only take on what you believe

 you can realistically do given your work, personal life, and other commitments....

My apologies if this e-mail seems redundant, but having been on the NOSB for 3 years I feel that I should be sure
 that I have opened the door for discussions on volunteer workload and expectations at the very beginning of your

 tenure. Five years is a long time, and a volunteer Board should be lots of Fun!

I am really enjoying my time on the NOSB. We get to know each other pretty well and there is a lot of give and

 take. We will all miss John, Joe, Jay and Wendy who have just finished their terms. We also work really hard to

 collaborate with the NOP and work as closely as possible with NOP staff. They are an amazing group of people. I

 love the mix of science, policy, agriculture, certification, law, politics and people! . Challenges on every front!

I sincerely hope that you will enjoy being on the NOSB as much as I do.

Contact me any time with questions or concerns

Welcome.

Jean

 (home/Office -Land Line)

 (Mobile and Text)

(b) (6) (b) (6) (b) (6)
From: Jean Richardson

To: lisa@momsorganicmarket.com; ashley@arkansasegg.com; Tom Chapman; Paula Daniels

Cc: Arsenault, Michelle - AMS; McEvoy, Miles - AMS

Subject: NOSB-Mentor

Date: Tuesday, October 14, 2014 10:14:19 AM

Good morning Lisa, Ashley, Paula and Tom:

I hope that you are getting to know some of the NOSB members, and familiarize yourselves with the OFPA, PPM

 and present Workplans and agendas of subcommittees.

You can of course chat with any of us at any time, but we also have a mentoring program in place.

So, Pursuant to the Policy and Procedures Manual (PPM) could you please let me know which of the NOSB

 members you would like to act as a mentor to you as you transition onto the Board.

If you are not sure, or would prefer the Chair to assign someone, just let me know and I will do so.

Please let me know your mentor preference by October 16 if possible. And let me know if you have any questions

 about the mentoring program.

Thank you

Jean

 (home/office)

 (mobile voice and text)

(b) (6) (b) (6) (b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS; Brown Rosen, Emily - AMS; Zea Sonnabend

Subject: Fwd: OFPA/USDA Compost standards

Date: Wednesday, April 22, 2015 1:52:07 PM

Attachments: image.png

2011 NOP compost guidance.pdf

Hi all

I know that NOP cannot say anything since the case is in court, but FYIWendy Sue Harper has a PhD in Soil Science, and Steve Wissbaum is a major organic

 compost producer

I gor these e-mails today

Jean

Begin forwarded message:

From: Wendy Sue Harper <wsh@gmavt.net>

Date: April 22, 2015 1:38:49 PM EDT

To: Pat Sagui <pats@gaw.com>

Cc: Steven Wisbaum <steven@cvcompost.com>, Wendy Sue Harper

 <wsh@gmavt.net>, "Richardson, Jean"

 <

Subject: Re: OFPA/USDA Compost standards

Hi Pat,

This is the first I have heard of CFS suing USDA about the 2011 NOP Green

 Waste guidance document (attached). It does not appear to me to have much

 merit as the NOP has always been a process based program with excluded

 methods. It does require some testing by certifying agencies for synthetic

 pesticides on organic produce, but it is not a testing based program. VOF has not

 discussed it with inspectors, but we do not meet until next month for updates. 

I am including Jean Richardson here as an FYI to her because she chairs the

 NOSB, which is mentioned in Steve's email. Jean if you have anything to add

 please do so.

However, that said the outcome of the lawsuit could impact composters so

 perhaps it should be on the Compost Association of Vermont's meeting agenda

 for 4/30 as an issue to watch.

Steven should take the lead on this agenda item, because he sent it to you. I would

 be happy to provide my 2 cents as always.

Best regards,

Wendy Sue

************************************

Wendy Sue Harper

(b) (6)
Bristol, VT 05443

wsh@gmavt.net

************************************

On Wed, Apr 22, 2015 at 10:33 AM, Pat Sagui <pats@gaw.com> wrote:

Hi Wendy Sue, see below from Steve Wisbaum, a CAV composter. Should we

 reserve a few minutes on the 4/30 agenda for you to give a brief update?

Begin forwarded message:

Date: April 21, 2015 at 1:20:50 PM EDT

Subject: FW: OFPA/USDA Compost standards 

From: Steven Wisbaum <swisbaum@gmavt.net>

To: <cultivate@cornucopia.org>, Dan Goossen

 <Dan@greenmountaincompost.com>, Tom Moreau <tmoreau@cswd.net>, Pat

 Sagui <pats@gaw.com>, <vof@nofavt.org>

All,

 The following press release was just came to my attention and I

 thought you might be interested in my response (pasted below)

 regarding the implications for the use of compost. 

http://www.centerforfoodsafety.org/press-releases/3847/cfs-and-allieschallenge-organic-loophole-for-pesticides-in-compost#

 <http://www.centerforfoodsafety.org/press-releases/3847/cfs-and-allieschallenge-organic-loophole-for-pesticides-in-compost> 

------ Forwarded Message

From: Steven Wisbaum <swisbaum@gmavt.net>

Date: Tue, 21 Apr 2015 13:08:16 -0400

To: <office@centerforfoodsafety.org>

Cc: 

Conversation: OFPA/USDA Compost standards 

Subject: OFPA/USDA Compost standards 

To whom it may concern,

 My name is Steven Wisbaum. For a little background, I’ve been a

 proponent, small-scale producer, and consumer of organic food for over

 three decades. I also worked as an independent organic certification

 inspector for farms and processors in the western US, the mid-west,

 and Vermont and New York State from around 1992 to 1996. During

 that time I was a major contributor to some of the first formal organic

 inspector training manuals for the Independent Organic Inspectors

 Association (IOIA) and also advocated for substantial changes in the

(b) (6) (b) (6)

------ End of Forwarded Message
United States Department of Agriculture 1400 Independence Avenue SW. NOP 5016

Agricultural Marketing Service Room 2646-South Building Effective Date: July 22, 2011

National Organic Program Washington, DC 20250 Page 1 of 3

Original Issue Date: 04/19/10 Authorized Distribution: Public

File Name: NOP 5016 Allowance of Green Waste Rev01 07 22 11 

Guidance 

Allowance of Green Waste in Organic Production Systems

1. Purpose 

This guidance provides clarification on the allowance of green waste and green waste compost in 

organic production systems under the National Organic Program (NOP) regulations. 

2. Scope

This guidance applies to National Organic Program (NOP) certifying agents and all certified and exempt 

organic producers. 

3. Background 

The Organic Foods Production Act of 1990 (OFPA), 7 U.S.C. Section 6501, et. seq., as amended, as 

implemented in 7 CFR Part 205, the NOP Final Rule, regulates the production, handling, processing, 

and labeling of all raw or processed agricultural products to be sold, labeled, or represented as organic in 

the United States. 

The NOP regulations support the use of composted plant and animal materials to maintain or improve 

soil organic matter. According to § 205.203(c): 

“The producer must manage plant and animal materials to maintain or improve soil organic 

matter content in a manner that does not contribute to contamination of crops, soil, or water by 

plant nutrients, pathogenic organisms, heavy metals, or residues of prohibited substances.” 

In 2009, the California Department of Food and Agriculture (CDFA) found bifenthrin residues in 

samples of three different commercial green waste composts. Bifenthrin is a synthetic pyrethroid 

insecticide that is prohibited under the NOP regulation. Acting under their authority as a State organic 

program and under advisement from the NOP, CDFA advised organic producers and accredited 

certifying agents in California that these three green waste composts were not allowed to be used in 

organic crop production. 

In the fall of 2009, the NOP sent a draft policy to accredited certifying agents that addressed pesticide 

residues in compost. We received six comments, all of which urged the NOP to take an alternative 

approach. In January 2010, a meeting was held in Monterey, California to discuss the draft policy and 

other alternatives.

In March 2010, the NOP received compost test results from CCOF, an accredited certifying agent. 

Samples were collected from crop fields where green waste compost had been applied in July 2009, at 

the rate of 5-6 tons per acre. The green waste compost had been tested in December 2009 and showed 
United States Department of Agriculture 1400 Independence Avenue SW. NOP 5016

Agricultural Marketing Service Room 2646-South Building Effective Date: July 22, 2011

National Organic Program Washington, DC 20250 Page 2 of 3

Original Issue Date: 04/19/10 Authorized Distribution: Public

File Name: NOP 5016 Allowance of Green Waste Rev01 07 22 11 

bifenthrin residues of 0.09 ppm. Bifenthrin residues were not detected in any of the soil or crop 

samples, collected in February 2010, at a limit of detection of 0.01 ppm. 

After considering comments and the sample results, the NOP is providing this information to certifiers, 

certified producers and other interested parties concerning the use of green waste and green waste 

compost in organic production systems.

4. Policy

For the purpose of this guidance, the following definitions shall apply: 

Green waste: Biodegradable waste that can be composed of garden or park waste, such as grass or 

flower cuttings and hedge trimmings, as well as domestic and commercial food waste. Green waste is 

often collected in municipal curbside collection schemes or through private waste management 

contractor businesses. 

Feedstocks: Bulk raw materials that are mixed together during the composting process. 

Approved feedstocks for compost include: 

1. Plant and animal materials, such as, crop residues, animal manure, food waste, yard waste;

2. Nonsynthetic substances not prohibited by § 205.602; 

3. Synthetic substances specifically allowed for use as a compost feedstock per § 205.601. 

Compost that is produced with prohibited feedstocks such as urea, recycled wallboard, or sewage sludge 

is prohibited. The NOP does not allow the use of compost that contains synthetic substances that are not 

on the National List. Section 205.203(e) states: 

“The producer must not use: (1) Any fertilizer or composted plant and animal material that 

contains a synthetic substance not included on the National List of synthetic substances allowed 

for use in organic crop production;” 

However, the NOP regulations were established with recognition that background levels of synthetic 

pesticides may be present in the environment and, therefore, may be present in organic production 

systems. This is referred to as unavoidable residual environmental contamination (UREC) in the 

regulations. Furthermore, the NOP standards are process based and do not mandate zero tolerance for 

synthetic pesticide residues in inputs, such as compost. Compost that is produced from the approved 

feedstocks, listed above, is acceptable for use in organic production, provided that any residual pesticide 

levels do not contribute to the contamination of crops, soil or water. 

Green waste and green waste compost that is produced from approved feedstocks, such as, non-organic 

crop residues or lawn clippings may contain pesticide residues. Provided that the green waste and green 

waste compost (i) is not subject to any direct application or use of prohibited substances (i.e. synthetic 

pesticides) during the composting process, and (ii) that any residual pesticide levels do not contribute to 

the contamination of crops, soil or water, the compost is acceptable for use in organic production. 
United States Department of Agriculture 1400 Independence Avenue SW. NOP 5016

Agricultural Marketing Service Room 2646-South Building Effective Date: July 22, 2011

National Organic Program Washington, DC 20250 Page 3 of 3

Original Issue Date: 04/19/10 Authorized Distribution: Public

File Name: NOP 5016 Allowance of Green Waste Rev01 07 22 11 

5. References

§ 205.2 Terms Defined 

Compost. The product of a managed process through which microorganisms break down plant and 

animal materials into more available forms suitable for application to the soil. Compost must be 

produced through a process that combines plant and animal materials with an initial C:N ratio of 

between 25:1 and 40:1. Producers using an in-vessel or static aerated pile system must maintain the 

composting materials at a temperature between 131 °F and 170 °F for 3 days. Producers using a 

windrow system must maintain the composting materials at a temperature between 131 °F and 170 °F 

for 15 days, during which time, the materials must be turned a minimum of five times.

Other Definitions

Green waste: Biodegradable waste that can be composed of garden or park waste, such as grass or 

flower cuttings and hedge trimmings, as well as domestic and commercial food waste. Green waste is 

often collected in municipal curbside collection schemes or through private waste management 

contractor businesses. 

Feedstocks: Bulk raw materials that are mixed together during the composting process. 

Organic Foods Productions Act (1990 as amended)

7 U.S.C. 6501, et seq. 

NOP Regulations (as amended to date)

7 CFR § 205.203 Soil fertility and crop nutrient management practice standard. 

(c) The producer must manage plant and animal materials to maintain or improve soil organic matter

content... 

(e) The producer must not use:... 

7 CFR § 205.601 Synthetic substances allowed for use in organic crop production. 

7 CFR § 205.602 Nonsynthetic substances prohibited for use in organic crop production. 

Approved on July 22, 2011 
From: McEvoy, Miles - AMS

To: "Jean Richardson"

Subject: OMRI newsletter re iodine

Date: Friday, June 26, 2015 9:00:41 AM

Attachments: Newsletter-Summer-2015.pdf

Miles McEvoy

Deputy Administrator

National Organic Program
From: Jean Richardson

To: Chuck Ross

Bcc: McEvoy, Miles - AMS

Subject: Fwd: Organic at NASDA meeting

Date: Saturday, August 30, 2014 10:13:09 AM

Hi Chuck

This is to introduce you to Betsy Rakola from AMS

I have worked with her a bit in my capacity as an inspector, and also as NOSB Chair.

It would be great if we can ensure that Betsy meets all the right people at the NASDA 

meeting, so I thought that I would forward her message to you.

Cheers,

Jean

Begin forwarded message:

From: "Rakola, Betsy - AMS" <Betsy.Rakola@ams.usda.gov>

Date: August 27, 2014 9:34:23 AM EDT

To: Jean Richardson <

Subject: RE: Organic at NASDA meeting

Hi Jean,

Thanks again for chatting this morning. I’ll be at the NASDA meeting all day Thursday 

the 11th and most of Friday the 12th, leaving around 3:30. As the new Organic Policy 

Advisor, my priorities are to integrate organic throughout USDA programs, ensure that 

USDA implements Farm Bill programs for organic, and increase education and outreach

 with the goal of growing the organic sector.

I’m hoping to connect with stakeholders at the NASDA meeting, both public and 

private, to learn about their interests. We’ve also had some challenges getting states 

re-enrolled in the organic certification cost share program, so I’ll be plugging that as 

well.

Best,

Betsy Rakola

Organic Policy Advisor, USDA Agricultural Marketing Service

Tel 202-604-5693

www.usda.gov/organic

From: Jean Richardson [mailto:

Sent: Tuesday, August 26, 2014 7:22 AM

To: Rakola, Betsy - AMS

Subject: Re: Organic at NASDA meeting

Hi Betsy

(b) (6) (b) (6)
happy to chat

Does Wednesday morning this week work for you?

Say 9 am?

call my home land line: 

Jean

On Aug 25, 2014, at 1:08 PM, Rakola, Betsy - AMS wrote:

Dear Jean,

I hope you’re doing well. We met briefly in April during a witness inspection of Highland

 Sugarworks in Websterville, and I recently shifted to a new role as the USDA Organic 

Policy Advisor. I’ll replace Mark Lipson once his term ends in September, and we’ll 

overlap until then.

Miles has asked me to attend the NASDA meeting in a couple of weeks to connect with 

you and other stakeholders, as well as to learn about the group’s work. It would be 

great to talk with you briefly to find out what the hot topics are at the meeting. Do you 

have 15 minutes free sometime this week or next?

Best regards,

Betsy Rakola

Organic Policy Advisor

USDA Agricultural Marketing Service

1400 Independence Ave., SW

Washington, DC 20250-0268

Tel 202-604-5693

Fax 202-205-7808

betsy.rakola@ams.usda.gov

www.usda.gov/organic

This electronic message contains information generated by 

the USDA solely for the intended recipients. Any 

unauthorized interception of this message or the use or 

disclosure of the information it contains may violate the law 

and subject the violator to civil or criminal penalties. If you 

believe you have received this message in error, please notify 

the sender and delete the email immediately.

(b) (6)

It has been an eventful few weeks since I sent out the last update. I have 

gotten a wave of response from my letter, and I am sharing just a few 

notes from others at the bottom of this letter.

Several of you have written Miles urging him to change the criteria for 

membership on the task force. You asked it to be a more honest 

representation of the organic community. So far he has declined. I fear 

that even if Miles does change the official criteria, he has shown where 

his true intentions lie, and he will pack the task force with hydroponic

advocates. A much better way to go forward would be for Miles to send 

the 2010 recommendation back to the NOSB for clarification on the 

points that he finds too vague. The NOSB was also hand picked by Miles

 and his predecessor, but it certainly is a better representation of the 

organic community than a cherry picked task force.

I am pleased to hear that the issue is in on the agenda for the next 

Interstate NOFA council meeting. It is also being put forward for further

action by the National Organic Coalition.

And finally, the Cornucopia Institute just issued a white paper and an 

article in their spring newsletter on the issue of hydroponic organic 

certification. Check out these links:

http://www.cornucopia.org/HydroponicsWhitePaper.pdf

http://www.cornucopia.org/2015/03/hydroponics-organic/?

utm_source=enews&utm_medium=email&utm_content=3-14-

15&utm_campaign=Hydroponics.MORE

It is wonderful to see so many people springing to action on this issue.

Many thanks

Dave Chapman

Begin forwarded message:

From: Abby Youngblood <abby@nationalorganiccoalition.org>

Date: March 12, 2015 10:43:02 AM EDT

To: Steve Gilman <

Subject: Re: [NOC-members] Fwd: An update on "organic hydroponic"

Dear Steve,

(b) (6)
Thank you so much for this background information - seems like an important issue for 

NOC to continue to take a stance on for multiple reasons. First, because having hydroponic 

that is not true to organic principles threatens organic integrity, but also because NOP is 

disregarding NOSB recommendations here (once again!). I understand Dave's frustration.

Let's add this to our list of topics for the April call....and I will touch base with Steve E. on it

 as well. Let me know if there are other concrete things you think we should do to support 

Dave's efforts.

Abby

On Wed, Mar 11, 2015 at 6:13 PM, Steve Gilman < wrote:

Hello NOC members,

Please spend a few minutes reviewing today's message (at the bottom) from VT farmer 

Dave Chapman who objected last year to the wave of "certified organic hydroponic 

tomatoes" from Mexico that he has to compete with in the VT marketplace. You'll recall 

he's led the charge against some top-down rulings by NOP that ignored NOSB's wellvetted 2010 recommendations -- and are allowing certification of "organic hydroponic".

NOC took up the discussion and last year, after protracted discussion, on Feb 7, 2014 NOC

 issued a position paper "NOC Position on Hydroponic Production" affirming soil-based 

organic agriculture and concluded:

"Until a clear definition has been provided by the NOP, certifiers should not be allowed to 

certify hydroponic systems. Certifiers need to be directed as to which systems may be 

certified, and which do not meet the criteria and are not eligible for organic certification. 

NOC urges the NOP to write “NOP Instruction to Certifiers” that leads to Rulemaking. The 

instruction should include clear criteria that follow the NOSB 2010 recommendation, and 

adhere to the definition of organic production presented in the Rule. "

However, just recently AMS put out a call for nominations for a Task Force on organic 

hydroponics (see below). The NOFAs are interested in nominating and gaining support for

 Dave Chapman as he is very articulate, knowledgable and highly committed -- and this 

would be a good way of re-opening the discussion and holding up such rulings to a greater 

transparency in the public eye.

However, when digging in deeper Dave discovered the fine print reveals that the only 

farmers eligible to serve on the Task Force are experienced hydroponic growers (!) -- 

producing a sham board that purposely negates one side of the debate and serves to further 

legitimize NOP's previous unilateral action to allow the certification of organic ingredient 

hydroponics.

You'll see in his letter Dave is clearly weary of fighting these organic integrity battles. He 

also has a farm to run. He is still willing to take this on, however, but needs organic 

community support -- and some more nominations for soil-based growers to help call the 

question.

It would be great to put this on the NOC discussion agenda.

Much Thanks,

Steve

(b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: Oral public comment

Date: Saturday, June 27, 2015 11:34:54 AM

Today?

Sent from my iPhone

On Jun 27, 2015, at 10:04 AM, McEvoy, Miles - AMS <Miles.McEvoy@ams.usda.gov> wrote:

I spoke with paula. Give a call when you have some time.

Miles V McEvoy

Deputy Administrator

USDA National Organic Program

> On Jun 27, 2015, at 9:50 AM, "Jean Richardson" < wrote:

>

> Hi Miles

> I just had a long conversation with Ed Maltby of NODPA. This was very helpful. He is logical and understands

 the nuances. He was in DC and met with Anne Alonzo separately apparently as well as with the NOC group etc.

> He had some useful suggestions, one of which will not be popular! But I am agreeing that we should do a Monday

 evening oral comment public session on the first Monday of the October meeting. So the Monday will be mostly

 Public oral comment. I explained that I could not force all NOSB volunteers to keep going after a dinner break, till

 9 or 10 pm! but we will do it this once so we can get on and complete Sunset and other NOSB work. Michelle

 will really complain about the workload and I cannot blame her, but just this once.

> I will be drafting some language for "damage control" (so Ed calls it) for springing the Webinar idea on the world

 this week!!!!

> - He also suggests that we NOSB members should be getting a per diem for our actual time spent, and I agree with

 that!!!

> More tomorrow when it is raining and I can be at my desk and draft language for the Webinar announcement

 which should be a joint NOSB/NOP announcement to show that the NOSB is not being controlled by the NOP.

> Cheers

> Jean

>

>

(b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: Oral public comment

Date: Saturday, June 27, 2015 5:35:15 PM

Ok Paula called

Very pleasant conversation

I am taking her off all sub committees

Call if you want to chat

Jean

Sent from my iPhone

On Jun 27, 2015, at 10:04 AM, McEvoy, Miles - AMS <Miles.McEvoy@ams.usda.gov> wrote:

I spoke with paula. Give a call when you have some time.

Miles V McEvoy

Deputy Administrator

USDA National Organic Program

> On Jun 27, 2015, at 9:50 AM, "Jean Richardson" < wrote:

>

> Hi Miles

> I just had a long conversation with Ed Maltby of NODPA. This was very helpful. He is logical and understands

 the nuances. He was in DC and met with Anne Alonzo separately apparently as well as with the NOC group etc.

> He had some useful suggestions, one of which will not be popular! But I am agreeing that we should do a Monday

 evening oral comment public session on the first Monday of the October meeting. So the Monday will be mostly

 Public oral comment. I explained that I could not force all NOSB volunteers to keep going after a dinner break, till

 9 or 10 pm! but we will do it this once so we can get on and complete Sunset and other NOSB work. Michelle

 will really complain about the workload and I cannot blame her, but just this once.

> I will be drafting some language for "damage control" (so Ed calls it) for springing the Webinar idea on the world

 this week!!!!

> - He also suggests that we NOSB members should be getting a per diem for our actual time spent, and I agree with

 that!!!

> More tomorrow when it is raining and I can be at my desk and draft language for the Webinar announcement

 which should be a joint NOSB/NOP announcement to show that the NOSB is not being controlled by the NOP.

> Cheers

> Jean

>

>

(b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS; Brown Rosen, Emily - AMS

Subject: Fwd: Organic down grade question

Date: Tuesday, November 11, 2014 1:12:39 PM

Attachments: Happy Baby Toddler Milk Ingredients List.tiff

Happy Baby Toddler Milk.tiff

A Deep Dive Into Chicken Labels.pdf

Antibiotics in Poultry Loophole Letter Dec 2013 FINAL.pdf

Hi Miles and Emily

here is what Urvashi Rangan sent me in connection with my question

FYI, Jean

Begin forwarded message:

From: Urvashi Rangan <urangan@consumer.org>

Date: November 3, 2014 8:21:25 PM EST

To: Jean Richardson <

Subject: Re: Organic down grade question

Hi Jean,

Thanks for your email and it was also good to see you and your new

 role as Chair. Max really enjoyed his experience and thank you for

 welcoming him there. He said he was inspired by I appreciate your

 concern about the rating downgrade of organic. As you'll see in the

 detailed record, 100% organic is still highly meaningful but

 "organic" is now rated as meaningful. So I've given you #1-a link to

 the full label rating record for USDA organic, #2-an excerpt as to

 specifically why we downgraded the ratings and #2-a link to our

 label ratings for poultry production practices and how organic

 stacks up to other labels in very specific production practice areas.

 Then there are four attachments:

1. our chicken labels chart--you can see where organic nets out

 compared to others labels across production practices

2. happy baby toddler formula-front of package

3. happy baby toddler formula-back of package

4. our letter to usda on organic poultry loopholes. They did respond

 and i can scan and send the letter but it basically says that is an

 issue for Congress, not them. We disagree but I need more legal

 analysis there.

I also have some petitions into the FTC on organic personal care

 products potentially misleading and how USDA should include

As always, I (and Charlotte) would be happy to discuss anything in

 these records with you or answer questions you have.

Best,

Urvashi

(b) (6)
1. http://www.greenerchoices.org/eco-labels/label.cfm?

LabelID=151&searchType=Label&searchValue=organic&refpage=lab

elSearch&refqstr=label%3Dorganic%26pagenumber%3D5

2. Recent Inconsistencies Unresolved

Inconsistencies for poultry and eggs: The Organic Foods Production

 Act of 1990 and the USDA regulations explicitly prohibit continuous total

 confinement of organic animals, and require that year-round ACCESS

to the outdoors be granted. However, the USDA has failed to enforce this

 standard for poultry, and continues to allow a number of industrial-scale

 producers who have built covered porches as "outdoor access,"

 inaccessible to the majority of the birds, to label their poultry products

 "organic."

Inconsistencies for personal care and cosmetics: Personal care

 products can display the USDA Organic seal if they meet all the

 requirements in the federal organic regulations for food. However, unlike

 foods, non-food products can claim to be "organic" without being certified

 to the USDA organic standards, without facing enforcement action from

 the USDA. (Insert link to Organic personal care product label records) For

 non-food products, consumers should look specifically for the USDA

 Organic seal.

Inconsistencies for ANTIBIOTIC use: There is a legal allowance for

 use of ANTIBIOTICS in poultry hatcheries, where antibiotics can be

 administered in the egg and on the first day of the chicks' life.

Inconsistencies for artificial ingredient approval: While artificial

 ingredients were supposed to be approved for a five-year period and then

 "sunset," there have been a number of cases where these ingredients

 have been relisted or their use extended well beyond five years, even

 when human or environmental concerns have been raised. Urvashi

 addition that is not on website but testified that: We have identified an

 organic toddler formula on the market that has 6 of the ingredients that

 the NOSB voted down at the Providence meeting.

On Mon, Nov 3, 2014 at 12:31 PM, Jean Richardson

 < wrote:

Hi Urvashi.

Nice to see both you and Max at the NOSB meeting.

Can you send me the best information that helps me understand the scope of

 issues that resulted in your down grade of the Organic Seal.

I would like to work on this very serious issue

Many thanks

Jean Richardson

(b) (6)
-- 

Urvashi Rangan, Ph.D.

Director, Consumer Safety and Sustainability

Consumer Reports

101 Truman Avenue

Yonkers, New York 10703

urangan@consumer.org

sign our petition to ban the "natural" label -- www.takepart.com/food-labels

*****

This e-mail message is intended only for the designated 

recipient(s) named above. The information contained in this e-mail 

and any attachments may be confidential or legally privileged. If 

you are not the intended recipient, you may not review, retain, 

copy, redistribute or use this e-mail or any attachment for any 

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received this e-mail in error, please immediately notify the sender

 by reply e-mail and permanently delete this e-mail and any 

attachments from your computer system.

*****


Food Safety and Sustainability Center

A Deep Dive Into Chicken Labels

A Deep Dive Into Chicken Labels

As consumers become increasingly concerned with how food is produced and how farm animals are raised

and treated, farmers and companies are responding with various labels and claims. Labels or claims generally

aim to assure consumers that the food was produced in a better way - whether it be more humane,

sustainable or healthy - but they can vary widely in how meaningful they are and in what is actually required.

The chart below is designed to help you better understand the different labels and claims you'll find on

chicken. We looked at 23 different labels you might find on a package of chicken, and what they actually

require for 17 different areas that affect either animal welfare (e.g., whether the chickens can go outdoors),

public health (e.g., prudent antibiotic use) and sustainability (e.g., whether the chicken feed contains

genetically engineered crops). For more information, visit www.greenerchoices.org
The Honorable Thomas Vilsack December 18, 2013

Secretary of Agriculture

U.S. Department of Agriculture 

Jamie L. Whitten Federal Building 

1400 Independence Avenue S.W. 

Washington D.C. 20250

Dear Secretary Vilsack: 

Consumers Union, the public policy and advocacy arm of Consumer Reports, is writing to share 

our concerns about the non-therapeutic use in animal agriculture of antibiotics, especially those 

that are considered critical to human medicine. The U.S. Department of Agriculture (USDA) 

Organic label is important to consumers who share this concern and who seek meat and other 

food products from animals that were not treated with antibiotics. We believe, however, that 

there is a loophole in the standards that needs to be closed in order to protect the public health, 

and to meet consumer expectations about meat and poultry labeled “organic.”

As you know, the National Organic Program is a marketing program. “Organic” is widely 

marketed to consumers as meaning “no antibiotics.” Yet while the standards expressly prohibit 

any animal treated with antibiotics to be sold, labeled or represented as “organic” (see

7CFR205.238(c)(1)), the organic law (section 6509(e)(1)) and standards (7CFR205.236(a)(1)) 

exempt day-old chicks from organic management. It is currently unclear which standard takes 

precedence, and we urge the agency to clarify the rules that govern the treatment of chicks raised 

to be sold under the “organic” label. 

Currently, one of the most common antibiotics administered to day-old chicks in conventional 

hatcheries for the prevention of disease is gentamicin. Gentamicin is classified by the World 

Health Organization as “critically important” for human medicine, as it is the sole therapy or one 

of few alternatives to treat serious human disease. Its routine use to prevent disease in day-old 

chicks is disconcerting in any segment of agriculture, but especially when those chicks are raised 

under organic management after the first day of their lives and eventually sold as “organic.” 

We urge USDA to clarify the language in the organic regulations to specifically prohibit the 

administration of antibiotics to day-old chicks, as well as chicks still in the egg. Due to the 

prohibition against antibiotic use in virtually all other segments of organic agriculture and the 

common marketing of “organic” as “no antibiotics used,” consumers expect all organic animals 

-- including day-old chicks -- to be raised without antibiotics. 

 1
Specifically, we urge that the following phrase be added (see bold) as clarification to the 

standards, 7CFR205.238(c)(1):

(c)The producer of an organic livestock operation must not:

(1)Sell, label, or represent as organic any animal or edible product derived from any animal 

treated with antibiotics, including chickens that were treated with antibiotics while in 

the egg or on day one of their lives, any substance that contains a synthetic substance 

not allowed under §205.603, or any substance that contains a nonsynthetic substance 

prohibited in §205.604

The emergence of antimicrobial resistance is a serious and urgent public health concern. Earlier 

this year, the Centers for Disease Control and Prevention released a report that notes that 23,000 

human deaths could be attributed to the development of antibiotic resistance from overuse of 

antibiotics, including in agricultural settings. 

Organic agriculture is marketed as being part of the solution to this widely recognized public 

health crisis. The marketing of “organic” as “no antibiotics used” is rooted in the organic 

standards, which clearly prohibit any animal or animal product from being sold as “organic” if it 

was treated with antibiotics. Given the current lack of clarity in the standards, consumers need 

assurance that this prohibition against antibiotics takes precedence and applies to day-old chicks. 

Thank you for your consideration of our concerns.

Sincerely, 

Urvashi Rangan, Ph. D. 

Executive Director 

Consumer Reports Food Safety and Sustainability Center

 2
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Fwd: progress on banning organic hydroponic

Date: Friday, January 03, 2014 9:12:01 AM

Hi Miles;

Just an FYI to keep you in the loop on the hydroponic issue. Dave also sent this to Leahy's 

staff in Vermont as you can see from the list of names below.

Happy New Year,

Jean

Begin forwarded message:

From: Dave Chapman <

Date: January 2, 2014 12:18:27 PM EST

To: Davey Miskell <misktome@gmavt.net>, Nicole Dehne 

<nicole@nofavt.org>, David Parvey <

 Chuck Ross <Chuck.Ross@state.vt.us>, 

Tom Berry <tom_berry@leahy.senate.gov>

Subject: progress on banning organic hydroponic

Hi all,

I haven't sent out an update for quite a while, but we have been busy. I have 

started two petitions. One is meant for the certified organic farmers in Vermont to

 show support, and the second is meant for organic consumers everywhere. The 

petitions have been out for a week, and so far we have gotten 31 farmers, with 

another 5 farms who wrote me to say they will sign. In the same time we have 

gotten 126 consumers (mostly Vermonters, although the website shows most of us

 as living in Maine! It is tracking our server address) who signed. So far this has 

only gone out to friends, and friends of friends, and it is spreading slowly of its 

own accord.

Nicole is planning to take our petition to the next meeting of the NOFA Interstate 

Council. She is also planning to offer a resolution for a vote at the Winter Meeting

 of the VOF. Based on my conversations with the farmers, I expect a unanimous 

vote in support of the NOSB proposal. She and Dave Rogers are in touch with the

 National Organic Coalition, who have offered administrative help from an intern 

if needed. The NOC is committed to circulating the petitions widely throughout 

the country. They feel that the timing is perfect on this, and that it is good that the 

petitions have originated with a farmer, rather than some organization. 

Eliot Coleman has expressed strong support, and he is working on a short essay 

explaining why hydroponic should not be called organic. He is reaching out to 

friends with powerful voices to help us. Eliot also suggested we get in touch with 

Ronnie Cummins at the Organic Consumers Association.

Jack Kittredge, editor of The Natural Farmer is on our side. He will run an article 

on this in the March issue, and he has offered to hand out information about the 

(b) (6) (b) (6) (b) (6)
petitions at the Mass Winter Conference on January 11th in Worcester, MA.

Jack and Anne Lazor are supporting us. Jack, Eliot, and Jake Guest will share our 

concerns at the meeting of Organic Farming Elders at Esalen later this month 

(while sitting in the hot tubs looking out on the Pacific). Jack suggested we also 

reach out to Mark Kastel at Cornucopia.

It seems to me like we should approach Ronnie Cummins and Mark Kastel soon, 

but not quite yet. Lets get our stuff together, and work with the more moderate 

voices first.

The most sobering thing I heard while calling around to Vermont farmers is that 

Deep Root Organic Coop (based in Johnson, VT) lost $200,000 to $300,000 in 

organic tomato sales in 2013, when Whole Foods decided to switch their New 

York stores from New England soil grown organic tomatoes to Mexican 

hydroponic "organic" tomatoes. Our farm lost about $80,000 in sales to Whole 

Foods for the same reason as well. This is a clear example of how the influx of 

hydroponic tomatoes into the organic market has a chilling effect on the 

development of genuine soil based organic production. The refusal of the NOP to 

accept the NOSB recommendation is forcing soil grown organic producers out of 

the business, and taking that choice away from consumers.. These are the very 

reasons that the organic standards were created in the first place.

Our biggest challenge right now is getting a petition that will allow growers to 

easily sign their name, correct address, and farm name. The online petitions don't 

seem to be well set up to track business names. I am working on creating a 

website that will serve as a place for organic growers to sign a petition, as well as 

be a clearing house for related information. We are making every effort to have 

something online by next Wednesday, so Jack can take it to the NOFA Mass 

conference.

I will talk to Nicole on Friday, to catch up on all this.

Thanks to all of you for your support,

Dave Chapman
From: McEvoy, Miles - AMS

To: Robert Mac Stone ( Zea Sonnabend (zea@well.com); Jennifer Taylor;

joe.dickson@wholefoods.com; Jay Feldman; JFoster@ebfarm.com; Harold Austin (harolda@zirklefruit.com);

Colehour Bondera (colemel@kanalanifarm.org); CALVIN WALKER; Nick Maravell; Tracy Favre

 (tfavre@favrehouse.com); Jean Richardson; Carmela Beck (carmela.beck@driscolls.com);

wendy.fulwider@organicvalley.com; Francis Thicke (fthicke@iowatelecom.net)

Cc: Arsenault, Michelle - AMS; Bailey, Melissa - AMS; Lipson, Mark - OSEC

Subject: Production Aids proposal

Date: Thursday, September 05, 2013 6:03:35 AM

Dear NOSB,

The NOSB made a final recommendation in 2005 titled “Re-structure National List to follow OFPA categories.” The

 2005 NOSB recommendation included 1) a review of the National List to analyze if all substances fall within the

 OFPA categories; 2) a proposed clarification for the category production aids; and 3) a proposed new model for the

 restructuring of the National List. The current draft proposal on “definition of production aids” conflicts with the

 2005 NOSB recommendation and includes some inaccurate references to OFPA. The proposal also does not provide

 sufficient justification for revising the previous recommendation. Therefore, the proposal on “definition of

 production aids” is being removed from the agenda. Thank you for your understanding.

Miles McEvoy

Deputy Administrator

National Organic Program

202-720-3252

This electronic message contains information generated by the USDA solely for the intended

 recipients. Any unauthorized interception of this message or the use or disclosure of the

 information it contains may violate the law and subject the violator to civil or criminal

 penalties. If you believe you have received this message in error, please notify the sender and

 delete the email immediately.

(b) (6)
From: Jean Richardson

To: Tracy Favre; COLEHOUR BONDERA; Mac Stone; Jennifer Taylor

Cc: Brown Rosen, Emily - AMS; McEvoy, Miles - AMS; Arsenault, Michelle - AMS

Subject: PPM edits for June 30

Date: Monday, June 29, 2015 10:14:40 AM

Hi PDS

I have reviewed the June 10 draft and Emily's notes ready for discussion on Tuesday.

I would like to suggest we add a few sentences to public comment (this week's hot topic!) to 

make it more technologically up to date as follows:

Page 31, E

<!--[if !supportAnnotations]--> <!--[endif]-->

--[if !supportLists]-->A. <!--[endif]-->PUBLIC COMMENT 

The NOP and NOSB encourage public comment and work collaboratively to increase 

opportunities for greater participation by a broader range of people, by more pathways,

 using modern technology wherever possible.

Written Comments: All members of the public are encouraged to submit public comment in 

writing according to the Federal Register Notice. Advance submissions allow NOSB members 

the opportunity to read comments in advance electronically, eliminates or decreases the need 

for paper copies to be distributed during the meeting and allows each NOSB member to review

 and analyse data and information well ahead of the Public meeting and possible voting.

Written comments are provided to NOSB members on "thumb drives" and other computer 

based technology prior to the Public Meetings.

Oral Comments Pre-Meeting: Opportunities for oral comment may be provided in the format of

 Electronic meetings/Webinars. Public Notice of such Electronic meetings will be posted 

according to the Federal Register Notice. Such electronic pre-meetings may allow individuals 

more time to present their data or information, reduce the need to attend the public meeting in

 person, reduce our carbon footprint, and give the NOSB more time to absorb the information. 

Individuals may present oral comment at either a pre-meeting Electronic meeting or at the 

NOSB Meeting. Such Electronic meetings shall be recorded and made available to the public 

and to NOSB members.

Oral Comments at the NOSB meeting: All persons wishing to comment at NOSB meetings 

during public comment periods must, in general, sign-up in advance per the instructions in the 

Federal Register Notice for the meeting. Persons requesting time after the closing date in the 

Meeting Notice, or during last minute sign-up at the meeting, will be placed on a waiting list 

and will be considered at the discretion of the NOP working closely with the NOSB Chair and 

will depend on availability of time.

<!--[if !supportLists]-->· <!--[endif]-->Persons will be called upon to speak 

according to a posted schedule. However speakers should allow for some flexibility.
 Persons called upon who are absent from the room could potentially miss their 

opportunity for public comment.

<!--[if !supportLineBreakNewLine]-->

<!--[endif]-->

<!--[if !supportLists]-->· <!--[endif]-->Time allotment for public comment at the 

NOSB Meeting will be four (4) minutes per person, with the options of reducing to a

 minimum of three (3) and extending to a maximum of five (5) minutes at the 

discretion of the NOP working closely with the NOSB Chair in advance of the 

meeting.

For all public comment sessions:· Persons must give their names and affiliations for 

the record at the beginning of their public comment.

<!--[if !supportLists]-->· <!--[endif]-->Proxy speakers are not permitted.

<!--[if !supportLineBreakNewLine]-->

<!--[endif]-->

<!--[if !supportLists]-->· <!--[endif]-->Public comment requests may be scheduled 

according to topic.

<!--[if !supportLineBreakNewLine]-->

<!--[endif]-->

<!--[if !supportLists]-->· <!--[endif]-->Individuals providing public comment shall

refrain from making any personal attacks or remarks that might impugn the character 

of any individual.

<!--[if !supportLineBreakNewLine]-->

<!--[endif]-->

<!--[if !supportLists]-->· <!--[endif]-->Members of the public are asked to define 

clearly and succinctly the issues they wish to present before the Board. This will 

give NOSB members a comprehensible understanding of the speaker’s concerns.

OK all for this e-mail,

Thank you, Jean
From: Jean Richardson

To: Jean Richardson

Cc: Tracy Favre; COLEHOUR BONDERA; Mac Stone; Jennifer Taylor; Brown Rosen, Emily - AMS; McEvoy, Miles -

 AMS; Arsenault, Michelle - AMS

Subject: Re: PPM Board member participation

Date: Monday, June 29, 2015 1:40:01 PM

Hi PDS

Thank you for phone call feed back on how to deal with members who do not participate. I understand that we just

 have to write the "consequences" into our PPM.

Se here is some proposed language for discussion tomorrow:

Page 13

at the end of the Professional Standards Sections

"Failure to participate: The NOSB typically has a heavy work load and thus active participation by all 15 members

 is essential to cary out the mandates in OFPA in a professional manner. When one or more member fails to actively

 participate in Board work the whole NOSB and the organic community is negatively impacted. Thus, when a Board

 member finds that s/he cannot consistently attend subcommittee meetings, or take on work assignments, or

 complete subcommittee work in a timely manner, or find that they cannot attend public comment listening sessions,

 or the biannual public meetings, then the NOSB Chair shall discuss the matter with the Board member, bring the

 concerns to the attention of the Executive subcommittee, and if necessary encourage the board member to resign."

Thank you

Jean

On Jun 29, 2015, at 11:29 AM, Jean Richardson wrote:

> HI PDS

> In reviewing the PPM in preparation for tomorrow's meeting I am once again struck by the list, page 12-13,

 Professional Conduct Standards, such as:

> "NOSB Members shall..

> * Participate in meetings...

> * Serve on subcommittees.... and participate in the work...

> * NOT participate in partisan political activities....

>

> So what are the consequences if they do not do as they are expected to do?

> Thank you

> jean

>

>
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: PPM

Date: Tuesday, November 18, 2014 1:13:05 PM

Hi Miles

Today I went through entire PPM with Emily so we can get a next clean copy which could go to all PDS via e-mail.

Discussed taking all templates and research appendices into the (New) Member Guide which will become the

 research guide for members (not just when "new").

Talked to John and will also bring Mac and Tracy up to date

Cheers

Jean
From: Jean Richardson

To: Brown Rosen, Emily - AMS

Cc: mac@elmwoodstockfarm.com; Arsenault, Michelle - AMS; McEvoy, Miles - AMS

Subject: Re: PPM

Date: Thursday, January 22, 2015 12:47:55 PM

Importance: High

OK I can do Feb 17 at noon ET right before the next 3 NOSB calls.

Mac please let us know if that is OK for you.

Thank you

Jean

On Jan 22, 2015, at 12:23 PM, Brown Rosen, Emily - AMS wrote:

Hi Jean & Mac,

Miles cannot make the Feb 10 date for PDS due to the Accredited Certifiers training.

However the following week looks good, do any of these times look feasible:

Wed. Feb 18th 1 pm eastern 

Wed Feb 18th 2 pm

Tues Feb 17 at 12 noon eastern. (last choice, there are 3 other NOSB calls that day )

We should have an electronic version of the document ready to share before that 

week.

Emily

Emily Brown Rosen

Specialist, Standards Division

USDA-AMS-NOP

www. ams.usda.gov/nop

609-737-8630 NJ office

 cell

(b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: powerpoint for IOIA Meeting?

Date: Friday, February 27, 2015 8:28:17 AM

Thank you!

Jean

On Feb 26, 2015, at 5:42 PM, McEvoy, Miles - AMS wrote:

> NODPA and NOFA-VT presentations attached.

>

> -----Original Message-----

> From: Jean Richardson [mailto

> Sent: Thursday, February 26, 2015 10:05 AM

> To: McEvoy, Miles - AMS

> Subject: powerpoint for IOIA Meeting?

> Importance: High

>

> Hi Miles

> In March I am giving a short refresher overview about NOP/NOSB at the IOIA Training in Montana.

> I have all the NOSB New Member training power point slide on a thumb drive, but in reviewing it today there is

 too much detail.

> Any chance you could send me a thumb drive with your "canned" 15 minute type presentation on power point

 slides. ?- like the ones you did at NODPA or NOFA This would save me a lot of time.

> Thank you very much

> Jean

>

>

>

>

>

> This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

> <nodpa 2014.pptx><vermont - feb 2015.pptx>

(b) (6)
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Automatic reply: powerpoint for IOIA Meeting?

Date: Friday, February 27, 2015 8:28:18 AM

I am out of the office. Please contact Desiree Lee at 202-720-3252, desiree.lee@ams.usda.gov

 if you need immediate assistance.

This electronic message contains information generated by the USDA solely for the intended

 recipients. Any unauthorized interception of this message or the use or disclosure of the

 information it contains may violate the law and subject the violator to civil or criminal

 penalties. If you believe you have received this message in error, please notify the sender and

 delete the email immediately.
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Political activities

Date: Saturday, May 09, 2015 2:46:28 PM

Hi Miles

Just been editing the PPM and I was reminded that our policies do state " do not engage in partisan political

 activities" - just think of Paul

FYI

Jean
From: McEvoy, Miles - AMS

To: Jean Richardson (

Subject: FW: please call...

Date: Thursday, May 24, 2012 12:20:51 AM

I do not plan to talk with him. I’d appreciate your support.

Miles

From: MAK [mailto:

Sent: Wednesday, May 23, 2012 11:28 PM

To: McEvoy, Miles - AMS

Cc: Miles.McEvoy@usda.gov

Subject: please call...

Dear Miles,

Please give me a call. If you get this message tonight I'll be up for a little while longer. If not,

 please feel free to call in the morning (if you miss me tonight, and get my voicemail, please

 leave your number and let me know how early I can call you in the morning).

I started drafting an e-mail to you but didn't like the way it sounded. I think it's important that

 we talk before I get my next phone call from the New York Times asking me to explain the

 unfortunate incident that occurred between us.

A couple of the NOSB members were concerned that this could hurt your reputation. And

 quite frankly, I for one don't want that to happen.

Mark

This electronic message contains information generated by the USDA solely for the intended

recipients. Any unauthorized interception of this message or the use or disclosure of the

information it contains may violate the law and subject the violator to civil or criminal

penalties. If you believe you have received this message in error, please notify the sender and

delete the email immediately.

(b) (6) (b) (6) (b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: phone check in

Date: Tuesday, March 31, 2015 11:03:16 AM

Friday sounds good

On Mar 31, 2015, at 10:55 AM, McEvoy, Miles - AMS wrote:

> Wasn't sure if you were traveling on Monday. Friday will work for me this week unless we need to talk sooner.

> Warm here today.

> Miles

>

> -----Original Message-----

> From: Jean Richardson [mailto

> Sent: Tuesday, March 31, 2015 10:22 AM

> To: McEvoy, Miles - AMS

> Subject: phone check in

>

> Hi Miles

> Not sure if I missed your Monday call?

> I was flying back from an excellent IOIA meeting in Montana.

> Lars did a great job.

> Are we doing Monday or Friday calls at present?

> Still snowing in Vermont!

> Jean

(b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS

Cc: Zea Sonnabend; Mac Stone; John Foster

Subject: PDS Work Agenda Item request

Date: Wednesday, October 22, 2014 5:44:29 PM

Hi Miles

I have received a request from Zea, Chair of Crops Subcommittee, and Inerts Working Group, that the newly

 reactivated PDS develop a censure policy for its own Board members.

I request that this item be added to the PDS Working Agenda

(I have been following the debate on replacing the problematic word "Workplans" with "Agenda" and thought I

 would try Working Agenda!)

Thank you

Jean
From: Jean Richardson

To: Jay Feldman

Cc: Mac Stone (mac@elmwoodstockfarm.com); John Foster; Nick Maravell; McEvoy, Miles - AMS; Arsenault, Michelle

 - AMS; Brown Rosen, Emily - AMS

Subject: Re: PDS Tuesday at 3 pm ET

Date: Monday, October 13, 2014 9:09:00 PM

Hi Jay

Yes this meeting will be brief

Jean

Sent from my iPhone

On Oct 13, 2014, at 8:02 PM, Jay Feldman <jfeldman@beyondpesticides.org> wrote:

Jean,

I thought that we were going to get an agenda ahead of time. I was also under the

 impression (I may be mistaken) that we would get some basic guidelines ahead of

 time as to the range of the activities/issues on which the program wants to

 collaborate with the NOSB. As you know, the NOSB and public was told that

 NOP was taking over the PPM and would assemble the NOSB on an ad hoc or as

 needed basis --you point this out in your September email. Is that no longer the

 case? I would like to see something in writing that clarifies this, if there is a

 change. I don't know how others feel, but any time I have these days is devoted to

 reading public comments, so I would hope that this would be a substantive and

 meaningful meeting.

Below, you'll see my email in response to your September note on a possible PDS

 meeting, as requested by NOP. As you know, I had several questions for which I

 did not receive a response. (Please see below.) I was hoping for some sort of

 answer.

Onward,

Jay

On 10/13/2014 7:09 PM, Jean Richardson wrote:

Hi Everyone

I have not received any material from NOP but am still 

planning on holding the PDS call at 3 pm ET to discuss 

reactivation etc. No Agenda per se.

Jean

-------- Original Message --------

Subject:Re: NOSB-Re-activate PDS

Date:Tue, 02 Sep 2014 10:25:06 -0400

From:Jay Feldman <jfeldman@beyondpesticides.org>

Organization:Beyond Pesticides

Jay Feldman| jfeldman@beyondpesticides.org

Executive Director

Beyond Pesticides

701 E Street, SE

Washington DC 20003

www.beyondpesticides.org

(202) 543-5450 | fax (202) 543-4791
From: Jean Richardson

To: Arsenault, Michelle - AMS

Cc: McEvoy, Miles - AMS

Subject: PDS next meeting

Date: Thursday, October 16, 2014 4:24:41 PM

Michelle

Can you send out time of next meeting of PDS. Monday 3-4 pm.

I do note however that Miles is scheduled on the NOC agenda then, but we should be able to move that.

Check with Miles first of course.

Thank you

jean
From: Jean Richardson

To: Brown Rosen, Emily - AMS

Cc: Tracy Favre; Colehour Bondera; Arsenault, Michelle - AMS; Jennifer Taylor; McEvoy, Miles - AMS; Mac Stone

(mac@elmwoodstockfarm.com)

Subject: Re: PDS meeting cancelled

Date: Tuesday, June 09, 2015 12:54:41 PM

Hi Emily

I like the way we are working on this collaboratively between the NOP and NOSB. I think we

 will have a a good document and am sure we will get it all done in time for posting.

Thank you

Jean

On Jun 9, 2015, at 10:23 AM, Brown Rosen, Emily - AMS wrote:

Hi all,

Sorry I did not get to finish compiling the latest version in time, it proved to be more 

complex task than I thought. I agree we should postpone. I will try and finish 

today/tomorrow and also draw up a list of items that need discussion, based on 

comments so far.

Thanks,

Emily Brown Rosen

Specialist, Standards Division

USDA-AMS-NOP

www. ams.usda.gov/nop

609-737-8630 NJ office

 cell

-----Original Message-----

From: Tracy Favre [mailto:tfavre@favrehouse.com]

Sent: Tuesday, June 09, 2015 10:16 AM

To: Jean Richardson

Cc: Colehour Bondera; Brown Rosen, Emily - AMS; Arsenault, Michelle - AMS; Jennifer 

Taylor; McEvoy, Miles - AMS; Mac Stone (mac@elmwoodstockfarm.com)

Subject: Re: PDS meeting cancelled

Yes that's my understanding too. In fact on our last call we confirmed we were waiting 

to get the draft edits back before further discussion.

Colehour if you'd like to take a start on language for the "remote vote" (shorthand 

language only. Lol) please do so. Otherwise I will assume it's not a priority over the 

general content. Thanks!

T

Sent from my iPhone

(b) (6)
> On Jun 9, 2015, at 8:56 AM, Jean Richardson < wrote:

>

> Hi Colehour.

> My PDS notes indicate that we had agreed that instead of circulating an ever more 

complex PPM document with lots of track changes we would send in our edits to Emily 

and she would compile the next version to circulate. That way we have a version that is 

always clean enough to read and re-edit. That seems to be working well. I think we are 

making good progress on the PPM. Hopefully we can get it out for public comment for 

the fall meeting and complete our work right after the meeting.

> But of course Sunset takes precedence.

>

> And in regards the issues you raise on other topics you could propose some specific 

language for us to review and discuss.

>

> Thank you

> Jean

>

>> On Jun 8, 2015, at 8:36 PM, Colehour Bondera wrote:

>>

>> Aloha PDS,

>>

>> While I will not make a formal "objection", I am sad to see that this monthly meeting

 is postponed another month...

>>

>> Further, as former PDS Chair for two years, and 4.5 years on the NOSB, our role

(both the PDS and the whole NOSB) is not to wait, prioritize based upon, and react to 

NOP at their schedule, but rather to develop our agenda (including getting it 

"approved") and work towards attainable goals.

>>

>> There are items on the PDS Agenda that do not require working through the 

changes that are to be proposed for the "existing" NOSB PPM, and it is our 

responsibility to ensure that these do not fall by the wayside as the NOP input to the 

past PPM is in process.

>>

>> There is (for example only) the subject that was brought up in terms of information 

being shared outside of the NOSB when being considered within a subcommittee, and 

then there is the concept of some unstated policy which would permit voting during a 

public NOSB meeting when not physically present. Those two example of "new" areas 

of the PPM (along with the others I have not reviewed in order to mention) could and 

should be getting attention so that our internal policy duties are kept up with while we

all continue forth with our other duties (which we all are very busy with during this 

"sunset" period, I full well know!)

>>

>> That said, do consider how we might meet (if not tomorrow then at a postponed 

(b) (6)
date/time, for which we all might have a chance to prepare) during June despite delays.

>>

>> Thanks for listening,

>>

>> Colehour

>>

>>> On Jun 8, 2015, at 10:56 AM, Tracy Favre wrote:

>>>

>>> Folks,

>>> As we don’t have the latest version of the PPM for discussion tomorrow, I propose 

that we cancel the PDS meeting. Please let me know if there are any objections to that.

>>> Tracy

>

>
From: Jean Richardson

To: Arsenault, Michelle - AMS

Cc: McEvoy, Miles - AMS; Tucker, Jennifer - AMS; Maravell; Mac Stone; John Foster;

jfeldman@beyondpesticides.org Feldman; Brown Rosen, Emily - AMS

Subject: PDS conference call

Date: Monday, August 18, 2014 8:11:36 AM

Hi Michelle

It does not look like we can have all members of the PDS and NOP on the call tentatively scheduled for August 28.

May I suggest that we try to see if we can find a day/time September 5 (after noon),12,15, 16, 17, 18,19, 22, 23

Perhaps you could do a doodle poll this morning. That might be the fastest way given the complexities of everyone's

 schedules.

Thank you

Jean

(b) (6)
From: Jean Richardson

To: Colehour Bondera

Cc: Tracy Favre; Stone, Mac (AGR); Jennifer Taylor; Arsenault, Michelle - AMS; Brown Rosen, Emily - AMS; McEvoy,

 Miles - AMS

Subject: Re: PDS Agenda and Roberts Rules

Date: Monday, May 11, 2015 7:33:14 AM

Dear Colehour

Best Regards

Jean

On May 11, 2015, at 6:01 AM, Colehour Bondera wrote:

> Thank you so much for the reply, Jean. No need to talk about this beforehand, but I wanted to put forth relevant

 thoughts for serious consideration before Tuesday.

>

> While I do not hold a law degree, it is of serious concern that in none of the mix (OFPA, FACA, NOP, PPM,

 Roberts' Rules or Tradition) which you cited is it clear how the conclusion reached at the meeting was so acted

 upon. Where in OFPA, FACA, NOP, PPM, Roberts' Rules, or Tradition does such a citation/reference exist? Since

 as I put in the public record it is otherwise so stated on page 423 of Roberts Rules, the reference in question must

 exist somewhere to over-ride Roberts Rules, right?

>

> If we can be called on to follow Roberts Rules during a meeting due to proper process (which was about to happen

 by Lisa when I attempted to request sending the petition vote back to committee for further consideration, as it was

 done in a manner that was not following the Roberts' Rules protocol, which is how such actions have traditionally

 been acted upon at the NOSB meetings), what is being used for determination with the decision made at our

 meeting in La Jolla regarding voting while not present, and how can that be advised for equality of the NOSB past,

 present and future?

>

> What appears as arbitrary and capricious decision making would mean that the conclusions reached are not able to

 stand on their own. Both the NOSB and the NOP can and should want for conclusions reached to be able to hold

 their own upon review by an outsider. The public is who we are representing and the public must not have

 fundamental questions about how conclusions were reached.

>

> As the NOSB Chair, it is clear and obvious that actions would never be taken by you in order to seek votes for one

 perspectives' conclusions, since your role is to represent all of us and to be sure that we are all treated as equally

 respected players. While I will bring up the question suggested on the PDS, is it to be open as a discussion, or has

 it actually already been decided upon, and NOSB members do not need to be treated with equality in terms of who

 is listened to and facilitated, and who is simply ignored?

>

> Votes cannot be stood behind if they were not take following a process that we all agreed upon before casting our

 votes. My desire is to work together as a group of equals all of whom have the same decision making power and

 respect, with the decisions made being ones that we all will stand behind because of due process. Discrimination is

 of concern since the whole must strive towards equality, or we simply cannot fairly do our work.

>

> Sincerely,

>

> Colehour

>

(b) (6)
>

> On May 8, 2015, at 3:07 AM, Jean Richardson wrote:

>

>> Hi Colehour

>> You may wish to bring this up on the next PDS. As I stated in public at the beginning of both the October and

 April NOSB Meetings, the NOSB operates with an interesting mix of OFPA, FACA, NOP, PPM, Roberts Rules

 and Tradition ! As Chair I must admit I find it quite fascinating!

>> Thank you

>> Jean

>>

>>

>>

>>

>> On May 6, 2015, at 6:49 PM, COLEHOUR BONDERA wrote:

>>

>>> Aloha PDS -

>>>

>>> Since there is an ES call on Friday, it is in the interest of the NOSB (and the NOP) that I request that the PDS

 Agenda (formerly "Workplan") be added to (and receive endorsement from the ES on the call and from the NOP)

 for the immediate future to review the use of Roberts Rules for the public meeting processes.

>>>

>>> That has been my understanding of the default, and we have an NOP staff member at the meetings who is to

 provide the parliamentary process based on Robert's Rules to ensure those basics. However at the recent meeting

 Roberts Rules was over-ridden by the Chair (with NOP support), and that suggests that there should be something

 in the PPM which, with full transparency, states the meeting procedures, so that NOSB members and the public are

 fully aware in advance of decisions.

>>>

>>> (As former PDS Chair it is not at all clear to me that having the NOP call the OGC is somehow the deciding

 factor - in the PPM or anywhere else [including FACA] - if Roberts Rules is not preferred or required for

 determination by those is decision-making roles at any particular moment).

>>>

>>> Please seriously consider the concept of equality and fairness in terms of ensuring that future NOSBs are

 consistently following the same protocol which are now in the record of a decisive voting process, set with no

 precedent.

>>>

>>> Sincerely,

>>>

>>> Colehour

>>

>
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: PDS

Date: Tuesday, February 11, 2014 9:06:44 PM

Yes spring meeting

Sent from my iPad

On Feb 11, 2014, at 7:52 PM, "McEvoy, Miles - AMS" <Miles.McEvoy@ams.usda.gov> wrote:

> Yes, good idea. You would do this at the NOSB spring meeting, correct?

>

> Miles V McEvoy

> Deputy Administrator

> National Organic Program

>

> -----Original Message-----

> From: Jean Richardson [mailto

> Sent: Tuesday, February 11, 2014 9:59 AM

> To: McEvoy, Miles - AMS

> Subject: PDS

>

> Hi Miles

> From a public perception point of view might it be useful for me to give an informal report on the changed status

 of the PD Subcommittee?

> This would allow members of the public to have an opportunity to voice their concern over checks and balances.

> I have received a number of e-mails and phone calls on this issue, as you may imagine.

> My primary concern is that we must ensure that we do not allow the misperception that the integrity of the organic

 label is endangered by the recent NOP interpretation of FACA.

> Jean

>

>

>

>

> This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

>

(b) (6)
From: Jean Richardson

To: Brown Rosen, Emily - AMS

Cc: McEvoy, Miles - AMS; Mac Stone; Tracy Favre (tfavre@holisticmanagement.org); FAMU Register; Colehour

 Bondera

Subject: PDS

Date: Monday, March 09, 2015 6:07:08 PM

Hi Emily - in addition to updating us on the PPM tomorrow on PDS,

could you give us some history on Minority Opinions as you recall - when they came in to NOSB and how they

 have been used.

So far I have had no luck finding any other FACAs that use them

Thanks Jean
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Paula D

Date: Monday, June 22, 2015 4:37:42 PM

Miles,

Fyi

Jean

Sent from my iPhone

Begin forwarded message:

From: Zea Sonnabend <zea@well.com>

Date: June 22, 2015 at 12:17:02 PM EDT

To: Paula Daniels <

Cc: Michelle - AMS Arsenault <Michelle.Arsenault@ams.usda.gov>, Emily - AMS Brown

 Rosen <Emily.BrownRosen@ams.usda.gov>, Jean Richardson <

Subject: Re: my drafts for the Crops review of Sucrose Octanate Esters and Vit D3

Hi Paula,

I think you should send these out to the group anyway, so at least we can keep the agenda

 moving along.

However, you didn't use the template I sent you so I would have to transfer it, and you didn't

 follow the format of the ones the others use because you have to say something about the

 public comment; even if there was none you need to say that no new information came in.

I would still like to speak with you on the phone about your future participation, but if the rest

 of your time is this connected, I suggest that resigning now is a good idea so that your

 position can possibly be filled in the next round of appointments. We need members to not

 only do the assignments, but be informed voters on all the issues. A leave of absence only

 drags the rest of us down for that period when we are trying to work one member and one

 vote short.

Regards,

Zea

On Jun 21, 2015, at 6:22 PM, Paula Daniels wrote:

Hello all; I'm attaching my drafts for the committee discussion on Tuesday, with 

apologies in advance. I haven't been able to pay attention to the details of what is

needed and I'm not sure if this is what need from us for these materials, at this 

juncture.

It's basically a cut and paste of my review notes from the last round. I don't recall 

any public comment. I opened the public record document but it is not a 

(b) (6) (b) (6)
searchable database and I have to confess that I simply do not have the time to 

search it page by page, at this point in time.

I am probably going to have to resign or at a minimum take an official leave of 

absence for the rest of the year as I will not be able to devote the time that this 

requires, for reasons I've mentioned to you separately. 

I'm sending this to you as drafts now in case there are any glaring errors I should 

try to fix before Tuesday. Thanks for any help, and sorry about all this.

<CS 2017 Sunset Sucrose Octanate Esters.docx>

<CS 2017 Sunset Vit D3.docx>

Paula 

~~~~~~
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Parliamentarian

Date: Saturday, October 04, 2014 11:05:59 AM

Hi Miles

at the IOIA Advanced Training.

Jim Pierce feels we should for sure have a Parliamentarian. It has been done in the past.

We may need to hire one. He expects a lot of motions

Jim will be making comments and trying to help set a positive tone

Mathew Michaels made an excellent presentation.

Thanks Jean
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Parliamentarian

Date: Wednesday, October 22, 2014 12:40:29 PM

Hi Miles

If Jay hires his personal Parliamentarian I would like NOP legal advice on how to deal with that situation. Can you

 check with someone so we are prepared.

(I of course have my opinion!)

Thank you

Jean
From: Jean Richardson

To: Tracy Favre

Cc: Calvin Walker; Mac Stone; ashley@arkansasegg.com Swaffar; Bondera Colehour; Thicke Francis; Brown Rosen,

 Emily - AMS; McEvoy, Miles - AMS; Arsenault, Michelle - AMS

Subject: Re: Parasiticdes-Discussion Document

Date: Monday, July 20, 2015 4:14:35 PM

There are some edits needed on the Parasiticides document and I am tied up right now so we can wait on that

Sent from my iPhone

On Jul 20, 2015, at 12:47 PM, Tracy Favre <tfavre@favrehouse.com> wrote:

Again, let’s put this on tomorrow’s call and if we get to it, great.

thanks

T

> On Jul 19, 2015, at 8:23 AM, Jean Richardson < wrote:

>

> Hi LS

> Here is a draft of what I would suggest we send out in regards parasiticides.

> We have the new TR and all sorts of interesting new data since these materials were last reviewed.

> There is broad support amongst stakeholders that we need to look at parasiticides again.

> There was o science behind the Withholding period.

> Moxidectin is incorrectly annotated based on an error at the time of listing.

> We may of course vote to eliminate Ivermectin in Fall but it still needs to be in this document

> We have the continued request from Sheep producers over many years to be able to sell their fleece as organic. ...

> So this document is a Discussion Document to get some public input in response to questions.

> We could then have a Proposal for NOSB vote in April next year.

>

> Your perspectives and ideas would be most appreciated.

> We can put this on any day you wish Tracy.

> Thank you

> Jean

>

> <Prasiticides Annotation change.docx>

(b) (6)
From: Jean Richardson

To: Bradley, Mark - AMS

Cc: McEvoy, Miles - AMS; Tracy Favre; Mac Stone

Subject: Re: Organic wild harvested fish

Date: Wednesday, October 08, 2014 11:53:37 AM

Such was the discussion!

But they want to try to make their case!

I suggested they talk with Jim Pierce before doing anything more.

On Oct 8, 2014, at 11:42 AM, Bradley, Mark - AMS wrote:

> The notion of certifying wild fish under 205.207 stops with the definition of wild crop. It is limited to plants.

> While persistent effort is admirable, they need to understand that WSDA or OTCO do not have the option to

 certify wild caught fish as organic under our regulations.

>

> -----Original Message-----

> From: Jean Richardson [mailto

> Sent: Wednesday, October 08, 2014 9:09 AM

> To: Bradley, Mark - AMS

> Cc: McEvoy, Miles - AMS; Tracy Favre; Mac Stone

> Subject: Re: Organic wild harvested fish

>

> Ok let's sit back and see where this goes.

> They seem pretty serious about getting it to work Jean

>

> Sent from my iPad

>

>> On Oct 8, 2014, at 8:54 AM, "Bradley, Mark - AMS" <Mark.Bradley@ams.usda.gov> wrote:

>>

>> My check-in with the AMS LPS Process Verified team was met with a less-than-enthusiastic response. While

 they have dealt with fish processing for school lunch programs, they consider certifying the actual fisheries to be

 outside their area of expertise. They would prefer to refer them to the U.S. Marine Fisheries Service to possibly

 develop a program.

>>

>> -----Original Message-----

>> From: Jean Richardson [mailto:

>> Sent: Tuesday, October 07, 2014 5:10 PM

>> To: Bradley, Mark - AMS; McEvoy, Miles - AMS; Tracy Favre; Mac Stone

>> Subject: Organic wild harvested fish

>>

>> Hi Everyone

>> I just spent an hour or so on the phone with Dennis Moran, Mike Szymanski and Arne Fuglov of Alaska and

 Seattle . They want to have USDA organic certification for wild caught deep water fish from a highly regulated part

 of the Bering Sea.

>>

>> I explained how USDA organic certification works, certifiers, inspectors, OSP's etc. etc I suggested they instead

 use the AMS LPS Process Verified Program etc. (as Mark suggested).

>> They do not want that.

>>

>> We discussed the Wild crop harvesting practice standard 205.207 as it might be applied to mushrooms,

 blueberries, maple sap for example. - I described wild crop OSP and an approved management plan etc. They like

 that idea.

>>

>> I explained that 205.207 may not apply to wild fish. But they appear to wish to talk with WSDA as a certifier to

(b) (6) (b) (6)
 explore this path. I also referred them to Jim Pierce.

>> They do not want to give up on this.

>>

>> So there you have it in a nutshell. Call me if you want more details

>> Jean

>>

>>

>>

>>

>>

>> This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

policy-making. In adopting the Organic Foods Production Act of 1990(OFPA), Congress created standards 

for organic certification and established the NOSB to oversee the allowance of synthetic materials based on

 a determination that they do not cause harm to human health and the environment and are necessary in 

organic food production and processing, given a lack of alternatives.

Under the law, a review of these materials takes place on a five year cycle, with a procedure for relisting if 

consistent with OFPA criteria. Plaintiffs in this case maintain that the USDA organic rule establishes a public

 process that creates public trust in the USDA organic label, which has resulted in exponential growth in 

organic sales over the last two decades.

At issue in the lawsuit is a rule that implements the organic law’s “sunset provision,” which since its origins has been interpreted to require all listed materials to cycle

off the National List of Allowed and Prohibited Substances every five years unless the NOSB votes by a two-thirds majority to relist them. In making its decision, the

NOSB is charged with considering public input, new science, and new information on available alternatives.

In September, 2013, in a complete reversal of accepted process, USDA announced a definitive change in the rule it had been operating under since the inception of 

the organic program without any public input. Now, materials can remain on the National List in perpetuity unless the NOSB takes initiative to vote it off the List.

In a joint statement, the plaintiffs, representing a broad cross-section of interests in organic, said:

We are filing this lawsuit today because we are deeply concerned that the organic decision making process is being undermined by USDA. The

complaint challenges the unilateral agency action on the sunset procedure for synthetic materials review, which represents a dramatic departure

from the organic community’s commitment to an open and fair decision making process, subject to public input. Legally, the agency’s decision

represents a rule change and therefore must be subject to public comment. But equally important, it is a departure from the public process that

we have built as a community. This process has created a unique opportunity within government for a community of stakeholders to come

together, hear all points of view, and chart a course for the future of organic. It is a process that continually strengthens organic, supports its rapid

 growth, and builds the integrity of the USDA certified label in the marketplace.

The plaintiffs in the case, represented by counsel from Center for Food Safety, include: Beyond Pesticides, Center for Food Safety, Equal Exchange, Food and Water

Watch, Frey Vineyards, La Montanita Co-op, Maine Organic Farmers and Gardeners Association, New Natives, Northeast Organic Dairy Producers Alliance,

Northeast Organic Farmers Association Massachusetts, Ohio Ecological Food and Farm Association, Organic Consumers Association, Organic Seed Growers and

Trade Association, PCC Natural Markets, and The Cornucopia Institute.

1The NOSB is a 15 member Board comprised of farmers, consumers, environmentalists, retailers, certifiers and food producers who advise the Secretary of Agriculture and the National Organic

Program on all matters related to organic food and agriculture policy.

-30-

Joint Statement of Plaintiffs on USDA Change to Organic Rule

without Public Comment

[The following joint statement concerning the lawsuit challenging the changes to the USDA s Sunset policy is provided by Beyond Pesticides, Center for Food Safety, 

Equal Exchange, Food and Water Watch, Frey Vineyards, La Montanita Co-op, Maine Organic Farmers and Gardeners Association, New Natives, Northeast Organic

Dairy Producers Alliance, Northeast Organic Farmers Association Massachusetts, Ohio Ecological Food and Farm Association, Organic Consumers Association,

Organic Seed Growers and Trade Association, PCC Natural Markets, and The Cornucopia Institute.]

When a USDA rule implementing a section of the Organic Foods Production Act as important as the “sunset provision” is changed, why are we concerned about

process? Since its origins, the sunset provision has been interpreted under the USDA organic rule to require allowed synthetic materials to cycle off the National List of

 Allowed and Prohibited Substances every five years unless the NOSB decisively votes by a two-thirds majority to relist them. In making its decision, the NOSB is

charged with considering public input, new science, and new information on available alternatives. In September, 2013, without public comment, and in a complete

reversal of the customary public process, USDA announced a change in the rule it had been operating under since the inception of the organic program, now allowing

synthetic materials to remain on the National List unless the NOSB votes it off.

The organic label is built on a history and solid foundation of holding public hearings and soliciting extensive public participation. Many of us remember when the

original proposed rule – which would have allowed GMOs, sewage sludge, and irradiation – resulted in a large outpouring of public input. It was important that the

public had an opportunity to be heard before the rule was adopted. This opportunity created the public belief that the process behind the organic label was something

that could be trusted. Ever since then, whether there was agreement on a decision or not, we could believe in a decision-making process and the high integrity of the

organic label.

We are deeply concerned that the decision-making process on allowed synthetic materials in organic production and processing is being undermined by USDA. The

lawsuit we are filing challenges the unilateral agency action on the sunset procedure for synthetic materials review, which represents a dramatic departure from the

organic community’s commitment to an open and fair decision making process that is subject to public input. Legalistically, the agency’s decision represents a rule

change and therefore must be subject to public comment. But equally important, it is a departure from the public process that we have built as a community. This

process has created a unique opportunity within government for a community of stakeholders to come together, hear all points of view, and chart a course for the

future of organic. t is a process that continually strengthens organic, supports its rapid growth, and builds the integrity of the USDA certified label in the marketplace.

The failure of USDA to comply with public hearing and comment procedures on the sunset rule change serve to usurp a process and label that the organic community

began building long before the agency even recognized the legitimacy of organic systems as a viable and productive form of agriculture. It is our hope that the filing of

our lawsuit will help set the process straight again, as the organic sector faces important questions of practices and synthetic material use in the future. We believe in

the value of the public voice in that process, as we seek to grow the organic sector through public trust in the organic label.

We must take a stand together, and hold USDA accountable to the public process that helped establish and grow organic. If we do not hold the line on public process,

we fear that in decision-after-decision, organic will lose its meaning. And, USDA will cause the demise of this treasured sector built by farmers, food producers, and

the public at large, with a vision that embodies the values and principles that have made the organic label trusted and strong.

Consumers and farmers working together have helped to grow organic from the beginning. We are at a critical and historic moment when the stakeholders must lead

in ensuring that our government respects what we have built and remains true to the public process and the legal framework that give organic its integrity.

From: McEvoy, Miles - AMS

To: "Tracy Favre"

Cc: "Richardson Jean"; Brown Rosen, Emily - AMS

Subject: RE: Organic Poultry Working Group

Date: Thursday, June 04, 2015 12:04:46 PM

Sounds good,

Miles

-----Original Message-----

From: Tracy Favre [mailto:tfavre@favrehouse.com]

Sent: Thursday, June 04, 2015 11:50 AM

To: McEvoy, Miles - AMS

Cc: Richardson Jean; Brown Rosen, Emily - AMS

Subject: Re: Organic Poultry Working Group

Let me put some information together and make a more formal request next week.

I’d prefer the group to be inclusive of some industry folks outside of the board. How that happens and what are the

 requirements is something on which I’m happy to get input. If it needs to be something formally advertised, we’ll

 need to get some structure put together. What I’d like for the work agenda is the opportunity to have Ashley,

 Calvin, Mac and myself spend some time to discuss the framework of the group... objectives, structure, etc. But

 regardless, I’ll get my ducks more officially in a row and submit it to you.

Thanks

T

> On Jun 3, 2015, at 3:33 PM, McEvoy, Miles - AMS <Miles.McEvoy@ams.usda.gov> wrote:

>

> Hi Tracy,

> I think there are some benefits to forming an Organic Poultry Working Group. Please clarify the purpose of

 objectives of this group. Do you see this as a Board ad-hoc group or something more like the Hydroponic Task

 Force that reports to the NOSB?

>

> Looping Emily in.

>

> Best,

> Miles

>

> -----Original Message-----

> From: Tracy Favre [mailto:tfavre@favrehouse.com]

> Sent: Tuesday, June 02, 2015 3:16 PM

> To: McEvoy, Miles - AMS

> Cc: Richardson Jean

> Subject: LS: Organic Poultry Working Group

>

> Hi Miles,

> This is an official request to add to the LS work agenda the creation of the Organic Poultry Working Group - as

 we discussed at the meeting in La Jolla. I believe that we have the 2017 Sunset materials well in hand, so I think

 we can safely add this task to our agenda without compromising our other work.

>

> Our initial work on this for this semester would include fleshing out the composition and intent of the working

 group. I’ve asked Calvin Walker, Ashley Swaffer and Mac Stone to lead the efforts of putting this together. I’ve

 put forth the following questions to those three:

>

>>> 1. How many in the group?
>>> 2. What is the make up of the group? (Small producers, large,

>>> pasture based, humanely raised, geographic area, etc.) 3. How will you recruit members?

>>> 4. What is the deadline for launching the group?

>>>

>>> I think we need solid plans for this group before our Fall meeting. In fact, I'd like for the LS to have an update

 report by the Fall deadline. Do you think that's possible?

>

> Calvin has responded that he thinks we could have enough work done on this to have an initial report for the Fall

 meeting.

>

> Please advise if we can plan to add this topic to our work.

> Thanks

> Tracy Favre

>
From: McEvoy, Miles - AMS

To: Dave Chapman

Cc: Jean Richardson; Tom Berry

Subject: Re: organic hydroponic update

Date: Monday, January 06, 2014 8:38:40 PM

Hi Dave,

Thanks for keeping me in the loop. Let's try to talk soon. This week is pretty packed but I'm available early next

 week to discuss.

Miles V McEvoy

Deputy Administrator

USDA National Organic Program

> On Jan 6, 2014, at 5:41 PM, "Dave Chapman" < wrote:

>

> Hi Miles,

>

> I have been working since we talked, reaching out to farmers in Vermont with a petition asking the NOP to adopt

 the recommendations of the NOSB banning hydroponic growing from organic certification. We have had a strong

 response in just the last ten days, with about 30% of those we emailed signing the petition. I think we will reach far

 more soon, and we are planning to send it out to farmers in other states shortly. I am asking if you will wait a while

 before making your decision to publicly oppose the NOSB's recommendation. I believe you will find there is a lot

 of concern about the hydroponic issue, and also a lot of concern about the NOP going against the NOSB

 recommendation. Please give me a little time to show you that you are wrong about how people feel about this.

 What I have found is frustration, and a sense of hopelessness, as the definition of organic is changed by the NOP

 beyond recognition.

>

> Thanks for talking with me about this. I realize that you have many demands on your attention. I sympathize with

 your support of the Veteran's Affairs program to train vets how to grow hydroponically. I also support that program.

 We just shouldn't call it organic, because it isn't. We shouldn't allow the Veterans Affairs folks to decide the

 definition of organic. I am not opposed to hydroponic growing. Some of my best friends....It is an ingenious method

 of growing in the greenhouse, and it has displaced all conventional soil based vegetable growing in the greenhouse.

 But it is NOT organic. In Europe and Canada, they are quite clear about this, and there are many organic

 greenhouse operations doing a fine job of growing in the soil. It is perfectly doable to grow wonderful organic crops

 in a greenhouse soil. It is not as cheap and easy as hydroponic production, just as growing organically in the field is

 not as cheap and easy as conventional growing.

>

> I hope that you can put off your public announcement until you have had a chance to see how the American

 organic community feels about this issue.

>

> Thanks,

>

> Dave Chapman

> Long Wind Farm

This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

(b) (6)
From: Jean Richardson

To: Tracy Favre; Mac Stone; Colehour Bondera; Ashley Swaffar; Francis Thicke; Calvin Walker

Cc: Brown Rosen, Emily - AMS; McEvoy, Miles - AMS; Arsenault, Michelle - AMS

Subject: Proposal Change Annotation/Lidocaine/Procaine

Date: Sunday, July 19, 2015 10:41:40 AM

Attachments: LoidcaineProcaineProposal.doc

Hi LS

For consideration in October.

Here is a draft of the Proposal to change the annotation on Lidocaine and procaine withholding, based on science,

 and - as Ed Maltby of NODPA tells me- because is just plain sensible!

Tracy you can put this on any call you wish for discussion and vote.
National Organic Standards Board

Livestock Subcommittee

Proposal

To change Annotation for Lidocaine and Procaine Use in Livestock Production.

 July 19, 2015

I INTRODUCTION

Lidocaine and procaine are local anesthetics. They are used at times such as debudding horns in baby calves, or general minor surgery on mature cows. They numb 

only the area to be worked on. Humane treatment of animals is critically important. A 

lengthy witholding may result in animals not being treated in a timely manner, or not at 

all. Based on new information received during Sunset Review of these materials the 

NOSB proposes to modify the annotation to reduce the Witholding period from 90 days 

to 5 days. 

II BACKGROUND

When added to the National List in 1995 there was no scientific rationale for the 90 day 

Witholding. New science and information have been provided during the recent Sunset 

Review which suggest a shorter withholding of 5 days may be more sensible. Public 

Comment appears to support such a proposal.

III RELEVANT AREAS OF THE RULE

Lidocaine:

Reference: §205.603(b) As topical treatment, external parasiticide or local anesthetic as 

applicable 

(4) Lidocaine—as a local anesthetic. Use requires a withdrawal period of 90 days after 

administering to livestock intended for slaughter and 7 days after administering to dairy 

animals

Technical Report: None

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 sunset recommendation;

10/2010 sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 

33290) 

Sunset Date: 6/27/2017 

Procaine:

Reference: §205.603(b) As topical treatment, external parasiticide or local anesthetic as 

applicable. 

(7) Procaine—as a local anesthetic, use requires a withdrawal period of 90 days after 

administering to livestock intended for slaughter and 7 days after administering to dairy 

animals

Technical Report: N/A
Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 

10/2010 sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 

33290) 

Sunset Date: 6/27/2017

IV DISCUSSION

During Review of these materials the NOSB in its initial request for public comment 

asked:

1. Since this material was last reviewed have alternative materials emerged?

2. What is the scientific rational for what appears to be an excessively long withdrawal 

period?

3. Is there research to indicate that a shorter withdrawal period would be appropriate?

Public comment did not provide any alternatives, did not provide any scientific rationale 

for the lengthy withholding period and recommendations were received suggesting that 

a very short withholding period, such as 5 days would be scientifically acceptable. 

There was widespread stakeholder support for continuing to list lidocaine and procaine.

In contrast to butorphanol, which is a systemic anesthetic, lidocaine and procaine numb 

only the area to be worked on. Science indicates that the half life of lidocaine and 

procaine in all animals studied is very short- typically less than one hour. The US Food 

Animal Residue Avoidance Databank (FARAD) recomends a 24 hour meat and milk 

withholding for lidocaine and procaine in all food producing ruminant species.

There appears to be widespread support to reduce the Withholding period in order to 

ensure humane treatment of animals.

V RECOMENDATION

That Annotations at 205.603 (b) for Lidocaine and Procaine be changed as follows:

Lidocaine—as a local anesthetic. Use requires a withdrawal period of 90 days after 

administering to livestock intended for slaughter and 7 days after administering to dairy 

animals 5 days after administering to livestock.

Procaine—as a local anesthetic, use requires a withdrawal period of 90 days after 

administering to livestock intended for slaughter and 7 days after administering to dairy 

animals 5 days after administering to livestock.

Subcommittee Vote:

Motion: Jean Richardson

Second:

Vote: Yes No Abstain Absent Recuse
From: McEvoy, Miles - AMS

To: Harold Austin; Zea Sonnabend (zea@well.com); Jean Richardson ( Tracy Favre

 (tfavre@favrehouse.com); Carmela Beck (carmela.beck@driscolls.com); Barry Flam; Colehour Bondera

 (colemel@efn.org); Jay Feldman; Jennifer.Taylor@famu.edu; JFoster@ebfarm.com;

joe.dickson@wholefoods.com; Katrina Heinze; Nicholas Maravell ( Rueben Walker

 ( Steve DeMuri; Stone, Mac (AGR); Tina Ellor; Tracy Miedema

 ( wendy.fulwider@organicvalley.com

Cc: Coke, Lorraine - AMS

Subject: Proposed rules on sunset 2012

Date: Monday, January 09, 2012 11:44:20 AM

Attachments: Release AMS Organic Vitamins 01-05-12 links.docx

The program will be publishing proposed rules on sunset 2012 and vitamins and minerals later this

 week. Attached is the press release. Copies of the proposals are available on the NOP website.

Miles V. McEvoy

Deputy Administrator

National Organic Program

U.S. Department of Agriculture

Room 2646-So. (Stop 0268)

1400 Independence Ave SW

Washington, DC 20250-0268

202-720-1413

www.ams.usda.gov/nop

Organic Integrity from Farm to Table, Consumers Trust the Organic Label

Register for the NOP Organic Insider, the National Organic Program’s email notification service, by

 visiting http://bit.ly/NOPOrganicInsiderRegistration.

(b) (6) (b) (6) (b) (6) (b) (6)
PROGRAM ANNOUNCEMENT 

AGRICULTURAL MARKETING SERVICE

United States Department of Agriculture | 1400 Independence Ave., SW | Room 4512-S

Washington, DC 20250 | (202) 720-8998 | http://www.ams.usda.gov

AMS No. 008-12

Michael T. Jarvis (202) 720-8998

Michael.Jarvis@ams.usda.gov 

USDA Proposes Clarifying the Use of Vitamins and Minerals in Organic Foods; 

Affirms Advisory Board Decisions on Other Allowed and Prohibited Substances 

WASHINGTON, Jan. 9, 2012—The U.S. Department of Agriculture will publish a 

proposed rule later this week under the National Organic Program (NOP) addressing the use of 

vitamins and minerals in organic foods and infant formula. The proposed rule aligns the organic 

standards with Food and Drug Administration (FDA) rules and provides a clear list of vitamins 

and minerals that are allowed in organic products. As a result, this will increase consumer 

confidence that organic foods are consistent both with FDA rules and the principles of organic 

production. 

“Consumers expect that each substance allowed in organic products has met stringent 

criteria and has been recommended by the independent National Organic Standards Board,” said 

Miles McEvoy, deputy administrator of the National Organic Program. “The changes proposed 

today would provide clear, enforceable standards for the use of vitamins and minerals in organic 

products.” 

The proposed rule would correct an inaccurate reference to FDA’s fortification policy 

and clearly delineate that only vitamins and minerals the FDA has classified as essential are 

permitted in products labeled as “organic” or “made with organic (specified ingredients or food 

group(s)).” Additionally, since current USDA organic regulations do not cover infant formula, 

the proposed rule would allow essential vitamins and minerals as additives to organic infant 

formula. 

 

Nutrients not covered under this proposed rule would be prohibited in organic products 

unless they are listed separately on the National List of Allowed and Prohibited Substances 

(National List). This section of the federal organic standards lists the non-organic ingredients and 

processing aids allowed in organic processed products. The proposed rule includes a two-year 

implementation period to allow companies to change their formulations to comply with the new 

requirements. 

Additionally the National Organic Program will publish a proposed rule later this week 

that would renew the allowance or prohibition of the substances used in organic production and 

handling that are scheduled to expire later this year. The proposed rule would renew the listings 
for over 200 National List substances. Additionally, the allowance for seven substances would be 

clarified or restricted: chlorine materials (for use in crops and livestock production); lignin 

sulfonate (crops); streptomycin (crops); yeast (handling); colors (handling); hops (handling); 

and, pectin – high-methoxy (handling). Three allowances would be removed: sulfur dioxide 

(crops – underground rodent control); pectin – low-methoxy (handling); and, potassium iodide 

(handling). 

Under the sunset provisions of the Organic Foods Production Act of 1990, the National 

Organic Standards Board (NOSB), an independent board of organic industry stakeholders, must 

review all National List substances. Each substance must meet several criteria, including 

consistency with organic agricultural systems, impact on the environment and human health, and 

essentiality in organic production and handling. The advisory board also considers natural 

alternatives to each National List substance. This advisory board must then recommend if each 

specific exemption or prohibition should be renewed for another five years. 

The proposed rule to be published later this week in the Federal Register will reflect the 

recommendations of the NOSB. Most of the substances proposed to be renewed by this action 

have been on the National List since its inception in 1990 and have proven to meet the criteria 

established by law. For example, pheromones have long been used as an effective, non-toxic way 

to “confuse” insects that may otherwise infest organic crops, especially fruit. Likewise, vaccines 

for animals are important disease prevention tools against many infectious diseases, especially 

since antibiotic therapy is prohibited in organic livestock. The proposed renewals also include 

processing aids such as baking soda, which acts to lighten (leaven) the dough for organic 

pancakes, baked goods, and other products. This rule also proposes to renew long-standing 

prohibitions on certain toxic natural substances, such as strychnine. 

The allowances proposed to be removed or restricted also reflect the application of the 

statutory criteria and the rigor of the sunset review process. “It’s an important feature of the 

National List that it can be dynamic over time in response to changing conditions and new 

information,” said McEvoy. 

Sodium nitrate, which is currently allowed under restricted conditions in organic crop 

production, will undergo a separate rulemaking that considers the NOSB’s recommendation to 

prohibit its use altogether in organic crop production. This separate action will allow the NOP to 

further assess the potential industry impacts of such a change.

The proposed rule to be published later this week on vitamins and minerals, along with 

additional background information, will be available at www.regulations.gov (search for docket 

number AMS-NOP-10-0083). The proposed sunset 2012 rule, along with additional background 

information, will be available later this week at www.regulations.gov (search for docket number 

AMS-NOP-09-0074). Information on how to submit a comment will be included on the 

www.regulations.gov site along with dates for the comment period. 
Interested persons should submit their comments at www.regulations.gov or mail them to 

Toni Strother, Agricultural Marketing Specialist, National Organic Program, USDA-AMS-NOP, 

1400 Independence Ave., SW., Room 2646-So., Ag Stop 0268, Washington, DC 20250. All 

comments will be posted without change to www.regulations.gov. 

The National List is a subpart of the USDA’s organic standards that identifies synthetic 

substances that may and nonsynthetic (natural) substances that may not be used in organic 

production. The Organic Foods Production Act of 1990 and National Organic Program 

regulations specifically prohibit the use of any synthetic substance in organic production and 

handling unless the synthetic substance is on the National List. 

The National Organic Program of the U.S. Department of Agriculture facilitates trade and 

ensures integrity of organic agricultural products by consistently implementing the organic 

standards and enforcing compliance with the regulations. 

For further information about the proposed rule, contact Miles McEvoy, NOP Deputy 

Administrator, Telephone: (202) 720-3252; Fax: (202) 205-7808. 

 

### 

Get the latest Agricultural Marketing Service news at http://www.ams.usda.gov/news or follow us on Twitter 

@USDA AMS. 

USDA is an equal opportunity provider, employer and lender. To file a complaint of discrimination, write to USDA, 

Director, Office of Civil Rights, 1400 Independence Ave., S.W., Washington, DC 20250-9410, or call (800) 795-

3272 (Voice) or (202) 720-6382 (TDD).
From: Jean Richardson

To: Brown Rosen, Emily - AMS

Cc: Bondera Colehour; Arsenault, Michelle - AMS; Jennifer Taylor; McEvoy, Miles - AMS; Mac Stone

 (mac@elmwoodstockfarm.com); Tracy Favre (tfavre@favrehouse.com)

Subject: Re: revised PPM 6-10-15 & make up meeting June 30?

Date: Wednesday, June 10, 2015 4:47:41 PM

Ok June 30 at 3 pm ET

Jean

Sent from my iPhone

On Jun 10, 2015, at 4:13 PM, Brown Rosen, Emily - AMS

 <Emily.BrownRosen@ams.usda.gov> wrote:

Hi all,

Here is the long awaited revision of the PPM, incorporating comments from the earlier meeting and

 those sent in by Jean and Tracy. I have left these changes in track changes mode.

I think this list below includes the significant changes that need discussion.

<!--[if !supportLists]-->1. <!--[endif]-->Section III D3 -Role of Secretary - page 8

<!--[if !supportLists]-->2. <!--[endif]-->Work agendas , Section III F Page 9

<!--[if !supportLists]-->3. <!--[endif]-->Standards of Conduct, Sect III J -1-2 page 14

<!--[if !supportLists]-->4. <!--[endif]-->Task forces – Section IV C page 19

<!--[if !supportLists]-->5. <!--[endif]-->Minority view Section IV F 1 page 21

<!--[if !supportLists]-->6. <!--[endif]-->Substance review – Roberts rules Section 1V G 6 page

 25

<!--[if !supportLists]-->7. <!--[endif]-->Changing annotations or classification IV G 2 page 25,

also mentioned under III F examples of work agenda items page 10

<!--[if !supportLists]-->8. <!--[endif]-->Additional considerations for TRs, IV G 3 page 26

<!--[if !supportLists]-->9. <!--[endif]-->Sunset review process, Sect VII page 27

<!--[if !supportLists]-->10. <!--[endif]-->Withdrawal of petitions sect IV G 6, page 28

<!--[if !supportLists]-->11. <!--[endif]-->ref to Roberts Rules – Section V B , C page 30-31

<!--[if !supportLists]-->12. <!--[endif]-->Remove appendix one, Procedures for Nat List petitions

 p.39

Do not worry about problems with numbering, bullets or indents. This seems to be a little unstable

 when it goes to different computers, but I assure you, it looks fine in my version.

How about we schedule a make-up meeting for PDS in June: does June 30, 3 pm Eastern work? It

 looks like there is crops and handling, but no livestock call that day.

Thanks,

Emily
Emily Brown Rosen

Specialist, Standards Division

USDA-AMS-NOP

www. ams.usda.gov/nop

609-737-8630 NJ office

 cell

<PPM 06-10-15.docx>

(b) (6)
From: Jean Richardson

To: Colehour Bondera

Cc: Arsenault, Michelle - AMS; Brown Rosen, Emily - AMS; Jennifer Taylor; McEvoy, Miles - AMS; Mac Stone

 (mac@elmwoodstockfarm.com); Tracy Favre (tfavre@favrehouse.com)

Subject: Re: revised PPM 6-10-15

Date: Tuesday, June 30, 2015 9:31:05 PM

No nothing

We just marked where we are up to.

Emily will send out clean version

Good progress

Good input from everyone

Cheers Jean

Sent from my iPad

On Jun 30, 2015, at 9:46 PM, Colehour Bondera < wrote:

Anything more happen with this meeting after the drop? 

Sorry that I could not come back as I had a meeting starting at 10:00.

COlehour

On Jun 30, 2015, at 9:59 AM, Arsenault, Michelle - AMS wrote:

I’m back on...weird. I was dropped

From: Jean Richardson [mailto:

Sent: Tuesday, June 30, 2015 8:26 AM

To: Colehour Bondera

Cc: Brown Rosen, Emily - AMS; Arsenault, Michelle - AMS; Jennifer Taylor;

 McEvoy, Miles - AMS; Mac Stone (mac@elmwoodstockfarm.com); Tracy

 Favre (tfavre@favrehouse.com)

Subject: Re: revised PPM 6-10-15

Hi Colehour

Thank you for your comments.

I agree with you that we need to get this out for public comment .

It is really exciting to see the document coming together in such a

 readable format.

Look forward to our call this afternoon

Jean

On Jun 30, 2015, at 2:03 AM, Colehour Bondera wrote:

Aloha NOSP PDS:

(b) (6) (b) (6)
Thank you for your efforts on this Emily (and Michelle!)

To begin, I need to reiterate my most significant general

 observation/feeling, which is that it is overwhelming, inappropriate

 and even untenable to include a large volume of both

 structural/presentation changes simultaneously with substantial

 content revisions in a document which was put together piece by

 piece and modified through a number of NOSB members over more

 than ten years.

In honesty, my feeling is that as an NOSB member who tries to

 dedicate an average of 20 hours per week to NOSB requirements,

 that completely and seriously reviewing this whole draft would take

 me more time than is possible as a member of other subcommittees.

While it was read through, it was nearly impossible to make

 comparisons and cross references to the original document without

 spending 5-10 times more time than was viable. Not clear how it

 could be anticipated that other NOSB members or members of the

 public can seriously, honestly or completely review what is put forth.

That said, it is my intent to try to participate for as long as what is put

 forth is at minimum listened to if not incorporated or followed in

 terms of reaching the desired goal in a timely and functional manner.

To be quite candid, however, it is unclear what the desired goal is at

 this time. For that reason alone it may be that each participant is

 working from their individual place of consideration, and not an

 agreed upon shared goal that we all strive to attain.

Since my understanding and desire is that it is very important for

 there to be NOSB - NOP collaboration, as noted on page 8 of the

 draft PPM, we must remember that this is significant for both NOSB

 members and employees of the NOP to share that the word at hand

 means, 'working together'. For that very reason, the implications of

 the word, "facilitated" in the second paragraph of that section E is

 somewhat divisive. Words such as, "sought" or, "encouraged" would

 make much more sense.

In any case below my desire is to mention at least the first read

 thoughts that came to me...

• p.4 - do NOT delete "supporting"

• p.8 - see above

• p.12 - section J. therein states, "...and COI" but the section does not

 go into COI, which is really a part of section K. That referral should

 be removed.

• p.16 (or so) - usually COI includes recusal from discussion and or

 from voting. The way this is presented, it is only tracked or even

 publicly referred to regarding the vote and that is incomplete.

• p.16 - IV. Subcommittees A. "sonducting" not right. should be,

 "facilitating", "considering", "seeking", etc.
• p.16 - 1. PDS description. Does not match from previous PPM.

Who modified and why is, "NOP request" required?!?

• p. 17 - 2. List (as in section above), "The current ad hoc

 subcommittees include GMO".

• p.19 - E. include parts that were tried and changed over time and

 lots of experience in terms of the appointment timings post election

 and for subcommittee roles.

• p. 20 - 7. where is the 'new member mentorship' part?

• p.21 - re: minority wording, NOT clear how it is not acceptable

 after a vote when it does not need to exist until a vote happens. Who

 has tried this strategy and when and how effective was it within the

 NOSB? This is academic conjecture and not what works within the

 system in place.

• p.22 - petition process references disturbing since now NOSB

 members are listed as able to submit petitions, and it is seriously

 unclear how the unique role does not seriously imply COI and also

 how it is not perceived as discrimination since those who are not in

 offices with staff and finances accessible (such as any actual farmer

 member which is 27% of the total) could seriously be able to

 consider such an option.

• p.23 - 3rd to last paragraph does not read...

• p.25 - 2. "NOP decides" should read more collaboratively, such as,

 "NOP reviews"

• p.27 - VI. Withdrawals. None should be permitted after vote. If

 starts should go through whole process to NOSB public vote. No

 exceptions or compromise as a policy!

• p.28 - should be clarified why a comment made at the 2nd meeting

 stage can be called, "untimely". Otherwise unfair to those who

 arbitrarily receive such determination.

p.30 - Unclear why the National List Manager would be identified in

 the PPM as potential parliamentary advisor to the Chair. Why

 instead not state, "NOP representative" so that it is open to holders of

 various positions and/or a consultant depending upon staff at a given

 moment?

My intent is to be ready for discussions on the items that were in the

 email list as well, though there is some overlap above and list

 (below).

As has been my understanding since growing up with 10 siblings, it

 is hard/impossible/dysfunctional to be following rules or procedures

 that are being created on the fly, so my opinion is that NOSB can

 and should have internal policies well in place BEFORE ever taking

 any action, even if being put forth as trial. Time and experience

 mean that things can get adjusted and improved. Starting anew and

 coming up with policies based on an end point reaction and not

 agreed upon goals can never hold over time and the role of the

 NOSB is to advise, with our input to be considered and as stated

 above, it is my hope that these thoughts are helpful for the shared

 goal of improving things (for which we all have differing views of
 best choices).

As an advisor of the public opinion or organic matters, there must be

 adequate time and involvement of the public to ensure that our

 internal policies and procedures are well understood and will be

 followed by all members. Transparency means we must allow

 enough consideration and review at both the NOSB level and the

 timing for public considerations. As stated at the beginning of this

 message, it is my observation and experience that it will be

 insufficient time for serious and complete public reviews within the

 present system of available time with all of the other items needing

 attention. It should therefore be recognized that if put forth that said

 process will need to happen again at the next public meeting after

 preliminary changes, and if this is agreed upon then it should be so

 put forth to the public with the anticipated process shared.

Until the morrow,

Colehour

On Jun 10, 2015, at 10:13 AM, Brown Rosen, Emily - AMS wrote:

Hi all,

Here is the long awaited revision of the PPM, incorporating comments

 from the earlier meeting and those sent in by Jean and Tracy. I have left

 these changes in track changes mode.

I think this list below includes the significant changes that need

 discussion.

1. Section III D3 -Role of Secretary - page 8

2. Work agendas , Section III F Page 9

3. Standards of Conduct, Sect III J -1-2 page 14

4. Task forces – Section IV C page 19

5. Minority view Section IV F 1 page 21

6. Substance review – Roberts rules Section 1V G 6 page 25

7. Changing annotations or classification IV G 2 page 25, also

 mentioned under III F examples of work agenda items page 10

8. Additional considerations for TRs, IV G 3 page 26

9. Sunset review process, Sect VII page 27

10. Withdrawal of petitions sect IV G 6, page 28

11. ref to Roberts Rules – Section V B , C page 30-31

12. Remove appendix one, Procedures for Nat List petitions p.39

Do not worry about problems with numbering, bullets or indents. This

 seems to be a little unstable when it goes to different computers, but I
 assure you, it looks fine in my version.

How about we schedule a make-up meeting for PDS in June: does June

 30, 3 pm Eastern work? It looks like there is crops and handling, but no

 livestock call that day.

Thanks,

Emily

Emily Brown Rosen

Specialist, Standards Division

USDA-AMS-NOP

www. ams.usda.gov/nop

609-737-8630 NJ office

 cell

<PPM 06-10-15.docx>

(b) (6)
From: McEvoy, Miles - AMS

To: David Miskell; "Dave Chapman"

Cc: "Jean Richardson"

Subject: RE: response to our meeting on 1/30/14

Date: Sunday, February 02, 2014 8:55:59 AM

Mark Lipson is USDA’s Organic Policy Coordinator. Melissa Bailey is NOP Standards Division Director.

 Jenny Tucker is NOP Associate Deputy Administrator.

Miles V McEvoy

Deputy Administrator

National Organic Program

From: David Miskell [mailto:misktome@gmavt.net] 

Sent: Saturday, February 01, 2014 7:23 PM

To: McEvoy, Miles - AMS; 'Dave Chapman'

Cc: 'Jean Richardson'

Subject: RE: response to our meeting on 1/30/14

Who are the usda persons that miles is ccing? Are they his bosses? Should we be ccing ann?

david

From: McEvoy, Miles - AMS [mailto:Miles.McEvoy@ams.usda.gov] 

Sent: Saturday, February 01, 2014 8:15 AM

To: Dave Chapman

Cc: Jean Richardson; Davey Miskell; Nicole Dehne; Eliot Coleman; Tom Berry; Lipson, Mark - OSEC;

 Bailey, Melissa - AMS; Tucker, Jennifer - AMS

Subject: Re: response to our meeting on 1/30/14

Hi Dave,

I've been thinking a lot about hydroponics as well. I appreciate your perspective. Rather than

posting your summary of NOP's perspective I would ask that you allow NOP to provide you

with our position. That should help clarify things and provide ideas for moving forward.

Thanks and have a great day,

Miles V McEvoy

Deputy Administrator

USDA National Organic Program

On Jan 31, 2014, at 2:40 PM, "Dave Chapman" < wrote:

Hi Miles,

I have been thinking a lot about our talk yesterday. You are very generous with your time,

 and I appreciate your effort to listen to all sides. Having said that, we must still agree to

 disagree. From my perspective, the NOP is in the process of redefining the term Organic. I

 know that it is the NOP's mission to define and protect organic farming in America, but I

 think that when you decide to include hydroponic growing under that definition, you are

 departing from the commonly agreed upon meaning of the term. For the past 70 years,

 organic farming has meant farming based on managing the organic matter and life in the

 soil. Thus the name "Organic". That is what the term means to the vast majority of organic

(b) (6)
 farmers in America, and that is what it means to the vast majority of the countries in the

 world that have organic certification. That is what it means to the NOSB by an

 overwhelming majority, and it is what is stated in the organic standards. What I am saying

 is that the NOP that is taking a radical position here, not us. We farmers are only only

 agreeing with the definition that has always existed for organic farming. And I would

 suggest that it is NOT the task of the NOP to redefine organic farming, but rather to protect

 organic farming.

When I asked you why you supported the inclusion of hydroponic growing in organic,

 despite such strong opposition from American organic farmers, the NOSB, and the world

 community, you said that wanted to embrace innovation for organic farming. I support

 innovation too. Organic farmers are innovating every day. In fact ALL farmers are

 innovating every day. You can barely avoid getting dizzy seeing the prodigious rate of

 change. But hydroponic growing is hardly a new idea, as it has already completely

 supplanted soil growing in the world of conventional greenhouse vegetable production.

 Virtually all conventional greenhouse vegetables in Europe and North America are grown

 hydroponically. Organic farmers are about the only ones left in the soil. it seems that

 hydroponic growing is doing very well without any support from the NOSB. It is authentic

 soil grown organic farming that needs your support. It is more difficult and more expensive

 in the soil, but it is not impossible. Organic growing DOES work in greenhouses as well as

 in the fields. I invite you to visit some of the organic greenhouses in Vermont, and see for

 yourself. We have twenty acres of soil grown organic vegetable production in Vermont

 greenhouses. 

You and I also discussed whether there is a possibility of some sort of compromise on

 these issues, and the question of a "hydroponic organic" label came up. I have thought all

 evening, and asked myself whether I could support this. I have also discussed this today

 with others working on this petition drive. We all agreed that we cannot support that

 compromise. It still implies that hydroponic growing is just a variation of organic farming.

 And we just don't think that is correct.

I WOULD support a new label that certified "unsprayed hydroponic". It was suggested that

 many consumers don't care about whether produce is grown in the soil, and all they are

 really concerned about is the use of pesticides. I would happily support a different label

 that said just that. I know that it is not the job of the NOP to develop such a certification

 program, but certainly the hydroponic growers could do that for themselves with your

 encouragement, just as we early organic growers did before the government got involved.

 We promoted our food as organically grown. We developed standards that we could all

 agree on (often with long meetings to resolve the minor differences), and we developed

 labels that earned the trust of the people who bought the food. Certainly that is a choice for

 the unsprayed hydroponic growers now. If consumers really don't care about whether the

 produce is grown in the soil, then they should readily accept the new label. Everybody

 wins.

I don't think that it is the job of the NOP to certify hydroponic produce as organic just

 because it is unsprayed. You said that it is being certified now because it isn't in violation of

 any standards. That is only because the NOP has failed to set standards that close the

 loophole by acting on the NOSB recommendation. It is time to move to rejoin the

 international community standards for organic farming. As we discussed, food grown with

 GMO seed could conceivably be grown in accordance with organically approved fertilizers,

 insecticides, and practices, and still not be able to be certified organic. That is because the

 NOP took a stand, and banned GMO from organic growing. Certainly GMOs are

 innovative, but they are still not organic. It is time for the NOP to take a stand once again. I

 hope that you will act to restore the organic community's trust in the NOP process and

 standards.

Many thanks for your time,
Dave Chapman

PS. I am attaching others to this response, and I will probably post it on our website. Please

 let me know if I have misrepresented your position in any way.

This electronic message contains information generated by the USDA solely for the intended

recipients. Any unauthorized interception of this message or the use or disclosure of the

information it contains may violate the law and subject the violator to civil or criminal

penalties. If you believe you have received this message in error, please notify the sender and

delete the email immediately.
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: response to our meeting on 1/30/14

Date: Friday, February 21, 2014 8:30:28 PM

Thank you for sending links

Mac said I was quoted in the Post on hydroponic but I saw just our dear colleague Jay

Sent from my iPad

On Feb 21, 2014, at 6:34 PM, "McEvoy, Miles - AMS" <Miles.McEvoy@ams.usda.gov>

 wrote:

Hi Dave and others,

Here is a link to a brief statement about organic hydroponics within the USDA organic

 regulations - Agricultural Marketing Service - Home. Thanks.

Miles V McEvoy

Deputy Administrator

National Organic Program

From: Dave Chapman [mailto:

Sent: Friday, January 31, 2014 2:40 PM

To: McEvoy, Miles - AMS; Jean Richardson; Davey Miskell; Nicole Dehne; Eliot Coleman;

 Tom Berry

Subject: response to our meeting on 1/30/14

Hi Miles,

I have been thinking a lot about our talk yesterday. You are very generous with your time,

 and I appreciate your effort to listen to all sides. Having said that, we must still agree to

 disagree. From my perspective, the NOP is in the process of redefining the term Organic. I

 know that it is the NOP's mission to define and protect organic farming in America, but I

 think that when you decide to include hydroponic growing under that definition, you are

 departing from the commonly agreed upon meaning of the term. For the past 70 years,

 organic farming has meant farming based on managing the organic matter and life in the

 soil. Thus the name "Organic". That is what the term means to the vast majority of organic

 farmers in America, and that is what it means to the vast majority of the countries in the

 world that have organic certification. That is what it means to the NOSB by an

 overwhelming majority, and it is what is stated in the organic standards. What I am saying

 is that the NOP that is taking a radical position here, not us. We farmers are only only

 agreeing with the definition that has always existed for organic farming. And I would

 suggest that it is NOT the task of the NOP to redefine organic farming, but rather to protect

 organic farming.

When I asked you why you supported the inclusion of hydroponic growing in organic,

 despite such strong opposition from American organic farmers, the NOSB, and the world

 community, you said that wanted to embrace innovation for organic farming. I support

 innovation too. Organic farmers are innovating every day. In fact ALL farmers are

 innovating every day. You can barely avoid getting dizzy seeing the prodigious rate of

 change. But hydroponic growing is hardly a new idea, as it has already completely

(b) (6)
 supplanted soil growing in the world of conventional greenhouse vegetable production.

 Virtually all conventional greenhouse vegetables in Europe and North America are grown

 hydroponically. Organic farmers are about the only ones left in the soil. it seems that

 hydroponic growing is doing very well without any support from the NOSB. It is authentic

 soil grown organic farming that needs your support. It is more difficult and more expensive

 in the soil, but it is not impossible. Organic growing DOES work in greenhouses as well as

 in the fields. I invite you to visit some of the organic greenhouses in Vermont, and see for

 yourself. We have twenty acres of soil grown organic vegetable production in Vermont

 greenhouses. 

You and I also discussed whether there is a possibility of some sort of compromise on

 these issues, and the question of a "hydroponic organic" label came up. I have thought all

 evening, and asked myself whether I could support this. I have also discussed this today

 with others working on this petition drive. We all agreed that we cannot support that

 compromise. It still implies that hydroponic growing is just a variation of organic farming.

 And we just don't think that is correct.

I WOULD support a new label that certified "unsprayed hydroponic". It was suggested that

 many consumers don't care about whether produce is grown in the soil, and all they are

 really concerned about is the use of pesticides. I would happily support a different label

 that said just that. I know that it is not the job of the NOP to develop such a certification

 program, but certainly the hydroponic growers could do that for themselves with your

 encouragement, just as we early organic growers did before the government got involved.

 We promoted our food as organically grown. We developed standards that we could all

 agree on (often with long meetings to resolve the minor differences), and we developed

 labels that earned the trust of the people who bought the food. Certainly that is a choice for

 the unsprayed hydroponic growers now. If consumers really don't care about whether the

 produce is grown in the soil, then they should readily accept the new label. Everybody

 wins.

I don't think that it is the job of the NOP to certify hydroponic produce as organic just

 because it is unsprayed. You said that it is being certified now because it isn't in violation of

 any standards. That is only because the NOP has failed to set standards that close the

 loophole by acting on the NOSB recommendation. It is time to move to rejoin the

 international community standards for organic farming. As we discussed, food grown with

 GMO seed could conceivably be grown in accordance with organically approved fertilizers,

 insecticides, and practices, and still not be able to be certified organic. That is because the

 NOP took a stand, and banned GMO from organic growing. Certainly GMOs are

 innovative, but they are still not organic. It is time for the NOP to take a stand once again. I

 hope that you will act to restore the organic community's trust in the NOP process and

 standards.

Many thanks for your time,

Dave Chapman

PS. I am attaching others to this response, and I will probably post it on our website. Please

 let me know if I have misrepresented your position in any way.

This electronic message contains information generated by the USDA solely for

 the intended recipients. Any unauthorized interception of this message or the use

 or disclosure of the information it contains may violate the law and subject the

 violator to civil or criminal penalties. If you believe you have received this
 message in error, please notify the sender and delete the email immediately.
From: McEvoy, Miles - AMS

To: Jean Richardson

Cc: John Foster (jfoster@ebfarm.com); Mac Stone (mac@elmwoodstockfarm.com); Nick Maravell; Jay Feldman;

Tracy Favre; Tucker, Jennifer - AMS; Harold Austin; Carmela Beck; Calvin Walker; COLEHOUR BONDERA;

Arsenault, Michelle - AMS; Brown Rosen, Emily - AMS

Subject: RE: request to reactivate the PDS

Date: Thursday, September 18, 2014 7:20:26 AM

Hi Jean,

We agree that the NOSB PPM needs revision and we look forward to supporting the work of the NOSB Policy

 Development Subcommittee in updating/revising the PPM. We look forward to discussing in more detail on

 October 14. We will provide some additional background material prior to the meeting on the 14th.

Miles V McEvoy

Deputy Administrator

National Organic Program

-----Original Message-----

From: Jean Richardson [mailto

Sent: Friday, September 12, 2014 4:39 PM

To: McEvoy, Miles - AMS

Cc: John Foster (jfoster@ebfarm.com); Mac Stone (mac@elmwoodstockfarm.com); Nick Maravell; Jay Feldman;

 Tracy Favre; Harold Austin; Carmela Beck; Calvin Walker; COLEHOUR BONDERA; Arsenault, Michelle - AMS;

 Brown Rosen, Emily - AMS

Subject: request to reactivate the PDS

Hi Miles: attached please find a request from the PDS to re-activate the Policy Development subcommittee, meet

 by teleconference call on October 14, and place on the Workplan the PPM.

Thank you

Jean

(b) (6)
From: McEvoy, Miles - AMS

To: Harold Austin

Cc: Brown Rosen, Emily - AMS; Arsenault, Michelle - AMS; Carmela Beck; John Foster; 

Subject: RE: Request to add item to the CACS workplan

Date: Monday, July 14, 2014 3:55:31 PM

Thanks Harold.

Is there a memo that comes along with the email?

Miles V. McEvoy

Deputy Administrator

National Organic Program

1400 Independence Ave. SW

Washington, DC 20250-0268

202-720-3252

www.ams.usda.gov/nop

Organic Integrity from Farm to Table, Consumers Trust the Organic Label

From: Harold Austin [mailto:HaroldA@Zirklefruit.com] 

Sent: Tuesday, July 08, 2014 3:42 PM

To: McEvoy, Miles - AMS

Cc: Brown Rosen, Emily - AMS; Arsenault, Michelle - AMS; Carmela Beck; John Foster;

Subject: Request to add item to the CACS workplan

Miles,

Per our discussion during the last NOSB Executive Committee call I have moved forward with a draft discussion

 document on " Best Practices and Use of Annotations in Proposals and Final NOSB Recommendations". We

 briefly went over it on our CACS sub-committee call today.

On behalf of the Compliance, Accreditation and Certification Sub-committee we would like to

1st request the NOP's approval to add this to our CACS Work Plan ?

2ndly to request how you would prefer that we title this document for future reference?

While Carmela is the sub-committee chair I was asked to send you this memo. We shall await your response and

 your valued input.

Warmest Regards,

Harold V. Austin IV

Member of the CACS

This electronic message contains information generated by the USDA solely for the intended

recipients. Any unauthorized interception of this message or the use or disclosure of the

information it contains may violate the law and subject the violator to civil or criminal

penalties. If you believe you have received this message in error, please notify the sender and

delete the email immediately.

(b) (6) (b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Fwd: Request for an interview

Date: Thursday, May 16, 2013 10:30:03 AM

FYI

Begin forwarded message:

From: Jean Richardson <

Date: May 16, 2013 10:26:03 AM EDT

To: Mark Keating <tenorganicfarms@earthlink.net>

Subject: Re: Request for an interview

Hi Mark:

Thank you for your e-mail request of May 15th to interview me about how the 

NOSB arrived at its decision on antibiotic spraying for Fireblight control.

Because the tetracycline vote had received so much prior national publicity in the 

press, TV, and radio, and overwhelming public comment, the NOSB Chair asked

each NOSB member to state their position regards this complex issue. In making 

their decision members had read extensively on the subject, analyzed the issue 

relative to the materials checklist and former Board actions, and attended site

visits to a diversity of orchards. Every member spoke clearly prior to voting. That 

transcript is public record.

As a person with a background in the sciences, law and policy, and considerable 

practical experience in agriculture, I work hard to see both sides of an issue before

 making a decision on the NOSB. I read with interest your previously published 

Acres article on use of antibiotics for apple and pear production ( attached to your

 e-mail) and I am not sure that I can add any more to your discussion on this issue,

 especially given your characterization of the NOSB as back seat drivers and the 

NOP/NOSB as "arm chair standard setters". It is my experience that the NOSB 

works very hard every week of the year to provide a diversity of perspectives 

which will advance organic agriculture for both national and international

markets.

I look forward to reading further articles which you write on organic certification, 

and would be happy to talk with you about general NOSB work, or up coming 

issues.

Sincerely

Jean Richardson Ph.D.

On May 15, 2013, at 11:08 AM, Mark Keating wrote:

<Transitions49.docx>

(b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Fwd: Remind me again: Who wants GMO labeling?

Date: Sunday, September 14, 2014 7:52:37 PM

Hi Miles

Who is this guy?

Jean

Sent from my iPad

Begin forwarded message:

From: Organic Authentication <authentication@isitorganic.ca>

Date: September 11, 2014 at 7:14:40 PM EDT

To:

Subject: Remind me again: Who wants GMO labeling?

Dear Jean:

Remind me again: Who wants GMO labeling?

Let’s see... not consumers, not farmers. And no... not even organic consumers and

 certainly not organic farmers.

The only people who want genetically-modified foods labelled are urban organic

 activists and... wait for it... GMO executives.

Why would executives at the helm of corporations like Monsanto, Bayer and Syngenta,

 along with executives from every farm bureau, commodity and industry group across

 the land, seek to “engage” with anti-GMO organic activists in the hope of finding --

 wait for it -- a “consensus” on GMO labelling, when there's been nothing but

 consensus between GMO and organic farmers for well over 20 years now?

Please read the latest article I wrote with the help of Dr. Jay Lehr and Dr. Klaus Amman:

http://www.consumeraffairs.com/news/remind-me-again-who-wants-gmo-labeling082514.html

Mischa Popoff, B.A. (Hons.) U. of S.

Former USDA contract organic inspector

Author of Is it Organic? The inside story of the organic industry

 Some people won't like this book, but you will

Policy Advisor for The Heartland Institute

Research Associate for The Frontier Centre for Public Policy

Greenville TX USA

903-456-1368

For consulting and expert testimony, visit polyphase.us

(b) (6)
For public speaking engagements, please contact the National Speakers Bureau

If you do not want to receive any more emails on this subject, reply to this email with REMOVE in the subject line.
From: Jean Richardson

To: COLEHOUR BONDERA

Cc: Ashely Swaffar; CALVIN WALKER; Carmela Beck; Francis Thicke; Harold Austin; Jennifer Taylor; Lisa de Lima;

Mac Stone (mac@elmwoodstockfarm.com); Nick Maravell; Arsenault, Michelle - AMS; Paula Daniels; Tom

 Chapman; Tracy Favre; Zea Sonnabend; Brown Rosen, Emily - AMS; McEvoy, Miles - AMS; Tucker, Jennifer -

 AMS; Brines, Lisa - AMS; Pattillo, Devon - AMS; Walden, Jessica - AMS

Subject: Re: Recommendation procedure

Date: Monday, June 01, 2015 9:06:22 AM

Hi Colehour -

1. As I am sure you know, the motion to remove is a construct which we developed in order to ensure that, under the

 revised Sunset process, a subcommittee vote to remove gets posted in the Federal Register, and moved to the full

 NOSB for discussion and vote after public comment.

2. The subcommittee vote also serves to provide some indication to the stakeholders/ public of the potential for

 actual Vote to Remove passing at the full board meeting.

3.This subcommittee vote, which appears in our Federal Register posting, provides legal "Notice" to the public, with

 enough detailed analysis to promote discussion, garner public input, and leave a clear historical record of the

 Board's analysis and concerns.

4. Such Notice in advance encourages public comment to address our concerns.

5. Listening to public comment in SanDiego indicates that the public understands this process. And reading the

 detailed written comment which many stakeholders provided in April indicates that this Sunset Review process is

 working.

6. As we all know, the purpose of the Motion and Second is simply to get the subject on to the table in order to be

 discussed.

A subcommittee cannot make a final decision.

If you personally do not want to make a Motion to Remove then some one else can do so on the subcommittee.

If you wish to vote to retain a material on the list then please vote that way at subcommittee level.

7. Clear Intent:

I agree with you that this is a cumbersome process. I agree that our Policy and Procedure Manual needs updating. In

 October 2014 we all clearly presented for the historical record our perspectives and concerns about the new Sunset

 Review. But despite those misgivings I am sure we can all agree that we want to make sure that substances that do

 not meet the OFPA criteria, based on new data, and/or are no longer necessary, are removed from the National List

 in a timely manner. We have been provided with many new TR's. Our subcommittee members are working

 incredibly hard, submitting their work, meeting every week, to ensure excellent, accurate analysis and

 recommendations. I am confident we can remove many substances. And I am confident that our work in cleaning

 up the National List and proposing annotations is the right thing to do for the organic community. I am sure that no

 NOSB Board has ever done such a good job at Sunset Review. We are being consistent with our approach to

 analysis of each substance. Our intent is clear.

So, even though we may not love the process, we are indeed upholding the integrity of organics.

It would be easy to get lost in the minutia of process. We could spend the entire four days of the Board meeting in

 October debating and get nowhere. We could block all votes. But I know that you will be as happy as I will be

 when we look back at the end of the October meeting and see how many substances we have been able to remove

 from the List.

I know that this is hard for you, but I do hope you can work with me and the Board to keep working with this

 process, and remove as many substances as data and analysis justifies.

Very Best Regards,

Jean
On Jun 1, 2015, at 12:13 AM, COLEHOUR BONDERA wrote:

> Aloha Jean -

>

> My apologies in advance for any redundancy to this observation/question(s), however after our recent call (May

 26, 2015) on the Livestock Subcommittee it is unclear to me what procedure is being followed to make Sunset

 material Recommendations.

>

> Specifically, my inquiry is how a member of any subcommittee is permitted to make a Recommendation for

 which they then vote in opposition. According to all procedures that I have ever followed or understood, the maker

 of the motion can and should and does support the motion they make.

>

> In terms of the Sunset process now being used, where does it appear in either NOSB or NOP by-laws or some

 other clear and accessible rule-book that an item can be moved to be removed or de-listed from the Nation List and

 then voted against by the maker?

>

> If there is no such procedure in documented reviewed and accepted policy form, the votes taken are out of order I

 believe, and I ask that of both yourself and the NOP members receiving this email.

>

> What is truly unclear is why the motion made is simply instead not to re-list said materials for the Sunset

 consideration? That approach would mean that a "Yes" vote would permit re-listing and would typically (the vast

 majority of times) be what is supported. Only in the rare cases (I estimate about 10% of the time or less) of Sunset

 items sought to be de-listed by all involved would there be an issue with the maker of the motion wanting to vote

 one way but needing to otherwise consider.

>

> Again, while it may be clear as a slow running brook to you all, it is cumbersome and bothersome to me as an

 active member to be making and considering votes on things that are blatant false-hoods and have nothing to do

 with the intent at hand.

>

> If no one wants to remove an item from the list and to so move, the Chair in question at the moment could and

 should serve as the back-up (according to an updated PPM) and make a motion to so engage and vote that way for

 the item to move ahead to the full NOSB. Said vice-Chair can be the way that a second is certain to happen.

>

> Again, my concern is both public and historical, and more-so NOSB member clarity in terms of what these

 motions and votes mean, as well as why they are happening in the way they are which is so inconsistent with both

 NOSB history, but also Roberts Rules and all other internal organizational procedures I have followed. Unless

 there is something which states this as a by-law procedure, it is full out of order in terms of how votes can be

 managed and I again (as I stated I apologize for redundancy) request that this detail of how the votes are managed

 be pointed out to us all where it occurs in what written procedure that we are following (not policy directive or

 email of explanation, but an approved and established procedure).

>

> Truly and based on how a procedure inquiry was handled at the meeting in La Jolla, it is unclear to me if policy if

 being fabricated based on no precedent and no functional logic that can be built upon, and that is the basis of this

 question. As was stated in La Jolla, procedure can be followed if so chosen, but shouldn't we all know about in

 advance and be following the same decisions instead of being at the whim of what will get the results desired?

>

> There are several items that I am the lead person on which need to stay as listed during Tuesday, June 2, 2015

 Crops call. It will NOT be possible for me to make motion(s) to remove said items as listed knowing that my

 subsequent vote will be to not remove. If the Chair or others want to so engage it is their choice, but it seems that it

 is expected that the lead person make said motions, and I am not willing to make motions that are not honest.

>

> Thanks in advance, and sorry if I am some kind of lone wolf crying out my concerns to an audience who feels that

 everything is going smoothly, since for me it is not only about change, but really feel very uncomfortable about the

 process that we are following to uphold and protect the purity and integrity of organics!
>

> Cordially,

>

> Colehour
From: Jean Richardson

To: Francis Thicke

Cc: Arsenault, Michelle - AMS; "Ashely Swaffar"; "Calvin Walker"; "Colehour Bondera"; "Mac Stone"; "Paula Daniels"; 

"Tracy Favre"; Brown Rosen, Emily - AMS; McEvoy, Miles - AMS; Brines, Lisa - AMS; Updike, Scott - AMS

Subject: Re: Question on synthetics in homeopathic remedies

Date: Friday, July 24, 2015 8:29:32 AM

Interesting question:

What may actually happening is that a lot of people are confusing the word homeopathy with 

other types of medicines. It is important to find out exactly what med is being discussed and 

see if it is actually a herbal mixture or a salve of some sort in a synthetic base. I have not yet 

heard of a certifier actually prohibiting the use of a real homeopathic medicine in its pure pill

or liquid form. It would be good to know if that is indeed happening... but so far it is all 

turning out to be mis use of terminology.

Jean

On Jul 24, 2015, at 7:59 AM, Francis Thicke wrote:

I received the email below from a veterinarian who works with organic livestock 

producers. She was inquiring about how apparently some certifiers are restricting the 

use of some homeopathic remedies. I am wondering if the NOSB or NOP has addressed

 this issue before.

The homeopathic remedies being rejected are those made with synthetic ingredients. 

Of course, it makes sense to not allow homeopathic remedies made from synthetic 

ingredients that are not on the National List. On the other hand, it can be argued that 

some homeopathic remedies are so dilute that there is a low probability that there is 

even a single molecule of the original ingredients left in the homeopathic remedy.

Has the NOSB/NOP ever looked at this issue?

Thanks,

Francis

This is an excerpt from the veterinarian’s email introducing me to a veterinarian from 

New Zealand who is wondering how the NOP policy on homeopathic remedies will 

affect New Zealand organic producers:

These introductions stem from the email Hue sent to the O Dairy list a few days ago, 

where he was asking about homeopathy and certified farms. Apparently the certifying 

agency is attempting to put some limits on the types of homeopathic medicines they 

will allow on organic farms - and they want to eliminate medicines whose ingredients 

are interpreted as chemical or synthetic.
(So, for example, medicines like Ammonium tart and Hepar sulph would be 

eliminated..... because they are made from compound ingredients....)

In New Zealand, all homeopathic medicines are approved for use by veterinarians in 

practice.

Since the New Zealand certifying agency looks to the NOP for their direction and 

directives, Susanna would like to see if there is any paper trail or documentation in the 

states that indicates that homeopathic medicines are allowing in certified organic 

production. She'd also like to get a sense of what's happening at the NOSB level around

 this.
From: Jean Richardson

To: McEvoy, Miles - AMS; Mac Stone; John Foster; Bailey, Melissa - AMS

Subject: Putting Sunset to bed?

Date: Wednesday, May 14, 2014 3:22:38 PM

With the old "Sunset" a substance would drop off the list or be re-listed following review.

There is no "Sunset" like that now, and the word creates angst.

How about replacing it with "Five Year Review". I know that we use the term "Sunset 2015", 2016 etc . and one

 word is simple, but does it make sense to change the language a bit to reflect the new procedure? Move on with

 life?

Jean
From: Jean Richardson

To: Tracy Favre; Tom Chapman; Harold Austin; Zea Sonnabend; Carmela Beck; Walker Calvin

Cc: Arsenault, Michelle - AMS; Brown Rosen, Emily - AMS; McEvoy, Miles - AMS; Tucker, Jennifer - AMS

Subject: Public Comments pre-meeting

Date: Friday, May 22, 2015 3:01:47 PM

Hi Executive & NOP

Following up from our last Exec, I have been thinking about dates to have a public comment session, after Federal

 Register Posting (Sept 8) and before close of public comment period (October 5), in order to potentially improve

 access for the public while reducing hours of public comment at the October meeting:

Could we we look at using two Tuesdays, September 22 and 29, from 1 pm until 4 pm ET.?

These are times when we normally would have subcommittee meetings so all NOSB Members should be able to

 listen in to the Sessions- which would be recorded of course-, and we can be sure that West Coast participants could

 attend.

Could you let me know if these seem like good dates. Things move slowly in DC so we should plan dates soon so as

 to be sure we have all the right approvals and systems in place

Thank you

jean
From: Jean Richardson

To: Abby Youngblood

Cc: McEvoy, Miles - AMS; Arsenault, Michelle - AMS; Brown Rosen, Emily - AMS; Tracy Favre

Subject: Public Comment via Webinar

Date: Friday, June 26, 2015 1:25:48 PM

Hi Abby

Just to follow up from your call to me last night:

I shared with Miles this morning some of your general concerns over the proposed September Public Comment

 sessions via Webinar and he agrees that we should all get on a phone call.

As you could tell I was a bit surprised and frustrated by NOC's negative perception of the proposed Webinars for

 oral public comment. The NOP and NOSB have been working collaboratively to find ways to increase

 opportunities for greater participation by a broader range of people over a longer period of time, by more

 pathways! The Oral Public Comment by Webinar seems to be a great, modern idea. And yes we keep on working

 to see if we can get a functioning public docket as well. Here's where we need patience!

We are also working to determine how to spread the Review of Sunset materials over more years, and not review

 essentially all of then in one large group every five years as we are right now. This should make the next few years

 much easier for us all.

As we all know, OFPA and the PPM do not lay out highly prescriptive mechanisms for public input. As the organic

 community has grown over the years, the number of individuals wishing to make oral comment at public NOSB

 meetings has grown and somehow we have been able to accommodate everyone while other FACA's hold entirely

 virtual meetings, and limit number of hours for oral comment.

In April in La Jolla we blocked out time for 130 oral commenters which took up almost 2 days ( 11-12 hours) of our

 4 day meeting. To be honest this is really mind numbing. None of us can respectfully listen to all persons and

 absorb and use the information in our decision making the next day. This is not fair to oral presenters or to the

 volunteer Board. We could doubtless sit and listen to public comment for 4 days and get no decisions made.

My goal as Chair for the next 4 months is to continue to work to expand opportunities for a broader cross section of

 public comment in a diversity of ways, using modern technology where possible, reduce our carbon footprint where

 possible, and complete this cycle of Sunset Review. I believe that working together we can do this.

We have doubled up our subcommittee conference calls as needed to work on Sunset Materials in Crops, Handling

 and Livestock, and should have all our Sunset Templates ready for Michelle on August 26, with a September 8

 Federal Register Posting date. We selected the dates of Tuesday September 22 and 29 from 1-4 pm as being days

 when the volunteer Board already has its time blocked out for NOSB work, and thus they can attend both Public

 Comment Webinars. These webinars will, of course, be part of the Public Record and available to listen to again

 before the meeting. Many of us will find this aspect very useful. And we encourage written comments as being the

 best way to inform our decision making and recommendations. As you heard during our Meeting 1 presentations in

 April, the organic community already has a pretty good idea of where we are headed with our materials review so

 public comment can be being developed now.

We hope that the 6 hours of early public comment in September, as a pilot project, will encourage a broader cross

 section of commenters. Presently I am assuming we will allow more time per speaker on the Webinars, perhaps 5

 minutes, instead of the 3 minutes per person in October. Individuals can chose to give oral comment on either a

 September day OR on October 26. We will still have 6 hours of public comment in October, and hopefully we can

 start our public deliberations on Sunset materials on Tuesday morning October 27 and be able to get through them

 all in 3 days. 

I would be most appreciative if NOC would reply to this e-mail with a clear list of concerns, and some realistic

 solutions to the wonderful challenge of having so many people who want to speak to a volunteer Board which is

 trying to complete the Five Year Sunset Review of a large number of materials.
Please help make this October meeting a time for celebrating 25 years of organic agriculture.

Thank you very much, and I look forward to our continued conversation on this in the next week or so.

Very Best Regards, Jean
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: protests at meeting

Date: Tuesday, September 16, 2014 8:25:38 AM

Hi Miles

I just had an interesting discussion with the Louisville Police (Metro) department about handling protesters, city

 ordinances, and permits.

From the protester perspective they need a permit to protest if there are 25 or more.

From the NOP/NOSB perspective, NOP could request a permit "for safety" to put up ropes or other markers to

 constrain where protesters could be located - Your idea of typical meeting room cloth hanging across the square to

 close it off seems like a good one.

All for now

Jean
From: Jean Richardson

To: Tucker, Jennifer - AMS

Cc: McEvoy, Miles - AMS

Subject: Re: Sharing documents and e-mails

Date: Thursday, February 13, 2014 6:50:11 PM

Yup

I agree

Jean

Sent from my iPad

On Feb 13, 2014, at 1:56 PM, "Tucker, Jennifer - AMS" <Jennifer.Tucker@ams.usda.gov> wrote:

> Hi Jean - Thanks for the note. There were some good questions about subcommittee information sharing during

 the training, and we have written to OGC to get some further guidelines.

>

> I am GUESSING that FACA openness rules were not intended to encourage subcommittee members to feel free

 to bcc others on emails (or that anyone may ask to be added to real-time communications), but rather, to establish a

 formal process by which an interested member of the public could request records from the government to better

 understand the Board's decision-making process. That said, as we all know, email is a very malleable tool, and

 there really is no legal or practical way to prevent people from forwarding and bcc:ing people on things if they

 choose to do so.

>

> In my experience, culture generally trumps policy - so my thinking would be that the best thing in this case would

 be for Board members who were upset by Jay's bcc activity to let him know that directly, and ask him, out of

 courtesy to other members, to stop. NOP will certainly send guidelines on sharing requirements, scope, and

 boundaries from OGC when we get them.

>

> Thanks much -

> Jenny

>

> ---------------------------------------

> Jennifer Tucker, Ph.D.

> Associate Deputy Administrator

> USDA National Organic Program

> 1400 Independence Ave SW; Room 2642 (Stop 0268)

> Washington, DC 20250-0268

> Phone: (202) 720-3252

> Jennifer.Tucker@ams.usda.gov

>

> -----Original Message-----

> From: Jean Richardson [mailto

> Sent: Wednesday, February 12, 2014 9:05 AM

> To: Tucker, Jennifer - AMS; McEvoy, Miles - AMS

> Subject: Sharing documents and e-mails

>

> Hi Jenny, Miles

> As Chair of the PDS / ad hoc committee let me know if you want to consult on how best to smooth out / clarify

 this sharing information situation. We could jointly send out an e-mail to all Board?

> I did chat with Jay about the possible problems that could arise from his all inclusive request, but this was before

 the error of the Terry Shistar copy on an e-mail exchange.

> I am trying to help the Board be more of a "team"! Romantic Jean!

> Cheers

> Jean

(b) (6)
>

>

>

>

>

>

> This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

>

From: Jean Richardson

To: Zea Sonnabend

Cc: Arsenault, Michelle - AMS; McEvoy, Miles - AMS; Calvin Walker; Francis Thicke; Jay Feldman; Jennifer Taylor; 

Nick Maravell; Wendy Fulwider; Harold Austin; Colehour Bondera

Subject: Re: Seed Expert Panel Purpose and some bios

Date: Tuesday, December 16, 2014 7:36:44 AM

Hi Zea

This panel seems like a good and timely idea and you have a good group of people to have as 

experts.

I can also suggest as an expert Tom Stearns, High Mowing Seeds, Wolcott, Vermont. He 

sources seeds from many locations nationally and internationally. But you have plenty on your

 list.

Given the various programs which now test and third party certify "gmo-free" can the panel 

address the "process" based verification system used in NOP standards against the testing used

 by these other programs.? This may seem too much, and I have not been on your recent calls 

and you may have already discussed this, but we do have to work within a changing non-gmo

certification context. Many of the organic processors I inspect have been pushed by consumer

 demand to pay for expensive "gmo-free" certification in addition to organic.

Thank you

Jean

On Dec 15, 2014, at 2:45 PM, Zea Sonnabend wrote:

<GMO Prevention Seed Expert Panel.docx>
From: McEvoy, Miles - AMS

To: "Zea Sonnabend"; Arsenault, Michelle - AMS; "Jean Richardson"

Cc: "Calvin Walker"; "Francis Thicke"; "Jay Feldman"; "Jennifer Taylor"; "Nick Maravell"; "Wendy Fulwider"; "Harold

 Austin"; "Colehour Bondera"; Rakola, Betsy - OSEC; Brown Rosen, Emily - AMS

Subject: RE: Seed Expert Panel Purpose and some bios

Date: Thursday, December 18, 2014 3:37:55 PM

Thanks Zea and others that contributed to this. Important topic.

The NOP needs to review budget implications of this expert panel along with other NOSB related

 expenses. It appears that we will have longer meetings this fiscal year, additional technical reports,

 and other NOSB expenses. As Jean requested we will be providing additional information about the

 NOP budget at the spring meeting (now that we have a full year budget).

I’ll get back to you in January on whether we can support an expert panel at the San Diego meeting.

 Again, thanks for your work on this topic.

Happy Holidays,

Miles

Miles V. McEvoy

Deputy Administrator

National Organic Program

1400 Independence Ave. SW

Washington, DC 20250-0268

202-720-3252

www.ams.usda.gov/nop

Organic Integrity from Farm to Table, Consumers Trust the Organic Label

From: Zea Sonnabend [mailto:zea@well.com] 

Sent: Monday, December 15, 2014 2:45 PM

To: Arsenault, Michelle - AMS; McEvoy, Miles - AMS; Jean Richardson

Cc: Calvin Walker; Francis Thicke; Jay Feldman; Jennifer Taylor; Nick Maravell; Wendy Fulwider; Harold

 Austin; Colehour Bondera

Subject: Seed Expert Panel Purpose and some bios

Hi MS and Miles and Jean,

Here is the request for a seed expert panel at the next NOSB meeting, with a purpose

articulated and the bios of some prospective panelists that I and other subcommittee members

suggested.

We will be discussing this again on our next call, which is Jan. 13 and so we are hoping for a

green light to go ahead by then.

Regards,

Zea
On Dec 10, 2014, at 9:12 AM, Arsenault, Michelle - AMS wrote:

Hello Materials,

Attached, please find the notes from the December 9 call for your review. Our next call is scheduled

 for January 13! 2015!! Thanks again for your patience while we had a competing conference call try

 to use our line. Hopefully we have addressed the problem and that won’t happen again!

Thanks,

Michelle

Michelle Arsenault

Advisory Committee Specialist

USDA National Organic Program

1400 Independence Ave SW; Room 2638S

Washington, DC 20250-0268

Office voicemail only: (202) 720-0081

Mobile: 

michelle.arsenault@ams.usda.gov

This electronic message contains information generated by the USDA solely for the intended

recipients. Any unauthorized interception of this message or the use or disclosure of the

information it contains may violate the law and subject the violator to civil or criminal

penalties. If you believe you have received this message in error, please notify the sender and

delete the email immediately.<MS 12 09 14 draft.docx>

(b) (6)
From: McEvoy, Miles - AMS

To: Zea Sonnabend; Arsenault, Michelle - AMS; Jean Richardson

Cc: Calvin Walker; Francis Thicke; Jay Feldman; Jennifer Taylor; Nick Maravell; Wendy Fulwider; Harold Austin;

Colehour Bondera

Subject: RE: Seed Expert Panel Purpose and some bios

Date: Friday, January 30, 2015 5:52:20 AM

Hi Zea,

Thanks again for this proposal. I need to gather some additional information before we can finalize

 plans for the panel. Thanks for your patience.

Miles

Miles V McEvoy

Deputy Administrator

Agricultural Marketing Service

National Organic Program

From: Zea Sonnabend [mailto:zea@well.com] 

Sent: Monday, December 15, 2014 2:45 PM

To: Arsenault, Michelle - AMS; McEvoy, Miles - AMS; Jean Richardson

Cc: Calvin Walker; Francis Thicke; Jay Feldman; Jennifer Taylor; Nick Maravell; Wendy Fulwider; Harold

 Austin; Colehour Bondera

Subject: Seed Expert Panel Purpose and some bios

Hi MS and Miles and Jean,

Here is the request for a seed expert panel at the next NOSB meeting, with a purpose

articulated and the bios of some prospective panelists that I and other subcommittee members

suggested.

We will be discussing this again on our next call, which is Jan. 13 and so we are hoping for a

green light to go ahead by then.

Regards,

Zea

On Dec 10, 2014, at 9:12 AM, Arsenault, Michelle - AMS wrote:

Hello Materials,

Attached, please find the notes from the December 9 call for your review. Our next call is scheduled

 for January 13! 2015!! Thanks again for your patience while we had a competing conference call try

 to use our line. Hopefully we have addressed the problem and that won’t happen again!

Thanks,

Michelle
Michelle Arsenault

Advisory Committee Specialist

USDA National Organic Program

1400 Independence Ave SW; Room 2638S

Washington, DC 20250-0268

Office voicemail only: (202) 720-0081

Mobile: 

michelle.arsenault@ams.usda.gov

This electronic message contains information generated by the USDA solely for the intended

recipients. Any unauthorized interception of this message or the use or disclosure of the

information it contains may violate the law and subject the violator to civil or criminal

penalties. If you believe you have received this message in error, please notify the sender and

delete the email immediately.<MS 12 09 14 draft.docx>

(b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: Scope of work? Strategic plan? Action plan?

Date: Friday, October 31, 2014 4:24:22 PM

OK

Spring and Fall Agendas it is!

Jean

Sent from my iPhone

> On Oct 31, 2014, at 3:14 PM, "McEvoy, Miles - AMS" <Miles.McEvoy@ams.usda.gov> wrote:

>

> I like agenda - like Spring Agenda.

>

> -----Original Message-----

> From: Paula Daniels [mailto:pdaniels@goodfoodla.org]

> Sent: Thursday, October 30, 2014 1:25 PM

> To: McEvoy, Miles - AMS

> Subject: Scope of work? Strategic plan? Action plan?

>

> Some suggestions.

>

> I don't think "Syllabus" makes sense.

>

> I favor "Action Plan"

>

> ________________

> (Sent from my iPad)

>

>

>

>

> This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.
From: Jean Richardson

To: John Foster; joe.dickson@wholefoods.com; Jay Feldman; Harold Austin; Wendy Fulwider; Zea Sonnabend;

tfavre@favrehouse.com Favre; Francis Thicke; Carmela Beck; Colehour Bondera; Jennifer Taylor; Nick Maravell;

Mac Stone; Calvin Walker

Bcc: Arsenault, Michelle - AMS; McEvoy, Miles - AMS

Subject: saying good things about you!

Date: Tuesday, September 30, 2014 5:54:39 PM

Hi Everyone:

At the public meeting we introduce ourselves with a brief statement. In addition to doing that I would like to have a

 few "bullet points" on a slide to be sure the public clearly understands what a great bunch you are!

So can you let me know if you have any awards, job changes etc you would like me to highlight rather than you not

 being sure if you should "blow your own trumpet!" (except for Francis who does blow his own trumpet!). And

 what about being inspected and doing inspections. ? Can you tell me roughly how many inspections you have done,

 or shadowed, and/or roughly how many times you have been inspected.

I am looking forward to the meeting and working with you all as a group.

Cheers from Vermont, where the Fall colors are amazing this year. Leaf peepers here by the thousands taking

 pictures of all those organic red leaves!

Jean
From: Jean Richardson

To: McEvoy, Miles - AMS; Mac Stone; Brown Rosen, Emily - AMS; Jones, Samuel - AMS

Subject: Sarah Flack"s mother is new NOSB chair!!

Date: Tuesday, May 20, 2014 9:25:21 AM

Hi

Thought you might enjoy yesterday's excited announcement to North East Organic Dairy folks

 about the NOSB Chair!

Jean

From: Edward Maltby 

Subject: [NODPA-ODAIRY] FW: New NOSB Chair (Sarah Flack's

mother)+ Sunset Fact Sheet

Date: May 19, 2014 6:48:21 PM EDT

To: ODAIRY@LISTSERV.NODPA.COM

Reply-To: Organic Dairy Producers 

<ODAIRY@LISTSERV.NODPA.COM>

(b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS; Nicole Dehne

Cc: Sarah Flack

Subject: Roundtable Saturday Feb 14

Date: Saturday, January 17, 2015 8:32:13 AM

Hi Miles and Nicole

The NOP Discussion Roundtable, open forum discussion, is Saturday Feb 14 from 1-2 in the Davis Center, 4th

 Floor.

I will moderate and encourage folks to come.

Thank you

Jean
From: Jean Richardson

To: Brown Rosen, Emily - AMS

Cc: Tracy Favre; Colehour Bondera; Arsenault, Michelle - AMS; Jennifer Taylor; Mac Stone

(mac@elmwoodstockfarm.com); McEvoy, Miles - AMS

Subject: Re: revised PPM 7-11-15

Date: Sunday, July 12, 2015 9:06:36 AM

Hi Emily et al

I have reviewed the July 11 PPM and it is looking good.

I think that the Appendix 2 section on FACA probably does not belong in the PPM, but should

 simply be referenced.

On Tuesday I shall be on the road in Pennsylvania earning some income! ..., but I plan on 

being on the call from my mobile.

Thank you

Jean

On Jul 11, 2015, at 11:58 AM, Brown Rosen, Emily - AMS wrote:

<PPM 07-11-15.docx>
From: Jean Richardson

To: Brown Rosen, Emily - AMS

Cc: Tracy Favre; Colehour Bondera; Arsenault, Michelle - AMS; Jennifer Taylor; McEvoy, Miles - AMS

Subject: Re: revised PPM 7-11-15

Date: Friday, July 17, 2015 1:54:23 PM

Hi Emily

Would it be possible for you to generate the next clean version before our next meeting on 

August 11.?

Thank you

Jean

On Jul 11, 2015, at 11:58 AM, Brown Rosen, Emily - AMS wrote:

Hi all,

Here is the revised PPM draft based on changes made during 6-30 meeting. We 

stopped on page 21. I have inserted additional comments from Jean and Colehour in 

track changes mode also, hopefully I got them all,

Regards,

Emily

From: Tracy Favre [mailto:tfavre@favrehouse.com]

Sent: Wednesday, July 01, 2015 3:01 PM

To: Colehour Bondera

Cc: Arsenault, Michelle - AMS; Jean Richardson; Brown Rosen, Emily - AMS; Jennifer 

Taylor; McEvoy, Miles - AMS; Mac Stone (mac@elmwoodstockfarm.com)

Subject: Re: revised PPM 6-10-15

Emily is going to mark up the ppm thru where we left a off and send the newest 

out.

Sent from my iPad

On Jun 30, 2015, at 8:46 PM, Colehour Bondera < wrote:

Anything more happen with this meeting after the drop? 

Sorry that I could not come back as I had a meeting starting at 10:00.

COlehour

On Jun 30, 2015, at 9:59 AM, Arsenault, Michelle - AMS wrote:

I’m back on...weird. I was dropped

From: Jean Richardson [mailto:

(b) (6) (b) (6)
Sent: Tuesday, June 30, 2015 8:26 AM

To: Colehour Bondera

Cc: Brown Rosen, Emily - AMS; Arsenault, Michelle - AMS; Jennifer Taylor; 

McEvoy, Miles - AMS; Mac Stone (mac@elmwoodstockfarm.com); Tracy Favre

 (tfavre@favrehouse.com)

Subject: Re: revised PPM 6-10-15

Hi Colehour

Thank you for your comments.

I agree with you that we need to get this out for public comment .

It is really exciting to see the document coming together in such a 

readable format.

Look forward to our call this afternoon

Jean

On Jun 30, 2015, at 2:03 AM, Colehour Bondera wrote:

Aloha NOSP PDS:

Thank you for your efforts on this Emily (and Michelle!)

To begin, I need to reiterate my most significant general 

observation/feeling, which is that it is overwhelming, inappropriate 

and even untenable to include a large volume of both

structural/presentation changes simultaneously with substantial

content revisions in a document which was put together piece by 

piece and modified through a number of NOSB members over more 

than ten years.

In honesty, my feeling is that as an NOSB member who tries to 

dedicate an average of 20 hours per week to NOSB requirements, that

 completely and seriously reviewing this whole draft would take me 

more time than is possible as a member of other subcommittees. 

While it was read through, it was nearly impossible to make 

comparisons and cross references to the original document without 

spending 5-10 times more time than was viable. Not clear how it 

could be anticipated that other NOSB members or members of the

public can seriously, honestly or completely review what is put forth.

That said, it is my intent to try to participate for as long as what is put

 forth is at minimum listened to if not incorporated or followed in 

terms of reaching the desired goal in a timely and functional manner. 

To be quite candid, however, it is unclear what the desired goal is at 

this time. For that reason alone it may be that each participant is 

working from their individual place of consideration, and not an

agreed upon shared goal that we all strive to attain.

Since my understanding and desire is that it is very important for 

there to be NOSB - NOP collaboration, as noted on page 8 of the 
draft PPM, we must remember that this is significant for both NOSB 

members and employees of the NOP to share that the word at hand 

means, 'working together'. For that very reason, the implications of 

the word, "facilitated" in the second paragraph of that section E is

somewhat divisive. Words such as, "sought" or, "encouraged" would 

make much more sense.

In any case below my desire is to mention at least the first read 

thoughts that came to me...

• p.4 - do NOT delete "supporting"

• p.8 - see above

• p.12 - section J. therein states, "...and COI" but the section does not 

go into COI, which is really a part of section K. That referral should 

be removed.

• p.16 (or so) - usually COI includes recusal from discussion and or

from voting. The way this is presented, it is only tracked or even 

publicly referred to regarding the vote and that is incomplete.

• p.16 - IV. Subcommittees A. "sonducting" not right. should be, 

"facilitating", "considering", "seeking", etc.

• p.16 - 1. PDS description. Does not match from previous PPM. 

Who modified and why is, "NOP request" required?!?

• p. 17 - 2. List (as in section above), "The current ad hoc 

subcommittees include GMO".

• p.19 - E. include parts that were tried and changed over time and 

lots of experience in terms of the appointment timings post election 

and for subcommittee roles.

• p. 20 - 7. where is the 'new member mentorship' part?

• p.21 - re: minority wording, NOT clear how it is not acceptable 

after a vote when it does not need to exist until a vote happens. Who 

has tried this strategy and when and how effective was it within the 

NOSB? This is academic conjecture and not what works within the 

system in place.

• p.22 - petition process references disturbing since now NOSB 

members are listed as able to submit petitions, and it is seriously

unclear how the unique role does not seriously imply COI and also 

how it is not perceived as discrimination since those who are not in 

offices with staff and finances accessible (such as any actual farmer 

member which is 27% of the total) could seriously be able to consider

 such an option.

• p.23 - 3rd to last paragraph does not read...

• p.25 - 2. "NOP decides" should read more collaboratively, such as, 

"NOP reviews"

• p.27 - VI. Withdrawals. None should be permitted after vote. If 

starts should go through whole process to NOSB public vote. No 

exceptions or compromise as a policy!

• p.28 - should be clarified why a comment made at the 2nd meeting

stage can be called, "untimely". Otherwise unfair to those who 

arbitrarily receive such determination.

p.30 - Unclear why the National List Manager would be identified in
the PPM as potential parliamentary advisor to the Chair. Why 

instead not state, "NOP representative" so that it is open to holders of 

various positions and/or a consultant depending upon staff at a given 

moment?

My intent is to be ready for discussions on the items that were in the 

email list as well, though there is some overlap above and list 

(below).

As has been my understanding since growing up with 10 siblings, it 

is hard/impossible/dysfunctional to be following rules or procedures 

that are being created on the fly, so my opinion is that NOSB can and

 should have internal policies well in place BEFORE ever taking any 

action, even if being put forth as trial. Time and experience mean 

that things can get adjusted and improved. Starting anew and coming

 up with policies based on an end point reaction and not agreed upon 

goals can never hold over time and the role of the NOSB is to advise,

with our input to be considered and as stated above, it is my hope that

 these thoughts are helpful for the shared goal of improving things 

(for which we all have differing views of best choices).

As an advisor of the public opinion or organic matters, there must be 

adequate time and involvement of the public to ensure that our 

internal policies and procedures are well understood and will be 

followed by all members. Transparency means we must allow 

enough consideration and review at both the NOSB level and the

timing for public considerations. As stated at the beginning of this 

message, it is my observation and experience that it will be

insufficient time for serious and complete public reviews within the 

present system of available time with all of the other items needing 

attention. It should therefore be recognized that if put forth that said 

process will need to happen again at the next public meeting after

preliminary changes, and if this is agreed upon then it should be so 

put forth to the public with the anticipated process shared.

Until the morrow,

Colehour

On Jun 10, 2015, at 10:13 AM, Brown Rosen, Emily - AMS wrote:

Hi all,

Here is the long awaited revision of the PPM, incorporating comments 

from the earlier meeting and those sent in by Jean and Tracy. I have left 

these changes in track changes mode.

I think this list below includes the significant changes that need 
discussion.

1. Section III D3 -Role of Secretary - page 8

2. Work agendas , Section III F Page 9

3. Standards of Conduct, Sect III J -1-2 page 14

4. Task forces – Section IV C page 19

5. Minority view Section IV F 1 page 21

6. Substance review – Roberts rules Section 1V G 6 page 25

7. Changing annotations or classification IV G 2 page 25, also 

mentioned under III F examples of work agenda items page 10

8. Additional considerations for TRs, IV G 3 page 26

9. Sunset review process, Sect VII page 27

10. Withdrawal of petitions sect IV G 6, page 28

11. ref to Roberts Rules – Section V B , C page 30-31

12. Remove appendix one, Procedures for Nat List petitions p.39

Do not worry about problems with numbering, bullets or indents. This 

seems to be a little unstable when it goes to different computers, but I 

assure you, it looks fine in my version.

How about we schedule a make-up meeting for PDS in June: does June 

30, 3 pm Eastern work? It looks like there is crops and handling, but no 

livestock call that day.

Thanks,

Emily

Emily Brown Rosen

Specialist, Standards Division

USDA-AMS-NOP

www. ams.usda.gov/nop

609-737-8630 NJ office

 cell

<PPM 06-10-15.docx>

<PPM 07-11-15.docx>

(b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Skiing in Vermont

Date: Saturday, March 07, 2015 6:21:23 PM

Attachments: ATT00001.txt
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: Skiing in Vermont

Date: Sunday, March 08, 2015 1:32:53 PM

5.30 tomorrow is fine.

Good luck with animal welfare

Jean

On Mar 8, 2015, at 1:22 PM, McEvoy, Miles - AMS wrote:

> I look stunned by the cold.

>

> I'd like to postpone our weekly chat. I need to meet on animal welfare in the morning. We could talk late Monday

 afternoon - say 5:30 pm?

>

> -----Original Message-----

> From: Jean Richardson [mailto

> Sent: Saturday, March 07, 2015 6:21 PM

> To: McEvoy, Miles - AMS

> Subject: Skiing in Vermont

>

>

>

>

>

>

>

> This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

(b) (6)

From: Jean Richardson

To: Tracy Favre; Harold Austin; Carmela Beck; Zea Sonnabend; Tom Chapman; Calvin Walker

Cc: Brown Rosen, Emily - AMS; McEvoy, Miles - AMS; Arsenault, Michelle - AMS

Subject: Sunset annotation proposals

Date: Friday, June 26, 2015 7:10:43 AM

Hi Exec. Subcommittee

Sunset Review indicates that some materials should be annotated. Such annotations must be proposals separate from

 Sunset Review. Some of the subcommittees have been discussing the desire to prepare proposals to annotate

 materials, and some proposals could be ready for consideration at the October meeting.

In order to be sure the record is clear, could each SC Chair please present to the Exec on the July 12 call, which

 proposals they would like to be able to develop, so the Exec and NOP can discuss and determine if these should be

 added to the SC Work Agendas.

Thank you

Jean
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Sunset and rule making

Date: Friday, January 30, 2015 7:24:22 AM

Hi Miles

Do I have this right?

If the motion to Remove a Sunset material fails then the material stays on the List and no Rule making is needed.

If the motion to Remove passes - such as iodine - then that recommendation to remove must go through Rule

 making.

If we then at the same meeting make a motion to add iodine to the NL with the following annotation xxxx then that

 Proposal must go through Rule making.

So that would be 2 Rule making procedures for one material.

Would it not be better to have one Rule making in such a circumstance?

Jean
From: Jean Richardson

To: McEvoy, Miles - AMS

Cc: Brown Rosen, Emily - AMS

Subject: Sunset

Date: Saturday, October 04, 2014 11:23:15 AM

Hi Miles

Jim Pierce also thinks that an NOP memo on how the votes to re-list should be interpreted under the new Sunset

 procedure should go out to public before the meeting.

Maybe on Tuesday we can finalize wording so you and I say the same thing

Jean
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Starry night cafe tonight at 7

Date: Wednesday, July 11, 2012 5:47:10 PM

Hi Miles:

You have directions OK for tonight?. Dinner at 7 pm

Starry Night cafe, North Ferrisburgh, Rt 7

home phone; if you need to reach me before 6.45,

thereafter cell phone will work, 

Starry night phone: 802-877- 6316

Jean

(b) (6) (b) (6)
From: Jean Richardson

To: Mac Stone

Cc: Arsenault, Michelle - AMS; Calvin Walker; Carmela Beck; Colehour Bondera; Francis Thicke; Harold Austin; Jay

 Feldman; Jennifer Taylor; joe.dickson@wholefoods.com; John Foster; Nick Maravell; Tracy Favre; Wendy

 Fulwider; Zea Sonnabend; McEvoy, Miles - AMS

Subject: Re: Spring 2013 Draft agenda

Date: Friday, February 08, 2013 11:29:40 AM

Hi Mac

thank you for your comprehensive response

sounds OK to me

Jean

Sent from my iPad

On Feb 8, 2013, at 11:20 AM, "Mac Stone" < wrote:

A few of you expressed interest in have balance in the aquaculture (AQ)

 presentation at the Portland meeting. George Lockwood is Chairman of the 12

 member AQ Working Group (AWG). The AWG members were appointed by

 NOP to fulfill a federal register notice to provide draft organic production and

 handling standards for Aquatic animals and plants. The wild fisheries working

 group was never seated. Members of the AWG are volunteer “contractors” for

 the NOP on our behalf. There were no term limits placed on these appointments

 so they can continue to provide input until the standards are codified. His

 presentation should not be viewed as one side of the interest. Dr. Becky Goldburg

 (former NOSB member) is the Environmental Scientist on the AWG and her

 concerns were incorporated into their recommendations. Members of the AWG

 worked very closely with the livestock committee and full board for several years

 during the deliberation of the final recommendation.

The intent is for George to describe who the members are, how the AWG worked

 to develop their recommendation to the NOSB, and their role in helping the

 NOSB make its recommendation to the NOP. His role is not to sell us on AQ but

 get this board up to speed on past conversations of the board that dealt with this

 subject.

Two aspects he has been asked to address is how is organic AQ distinguished

 from commercial AQ and how does organic AQ address environmental concerns.

 This will make for a very full hour, I want to have time for some questions as

 well.

At the fall meeting we plan to have a diverse panel of participants, that represents

 varying viewpoints on organic AQ, not only for presentations, but as technical

 resources as well. Becky and others are being lined up as we speak.

(b) (6)
The LS has scheduled a series of presenters for their upcoming calls for additional

 back ground information. We plan to begin with the environmental concerns.

 Becky is unavailable for the February 19 call, so we may re-arrange the order a

 bit. March 5, George will give the LS info similar to the presentation to full

 board, but also hear what the concerns are and what info the LS needs to help

 with their decisions on materials. March 19 has Jim Pierce from Oregon Tilth to

 lay out what OSP’s must address and what certifiers will be looking for (Jim

 raised aquatic animals for several years). Future calls will address fish meal and

 fish oil which means wild fisheries. All this is for background so individual

 materials will have more context.

Thanks for your understanding on the process to regain knowledge lost thru board

 rotation. There will be plenty of time for debate, and there will be plenty.

Thanks, Mac

From: Arsenault, Michelle - AMS [mailto:Michelle.Arsenault@ams.usda.gov] 

Sent: Thursday, February 07, 2013 10:57 AM

To: Calvin Walker; Carmela Beck; Colehour Bondera; Francis Thicke; Harold Austin; Jay

 Feldman; Jean Richardson; Jennifer Taylor; joe.dickson@wholefoods.com; John Foster;

 Mac Stone; Nick Maravell; Tracy Favre; Wendy Fulwider; Zea Sonnabend

Subject: Spring 2013 Draft agenda

Hello NOSB!

Attached, please find the latest iteration of the agenda (note the revision date of

 Feb 7 at the top). I removed some items that will not be ready for the spring

 meeting, and moved the Inerts WG update from Wednesday afternoon to

 Tuesday morning as was suggested, and I think the schedule feels very

 comfortable. There’s still some flexibility built in to accommodate public

 comments.

Let me know if you have any comments or changes, and if I don’t hear from you

 by Tuesday February 12th, this is the version (edited for external eyes of course)

 that I will post.

I will also place this in Dropbox.
Thanks for all of your input and suggestions! 

Michelle

Michelle Arsenault

Advisory Board Specialist

USDA National Organic Program

1400 Independence Ave SW; Room 2640S

Washington, DC 20250-0268

Office phone: (202) 720-0081

Mobile: 

michelle.arsenault@ams.usda.gov

This electronic message contains information generated by the USDA solely for

 the intended recipients. Any unauthorized interception of this message or the use

 or disclosure of the information it contains may violate the law and subject the

 violator to civil or criminal penalties. If you believe you have received this

 message in error, please notify the sender and delete the email immediately.

(b) (6)
From: McEvoy, Miles - AMS

To: "Angela Jagiello"

Cc: Rakola, Betsy - OSEC; "Jean Richardson"

Subject: RE: Speaking Invitation: All Things Organic (Sept. 17, 2015)

Date: Wednesday, July 22, 2015 8:13:03 AM

Hi Angela –

I look forward to the session.

Miles

Miles McEvoy

Deputy Administrator

National Organic Program

From: Angela Jagiello [mailto:AJagiello@ota.com] 

Sent: Tuesday, July 21, 2015 1:02 PM

To: McEvoy, Miles - AMS

Subject: Speaking Invitation: All Things Organic (Sept. 17, 2015)

Importance: High

Good afternoon,

I am writing to invite you to participate in a panel discussion at the upcoming All Things Organic

 Conference in Baltimore September 17-18, 2015. The conference is co-located with Natural

 Products Expo East – the largest natural products industry gathering on the East Coast.

The session, entitled “Organic Regulatory Update” will offer attendees updates on the activities of

 the USDA, including the National Organic Program, the National Organic Standards Board, and other

 regulatory and policy developments affecting organic. This session is perennially among our most

 informative and well attended. I hope you will consider participating!

Organic Regulatory Update

Thursday, September 17, 2015

12:00 - 1:15 PM 

Organic is the most highly regulated food system in the worlds. Come hear the latest from the

 agencies and individuals at the center of regulatory affairs for this $39 billion sector.

Invited Speakers: 

· Moderator: Gwendolyn Wyard, Senior Director, Regulatory and Technical Affairs,

 Organic Trade Association

· Miles McEvoy, Deputy Administrator, USDA – National Organic Program

· Betsy Rakola, Organic Policy Advisor, USDA – Office of the Secretary

· Jean Richardson, Chairperson, National Organic Standards Board

I look forward to hearing from you with any questions, and hope that you are able to join us!
Kindly,

--Angela Jagiello

________________________

Angela Jagiello

Associate Director, Conference and Product Development

Organic Trade Association (OTA)

Direct: (802) 275-3831

28 Vernon St, Suite 413

Brattleboro, VT 05301
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Speaking in PA?

Date: Tuesday, September 23, 2014 10:28:04 AM

Hi Miles

I have been asked to speak about the NOSB and organic agriculture standards in Pennsylvania - April 12-14, 2015-

 This will be on Ursinus College campus I think, in partnership with the Pennsylvania Association of Sustainable

 Agriculture .

Would you be interested in having me suggest that you also come to that?

cheers

Jean
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Automatic reply: small scale organic certification

Date: Monday, November 17, 2014 8:29:57 AM

I am out of the office. Please contact Desiree Lee at 202-720-3252, desiree.lee@ams.usda.gov

 if you need immediate assistance.

This electronic message contains information generated by the USDA solely for the intended

 recipients. Any unauthorized interception of this message or the use or disclosure of the

 information it contains may violate the law and subject the violator to civil or criminal

 penalties. If you believe you have received this message in error, please notify the sender and

 delete the email immediately.
From: Jean Richardson

To: COLEHOUR BONDERA

Cc: Calvin Walker; Carmela Beck; Francis Thicke; Harold Austin; Jay Feldman; Jennifer Taylor; 

joe.dickson@wholefoods.com; John Foster; Mac Stone; Nick Maravell; Tracy Favre; Wendy Fulwider

( Zea Sonnabend; Michelle Arsenault; McEvoy, Miles - AMS; Tucker, Jennifer - AMS; Tom

Chapman; Lisa; Paula Daniels (pdaniels@goodfoodla.org); Ashley Swaffar; Rakola, Betsy - AMS; Brown Rosen,

Emily - AMS

Subject: Re: small scale organic certification

Date: Monday, November 17, 2014 8:29:59 AM

Thank you Colehour. Let's put this on the next Executive Agenda for discussion. Jean

On Nov 17, 2014, at 2:52 AM, COLEHOUR BONDERA wrote:

Aloha NOSB members,

As a recipient of the ATTRA e-mail list, I found this note/discussion to be very "right on", from 

my perspective:

http://ofcfbc.wordpress.com/2014/10/30/to-certify-or-not-to-certify-the-perspective-ofsmall-scale-organic-farmers/

Such a large number of small-scale certified (or could be certified, but are not) farm(ers) exist 

that I simply wonder how and if we (the NOSB) can and should be formally recommending to 

the NOP that coordinated actions take place with others, such as Canada, to ensure that the 

"largest common denominator" not end up resulting in that organic by definition is by scale of

 operation, with standards that shut out participation by those too small, who in many places 

make up a vast majority of the number of farmers, if not the number of total organic acres. 

We must maintain and encourage the complete integrity of organics, and I think that this is a 

very important component which deserves more attention than it is presently receiving. 

Should the US system perhaps have a Working Group advising on this subject area is one of 

the first questions that comes to my mind at this moment (since materials are often needed 

differentially by small-scale and large-scale operations even in the same geographical 

regions). Based on my experience within the NOSB and as I perceive future actions and 

growth, I would like to request that such a Working Group formation be one of the 

components of a recommendation coming in some format (TBD at this time) from the NOSB

to the NOP (this is not simple since it does not fit within any of the prescribed "subcommittee" purviews, which is part of the reason that I send this to all of you as a group for 

further reflection or comments back...

Yours,

Colehour Bondera

KANALANI OHANA FARM

www.kanalanifarm.org

PO Box 861

(b) (6)
Honaunau, HI 96726

(b) (6)

 cell/text
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Skyping in Harold

Date: Saturday, June 27, 2015 5:42:43 PM

I chatted with Paula about a number of things and asked her opinion about skyping in Harold in October.- Paula is

 sort of like an outside observer.

She said to state medical necessity and just do it.

So should we raise this concept on the July Exec call too?

I am feeling so despondent about the NOC attitude towards oral public comment.

We work so hard to be treated with so much disrespect

Sorry!

Jean

Sent from my iPhone

Trudy

Trudy Bialic / Director, Public Affairs / PCC Natural Markets / Seattle, WA / 206-

547-1222

On behalf of:

PCC Natural Markets, Seattle, Washington

Central Co-op, Seattle, Washington

Marlene’s Markets, Tacoma and Federal Way, Washington

The Markets, Bellingham, Washington

Skagit Valley Food Co-op, Mt. Vernon, Washington

Tonasket Food Coop, Tonasket, Washington

Sacramento Natural Foods Co-op, Sacramento, California

Ocean Beach People’s Organic Food Coop, San Diego, California

Ashland Food Co-op, Ashland, Oregon

Outpost Natural Food Cooperative, Milwaukee, Wisconsin

One Degree Organic Foods, B.C., Canada

Dill Pickle Food Co-op, Chicago, Illinois

Wheatsville Food Co-op, Austin, Texas

La Montanita Food Co-op, Albuquerque, New Mexico

People's Food Co-op of Kalamazoo, Michigan

Whole Foods Co-op, Duluth, Minnesota

Mississippi Market Natural Foods Co-op, St. Paul, Minnesota

The Merc Community Market & Deli, Lawrence, Kansas

New Leaf Market Co-op, Tallahassee, Florida

Los Alamos Cooperative Market, Los Alamos, New Mexico

Hanover Consumer Co-op, Hanover, New Hampshire

Wild Oats Market, Williamstown, Massachusetts

Eastside Food Cooperative, Minneapolis, Minnesota

This email has been scanned for email related threats and delivered safely by Mimecast.

For more information please visit http://www.mimecast.com
August 18, 2014

To the Congressional Organic Caucus, 

We the undersigned organizations are writing to ask you to advocate reversal of USDA’s unilateral 

changes to the organic program’s Sunset Provision. We believe these changes violate the intent and the 

letter of the Organic Foods Production Act (OFPA). 

A high bar to allow and renew synthetics 

We have re-read OFPA and the letters from Sen. Leahy and Rep. DeFazio to Sec. Vilsack, as well as the 

letter from three former chairs of the National Organic Standards Board, and we respectfully disagree 

with the Deputy Administrator’s statement that the changes “shouldn’t make it harder” to remove items 

from the National List. 

NOP staff has admitted in various settings that materials up for Sunset from the National List of Allowed 

and Prohibited Substances were subject to being removed by a minority vote, and that materials some 

interests wanted to renew [leave on the list] weren’t getting enough votes, so USDA changed the voting 

process. In other words, NOP staff has admitted publicly it changed the rules to make it easier to keep 

synthetics on the National List. 

OFPA established the two-thirds supermajority requirement for “Decisive Votes” [Sec. 2119 (i)] 

intentionally to establish a very high hurdle for prohibited synthetics to be allowed, even temporarily, in 

organics. Within the context of the overarching principle in Sec. 2105 [7 USC 6504], that foods labeled 

organic must be “produced and handled without the use of synthetic chemicals ...,” Congress certainly

intended the Sunset Provision to emphasize the temporary nature of exemptions.

USDA’s policy change makes relisting and renewal of synthetics much easier. Now, only six votes are 

needed for a synthetic to be allowed continued use, not the 10-vote supermajority mandated by OFPA.

This assumes the full board even gets to vote on the relisting, since the murky nature of how these 

materials would be handled in subcommittees seems to preclude a full board vote if the subcommittee 

approves continued use. 

Now, even if nine NOSB members oppose relisting, a six-vote minority favoring continued use would 

determine the “Decisive Vote” to enable continued use. This is contrary to Congressional intent for

consensus in requiring a supermajority for Decisive Votes, through any plain reading of the law. 

OFPA’s framers meant clearly to establish a very high hurdle to add an exemption and to renew any 

exemptions — not a high hurdle to allow, and a low hurdle to renew. 

Policy change without public comment

USDA’s unilateral changes have been labeled a “power grab” with cause, since they were announced 

without the benefit of full notice and opportunity for public comment. 
When asked where the changes originated, NOP staff has stated that “USDA did recently adjust how it 

works with the National Organic Standards Board to be more consistent with how other federal advisory 

boards are managed [under the Federal Advisory Committee Act (FACA)].” 

The unique powers and authority granted to NOSB by OFPA have rubbed some USDA officials the wrong 

way from inception. But attempting to redefine the NOSB “to be more consistent with how other 

federal advisory boards are managed” contravenes what Congress enacted into law. (Note that FACA 

Sec. 9 says: (b) Unless otherwise specifically provided by statute or Presidential directive, advisory 

committees shall be utilized solely for advisory functions.) 

Congress knowingly and intentionally granted exceptional and unique powers and authority to the 

National Organic Standards Board — unlike most other federal advisory committees. In passing OFPA in 

1990, Congress knowingly and intentionally superseded the provisions established by FACA in 1972. In 

other words, OFPA overrides FACA. 

Subcommittee eliminated

We are very concerned by the NOP’s elimination of the Board’s Policy Development Subcommittee and 

control of the NOSB work plan and agenda. This unilateral, top-down action suggests that NOSB under 

the new rules would no longer be allowed to create a subcommittee to work on topics of its choosing, 

such as the GMO subcommittee or a subcommittee to study nanotechnology. 

OFPA established the NOSB to advise the Secretary of Agriculture on the organic program. NOSB cannot 

advise the Secretary well if its authority to develop a work plan and agenda, or create committees and 

procedures, is diminished or denied. 

Mandates ignored

There are two other OFPA provisions that appear to be contravened by USDA’s management of the 

organic program. 

Sec. 2119 (j) “Other Terms and Conditions” states “The Secretary shall authorize the Board [NOSB] to 

hire a staff director ...” To date, staff directors have been hired not by the Board as the law stipulates, 

but rather by the USDA. This must be rectified. 

Also, Sec. 2119 (j) (3) “Technical Advisory Panels” says, “The Board [NOSB] shall convene technical 

advisory panels to provide scientific evaluation of the materials considered for inclusion in the National 

List ...” To date, TAPs have been convened by USDA unilaterally, not the Board, as stipulated by the law. 

Selection of TAP reviewers by USDA has become so shrouded in secrecy that NOSB members do not 

even know who the TAP reviewers are. This must be rectified.

We realize the pressure USDA, and you in particular, must be facing from industry. Manufacturers and 

processors barely mustered the votes to allow carrageenan (even with flawed TAP reviews). They nearly

lost DHA, and larger orchards did lose antibiotics for growing apples and pears. 

Yet changing the rules and admitting they were intended to reverse the course of Sunset — to enable 

renewal of synthetics with just six of 15 votes — and to refashion NOSB under FACA, violates the intent 

of Congress and the letter of the law in OFPA. The drafters of OFPA required a two-thirds supermajority 
for Decisive Votes, requiring a higher level of consensus across the full range of organic stakeholders, to 

ensure both credibility of the organic label and public support for organic products. 

As significant stakeholders in the National Organic Program, we ask you to reverse these policies. We 

ask you, respectfully, to utilize the full notice and comment rulemaking procedures when there are 

changes NOP considers important.

Sincerely,

PCC Natural Markets, Seattle, Washington

Central Co-op, Seattle, Washington

Marlene’s Markets, Tacoma and Federal Way, Washington

The Markets, Bellingham, Washington

Skagit Valley Food Co-op, Mt. Vernon, Washington

Tonasket Food Coop, Tonasket, Washington

Sacramento Natural Foods Co-op, Sacramento, California

Ocean Beach People’s Organic Food Coop, San Diego, California

Ashland Food Co-op, Ashland, Oregon

Outpost Natural Food Cooperative, Milwaukee, Wisconsin

One Degree Organic Foods, B.C., Canada

Dill Pickle Food Co-op, Chicago, Illinois

Wheatsville Food Co-op, Austin, Texas

La Montanita Food Co-op, Albuquerque, New Mexico

People's Food Co-op of Kalamazoo, Michigan

Whole Foods Co-op, Duluth, Minnesota

Mississippi Market Natural Foods Co-op, St. Paul, Minnesota

The Merc Community Market & Deli, Lawrence, Kansas

New Leaf Market Co-op, Tallahassee, Florida

Los Alamos Cooperative Market, Los Alamos, New Mexico

Hanover Consumer Co-op, Hanover, New Hampshire 

Wild Oats Market, Williamstown, Massachusetts

Eastside Food Cooperative, Minneapolis, Minnesota
From: Jean Richardson

To: McEvoy, Miles - AMS

Cc: Robert Mac Stone ( John Foster (

Subject: Re: Tomorrow

Date: Sunday, February 02, 2014 1:55:20 PM

Ok with me.

Jean

On Feb 2, 2014, at 1:45 PM, McEvoy, Miles - AMS wrote:

Could we meet at Zaytinya, 701 9th St. NW at 5:30 pm? It is close to Gallery Place 

Metro.

Miles

This electronic message contains information generated by the USDA 

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this message or the use or disclosure of the information it contains 

may violate the law and subject the violator to civil or criminal 

penalties. If you believe you have received this message in error, 

please notify the sender and delete the email immediately.

(b) (6) (b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: Today

Date: Friday, November 14, 2014 9:14:25 PM

No problem

Monday is good.

I leave for India on Wednesday

Sent from my iPhone

> On Nov 14, 2014, at 6:24 PM, "McEvoy, Miles - AMS" <Miles.McEvoy@ams.usda.gov> wrote:

>

> Sorry. The day ran away from me. Early Monday?

>

> Miles V McEvoy

> Deputy Administrator

> USDA National Organic Program

>

>> On Nov 14, 2014, at 9:09 AM, "Jean Richardson" < wrote:

>>

>> Yes.. I have to watch my grandaughter at ballet class 3.pm - 4.15.

>> Can you call me at 5 pm on my cell phone? 

>> Have a happy retreat!

>> Jean

>>

>>> On Nov 14, 2014, at 8:25 AM, McEvoy, Miles - AMS wrote:

>>>

>>> I'm in an AMS retreat today. Can we check in late afternoon?

>>>

>>> Miles V McEvoy

>>> Deputy Administrator

>>> USDA National Organic Program

>>>

>>>

>>>

>>>

>>> This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

>>

(b) (6) (b) (6)
From: Jean Richardson

To: John Foster

Cc: McEvoy, Miles - AMS; Mac Stone (Personal)

Subject: Re: Title of that book: Thinking, Fast & Slow

Date: Wednesday, April 16, 2014 11:33:20 AM

Hi John

Thank you

I will check it out on Amazon.

Yes the lack of balance in public comments written and oral is frustrating.!

Jean

On Apr 16, 2014, at 11:26 AM, John Foster wrote:

Daniel Kahneman is the author. Brilliant discussion and articulation on how 

humans make decisions, thereby exposing the methods that lead to inappropriate

 manipulation of those less inclined to think independently.

For example, WSIATI-What you see is all there is. Unless you work hard 

intellectually, the only information used to inform a decision in what’s in front of

you. Public Comment, anyone?

Cheers,

-John

This email message is the property of Earthbound Farm and may contain confidential and privileged information. Any 

unauthorized review, use, disclosure or distribution is prohibited. If you have received this communication in error, 

please immediately re-send this communication to the intended party and delete the original message and any copy of 

it, including all attachments, from your computer system.
From: Jean Richardson

To: Mac Stone

Cc: McEvoy, Miles - AMS; Zea Sonnabend; Carmela Beck; Harold Austin; Tracy Favre; Wendy Fulwider;

joe.dickson@wholefoods.com; John Foster; Arsenault, Michelle - AMS

Subject: Re: Thursday morning

Date: Thursday, May 01, 2014 7:32:44 AM

It is aggravating not to be able to just get on with our work, but public meetings are open and

 the First Amendment is pretty clear on rights

Let's try to keep cool and carry on

Jean

Sent from my iPad

On May 1, 2014, at 5:28 AM, "Mac Stone" < wrote:

She made her statement and will not cause further problems in my opinion. She was

 there late in the day yesterday without issue. We should not honor the behavior by

 boycotting our own meeting. More antics from others will be handled as necessary if

 necessary. For the process to work we must be at work. I will be downstairs early if we

 need to make decisions. My number 859-621-0756

From: McEvoy, Miles - AMS [mailto:Miles.McEvoy@ams.usda.gov] 

Sent: Wednesday, April 30, 2014 11:45 PM

To: Zea Sonnabend

Cc: Carmela Beck; Harold Austin; Mac Stone; Tracy Favre; Wendy Fulwider;

joe.dickson@wholefoods.com; Jean Richardson; John Foster; Arsenault, Michelle - AMS

Subject: Re: Thursday morning

I would request that you do not do this. The NOSB meetings are open public meetings. I

 do not have the authority to keep her from attending the meeting. We can meet at 8

 to discuss.

Miles V McEvoy

Deputy Administrator

USDA National Organic Program

On Apr 30, 2014, at 9:55 PM, "Zea Sonnabend" <zea@well.com> wrote:

Hello fellow meeting participants,

Several of us were talking over dinner and found we were all not happy

 that Alexis from OCA was allowed to be back in the meeting room after

 being arrested for disrupting the meeting. We feel that if she is allowed in

 tomorrow, we do not want to participate either. We want our meetings

 to be civil and law-abiding. Therefore we plan to not be in the room if she

 is in there. We will stand outside and hopefully enough of you will join

 with us that a quorum cannot be achieved until she is gone.

(b) (6)
This attitude is exacerbated by it being out in the media that some other

 antics are being planned for tomorrow.

Miles, we ask you to give an assurance to us that such people and their

 tactics are not condoned by the department and make sure she is not

 there tomorrow or Friday.

Thanks,

Zea et. al.

From: "Michelle Arsenault - AMS"

 <Michelle.Arsenault@ams.usda.gov>

To: "Calvin Walker" < "Carmela Beck"

 <carmela.beck@driscolls.com>, "Colehour Bondera"

 <colemel@kanalanifarm.org>, "Francis Thicke"

 <fthicke@iowatelecom.net>, "Harold Austin"

 <harolda@zirklefruit.com>, "Jay Feldman"

 <jfeldman@beyondpesticides.org>, "Jean Richardson"

 < "Jennifer Taylor"

 < "joe dickson"

 <joe.dickson@wholefoods.com>, "John Foster"

 <jfoster@ebfarm.com>, "Mac Stone" <

 "Nick Maravell" < "Tracy Favre"

 <tfavre@favrehouse.com>, "Wendy Fulwider"

 < "Zea Sonnabend" <zea@well.com>

Sent: Wednesday, April 30, 2014 9:54:12 AM

Subject: FW: Made with Organic Guidance

FYI

... here is the link through which the Made with Organic Guidance notice

 will be available tomorrow when it publishes:

https://www.federalregister.gov/articles/2014/05/01/2014-09963/finalguidance-on-products-in-the-made-with-organic--labeling-categorynational-organic-program .

This electronic message contains information generated by the

 USDA solely for the intended recipients. Any unauthorized

 interception of this message or the use or disclosure of the

 information it contains may violate the law and subject the

 violator to civil or criminal penalties. If you believe you have

 received this message in error, please notify the sender and

(b) (6) (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
 delete the email immediately.
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Re: Thursday at 4

Date: Wednesday, January 28, 2015 5:18:45 PM

Sounds fun. Hi to sara. Ami and I are going to an event at the building museum.

Miles V McEvoy

Deputy Administrator

USDA National Organic Program

> On Jan 28, 2015, at 5:11 PM, "Jean Richardson" < wrote:

>

> Yes 5 is good tomorrow

> And yes for meetings

>

> I'm out having oysters and suchlike with Sarah!

> She says hi

>

> Sent from my iPhone

>

>> On Jan 28, 2015, at 4:37 PM, McEvoy, Miles - AMS <Miles.McEvoy@ams.usda.gov> wrote:

>>

>> I need to reschedule - can you do 5 pm?

>> Setting up meetings for you and Tracy - 11am Thursday with Deputy Chief of Staff Dan Christianson is

 scheduled. Others with NIFA, NRCS and EPA so far.

>>

>> -----Original Message-----

>> From: Jean Richardson [mailto:

>> Sent: Wednesday, January 28, 2015 4:12 PM

>> To: McEvoy, Miles - AMS

>> Subject: Re: Thursday at 4

>>

>> Thursday at 4 perfect

>>

>> Sent from my iPhone

>>

>>> On Jan 28, 2015, at 10:00 AM, McEvoy, Miles - AMS <Miles.McEvoy@ams.usda.gov> wrote:

>>>

>>> Yes, that will work. 4 pm?

>>>

>>> -----Original Message-----

>>> From: Jean Richardson [mailto

>>> Sent: Wednesday, January 28, 2015 8:10 AM

>>> To: McEvoy, Miles - AMS

>>> Subject: Friday at 8.30?

>>>

>>> Hi Miles

>>> Looks like I will be in the truck Friday morning headed out for a processing inspection - assuming snow is

 reasonable. So any chance we can chat Thursday late afternoon early evening like last week?

>>> Thanks

>>> Jean

>>>

>>>

>>>

(b) (6) (b) (6) (b) (6)
>>>

>>> This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Things to chat about?

Date: Sunday, November 16, 2014 10:28:55 AM

Hi Miles

Just going through some of my notes from the last NOSB meeting and I note three items for us to think about:

* Getting organic representation on all USDA committees

* The GAO looking at GMO's from perspective of food safety?

* Do we need a Working Group on Organic certification standards for Hydroponic/aquaponic food production?

* Should we be setting up an Aquaculture subcommittee in 2015? Wait till Rule is out?

* I could chat with you about the PPM draft. - looks reasonable

Talk with you Monday - any time after 7. am is good.

Cheers

Jean
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Automatic reply: Thanksgiving thoughts

Date: Tuesday, November 26, 2013 3:57:26 PM

I am out of the office. Please contact Joan Avila at 202-720-3252, joan.avila@ams.usda.gov if

 you need immediate assistance.

This electronic message contains information generated by the USDA solely for the intended

 recipients. Any unauthorized interception of this message or the use or disclosure of the

 information it contains may violate the law and subject the violator to civil or criminal

 penalties. If you believe you have received this message in error, please notify the sender and

 delete the email immediately.

 if your assignment is not exactly as you might have wished, but all calls are open to all

 members.

We also have the unique opportunity to have the same 15 members hold court for two

 full years. Hopefully we can work in a climate of mutual respect and set the tone on

 how best the NOSB should conduct its business, and the training will help us to

 understand how to make that happen. We owe it to the entire OG community to

 demonstrate how to revel in our differences, yet arrive at a conclusion of consensus on

 the best path forward. Just like family at Thanksgiving Dinner, we argue around the

 margins, but we all want the same thing.

We celebrated Thanksgiving this past Sunday with:

Kentucky Single Barrel Bourbon (locally produced 10 years ago)

Smoked salmon (OG not an option....yet?)

Elmwood Stock Farm OG romaine/red leaf salad with ESF onions, radish, and local blue

 cheese dressing

Elmwood Stock Farm OG pasture raised heritage turkey thighs (sold all the breasts)

Elmwood Stock Farm OG mashed Yukon gold potatoes ( actually “Made with” ‘cause

 the raw milk is not certified, nor is our kitchen)

Elmwood Stock Farm OG lacinato Kale in turkey stock with OG cranberries

Grandma’s dressing (nobody questioned OG status since it is sooo good)

Red wine (made with OG grapes)

OG (mostly) chocolate mud pie and/or Elmwood Stock Farm OG pumpkin pie

OG ice cream

Mommie Ruth’s yeast rolls (again no questions)

Lots of laughing and teaching the little ones bad words.

So eat, drink, and be merry this week. By all means, it best be organic to be the best.

Thanks for all you give to benefit others, Mac

Mac Stone

Elmwood Stock Farm

859.621.0756

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 recipients. Any unauthorized interception of this message or the use or disclosure of the
 information it contains may violate the law and subject the violator to civil or criminal

 penalties. If you believe you have received this message in error, please notify the sender and

 delete the email immediately.
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Fwd: Thanks for listening

Date: Tuesday, April 14, 2015 10:48:45 PM

Hi Miles

John Baker was at my public lecture Monday night and although I did not discuss hydroponics

 or aquaponics he chatted briefly with me about a whole different set of reasons for organic

 hydroponics and aquaponics and he may contact you about this and ask to be considered for

 the task force.

Cheers Jean

Sent from my iPad

Begin forwarded message:

From: JOHN BAKER <givingnature@me.com>

Date: April 14, 2015 at 9:57:01 PM EDT

To: " <

Subject: Thanks for listening

Hi Dr. Richardson,

It was a great pleasure to meet you this Monday evening. Thank you again for

 listening. You practice what you teach!

I'll follow up on seeking a place on the task force you mentioned and let you

 know how I made out. I really hope Hydroponics keeps a place in the universe of

 USDA Certified Organic agriculture. Our Chesapeake Bay will much appreciate

 it!

John Baker

Giving Nature 

Sent from my iPhone

(b) (6) (b) (6)
From: Jean Richardson

To: B. Flamm

Cc: Calvin Walker; Carmela Beck; Colehour Bondera; Harold Austin; Jay Feldman; Jennifer Taylor; 

joe.dickson@wholefoods.com; John Foster; Nicholas Maravell; Robert Stone; Tracy Favre; Wendy Fulwider; Zea

Sonnabend; Arsenault, Michelle - AMS; McEvoy, Miles - AMS

Subject: Re: Thanks

Date: Tuesday, May 29, 2012 6:13:13 PM

Hi Barry and everyone:

It was great to meet you all at last.

Thank you Barry for a job well done, and Michelle is incredible the way she kept everyone 

working so well.

I am out of state until June 11.

Jean

On May 29, 2012, at 2:37 PM, B. Flamm wrote:

Dear Members,

I wish to thank each of you for your very hard work, cooperation, team work and 

friendly spirit during our challenging week and I really appreciate the help given 

me in my first meeting as Board Chair.

Michelle, I also want to thank you for doing a great job, and no matter what a 

smile on your face!

Before we forget, I would like for you to jot down what worked and what didn't 

and your thoughts for improvement for our next Board meeting. Please share this 

with all Board members by June 8, our next EC call.

Thanks,

Barry
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Re: talk this week?

Date: Sunday, August 10, 2014 8:22:35 PM

8 am Friday is fine. Talk to you then.

Miles V McEvoy

Deputy Administrator

USDA National Organic Program

> On Aug 10, 2014, at 9:56 AM, "Jean Richardson" < wrote:

>

> Hi Miles

> Do we still have Friday at 8.30 for our call?

> Could it be 8 am instead.?

> quick updates:

> Sunset forms modified

> Voting in sub committees -strategies for reduced problems at October meeting

> October meeting agenda - I am trying to keep it short and sweet!

> NASDA, NODPA, Cornucopia

> PPM status?

> Annotation request of Harold's/CACS

> All for now

> Jean

>

>

This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

(b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: Talk Friday?

Date: Thursday, January 15, 2015 3:49:41 PM

OK good

Jean

On Jan 15, 2015, at 2:59 PM, McEvoy, Miles - AMS wrote:

> 5 pm?

>

> -----Original Message-----

> From: Jean Richardson [mailto

> Sent: Thursday, January 15, 2015 2:24 PM

> To: McEvoy, Miles - AMS

> Subject: Re: Talk Friday?

>

> Hi Miles

> Ok let's do after 4.30 today

> I should be home by then. So call my home phone Thanks Jean

>

> Sent from my iPhone

>

>> On Jan 15, 2015, at 8:20 AM, McEvoy, Miles - AMS <Miles.McEvoy@ams.usda.gov> wrote:

>>

>> Hi Jean and Happy New Year,

>> It's cold here too after Puerto Rico but not minus 10. Brrrr!

>> I'm fairly caught up with things now and would love to chat. I'm fairly flexible late today (after 4:30) and

 tomorrow before 10 am or afternoon if that works better for you.

>> Best,

>> Miles

>>

>> -----Original Message-----

>> From: Jean Richardson [mailto:

>> Sent: Thursday, January 15, 2015 7:49 AM

>> To: McEvoy, Miles - AMS

>> Subject: Talk Friday?

>>

>> Hi Miles

>> I was not thinking when I scheduled my work for tomorrow Friday, but I will be on the road, leaving the house

 by 7.30 am (Feed Mill inspection). However, I can stop the truck at 8.30, pull over and chat with you on my cell

 phone if you want to call. ? What do you think? Have you had time to catch up with the office since you got back?

>> Cell Phone 

>> Hope you had a great holiday break and are ready for work!

>> It is minus 10 F again this morning. I am headed out for a drive into the mountains for an inspection of a place

 that makes tempeh products. But we are promised some sun.

>> Cheers

>> Jean

>>

>>

>>

>>

>> This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

(b) (6) (b) (6) (b) (6) (b) (6)
 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.
From: Jean Richardson

To: Zea Sonnabend

Cc: Tracy Favre; Tom Chapman; McEvoy, Miles - AMS

Subject: Re: Sunset templates

Date: Sunday, July 26, 2015 3:03:06 PM

I am really sorry Zea

We had talked a while ago about the chairs doing this and I understood that we were all happy with this plan . I will

 contact Emily and Lisa B and get this off your list of tasks. Tom and Tracy would you prefer NOP staff to take this

 over?

If so I will work on the issue on Monday first thing

Jean

Sent from my iPhone

On Jul 26, 2015, at 2:27 PM, Zea Sonnabend <zea@well.com> wrote:

Hello Jean, Tracy, Tom, Miles,

I have found myself being resentful about this email since I recieved it a few days ago, and so I have chosen to just

 reply to fellow chairs and Miles rather than other NOP staff.

We volunteer subcommitte chairpeople are being asked to do a lot of extra work since the change in the sunset

 policy last year. It totally rankles me that NOP staff with high paying secure full time jobs to do this stuff are

 pressuring us to be a month earlier than our regular deadline to do something that they could be doing instead of us.

 Michelle has all the documents, and just plopping them into the template is easily something the NOP could do if

 they want it early and then we can just check it over for last minute innaccuracies.

I'm sorry to be grumpy about this, but I'm trying to use my time to work on quality subcommittee proposals that are

 not finished yet, and keep other members on task, so that we can make the real August deadline instead of

 housekeeping work that we should not have to do.

Pressuring me about this is likely to make it happen slower rather than faster. I am planning to finish my sunset

 workload for this term before I touch this other issue.

Regards,

Zea

> On Jul 24, 2015, at 1:28 PM, Jean Richardson wrote:

>

> Perfect, thank you, Jean

>

>> On Jul 24, 2015, at 1:44 PM, Zea Sonnabend wrote:

>>

>> Sorry, but such short notice doesn't work for me. I am busy this weekend. I should be able to get to it next week

 though.

>>

>> Regards,

>> Zea

>>

>>

>>> On Jul 24, 2015, at 6:04 AM, Jean Richardson wrote:

>>>

>>> Hi Sunset Team leaders!

>>> It is really Really important to get the Sunset templates "populated" now, preferably this weekend.....
>>> Lisa is getting anxious about being able to get through them all to clarify/edit as necessary, and tidy them up for

 posting. Only a few weeks for her to get through each one carefully.

>>> So I am sorry to be pushing more work on you, but we must get this done.

>>> If I can help let me know.

>>> Cheers

>>> Jean
From: Jean Richardson

To: Brines, Lisa - AMS; Brown Rosen, Emily - AMS; Arsenault, Michelle - AMS; McEvoy, Miles - AMS

Subject: Fwd: Sunset templates

Date: Tuesday, July 28, 2015 8:53:00 AM

Hi NOP colleagues.

I know that Subcommittee Chairs had hoped to get time to drop all the sunset material into 

templates but we are all getting pretty overwhelmed with the scope and depth of our NOSB 

analysis of materials under the new Sunset and everything else. So here are the replies from 

the 3 Sunset Chairs who are doing an amazing job keeping us on track, but asking for help

please. So it would seem much more efficient for NOP to take over putting templates together 

for posting.

Thank you

Jean

I have made zero progress on this but realize I agreed to it so I will get it done, 

obviously I'd prefer not to do it if we had support from NOP. 

On my end, two people from my department are on "sabbatical" so I have extra 

work on both fronts and have been struggling to keep up with both my NOSB 

work as well as my work work.

Tom 

I have a good portion of mine already in template so I can submit those but I see 

Zea's point. I'll do whatever the group agrees to. 

Tracy

On Jul 26, 2015, at 2:05 PM, Zea Sonnabend <zea@well.com> 

wrote:

I know I agreed at the time, but the workload has just recently gotten 

really burdensome. I can easily do it by the August 26 deadline 

though. It is the advance of the deadline concept I object to.

Zea
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: RE: sunset comments re-wording

Date: Tuesday, October 21, 2014 3:24:38 PM

Ok, I understand.

From: Jean Richardson [mailto:

Sent: Tuesday, October 21, 2014 10:37 AM

To: McEvoy, Miles - AMS

Subject: sunset comments re-wording

Hi Miles

Here is how I changed the last section. (see below)

If I add all the technically correct language you suggest it will be too much at that point in the

day's work.

I expect you will use the more "proper" wording when you give your comments. Or I can at

some other stage or if asked a question of clarification.

Also please note that there is also some confusion over the phrase of "untimely" public

comment as it appears in the FR.

*************************

".......Thus, in order for the public to clearly understand that a substance could potentially be

removed from the National List, and be given the opportunity to provide comment which could be

considered at this meeting, each substance comes to the full Board, from their respective

subcommittee, with a motion to remove the substance from the National List. 

The NOSB acknowledges that this is a somewhat artificial construct, but that it meets the intent of

the new Sunset process. 

Therefore, if a member votes YES on a motion to remove, that substance will be recommended to be

removed from the National List.

If a member votes NO on a motion to remove that substance will remain on the National List. "

This electronic message contains information generated by the USDA solely for the intended

recipients. Any unauthorized interception of this message or the use or disclosure of the

information it contains may violate the law and subject the violator to civil or criminal

penalties. If you believe you have received this message in error, please notify the sender and

delete the email immediately.

(b) (6)
From: Jean Richardson

To: Arsenault, Michelle - AMS; Bailey, Melissa - AMS; Brown Rosen, Emily - AMS; Brines, Lisa - AMS; McEvoy, Miles -

 AMS; Tucker, Jennifer - AMS; Mac Stone; John Foster

Subject: Training Evaluation and suggestions

Date: Sunday, February 16, 2014 5:02:13 PM

Attachments: NOSB Training Feb 2014.docx

Hi Michelle

here is my evaluation and suggestions from the training.

Please do not circulate beyond those above listed on the attached document.

Cheers, Jean
To: Michelle Arsenault, Miles McEvoy, Jenny Tucker, Melissa Bailey, Lisa Brines, 

Emily Brown Rosen, Mac Stone and John Foster.

From: Jean Richardson

RE: NOSB Training, Feb 2013

GENERAL COMMENTS: 

This was an excellent two day refresher course, and well worth our tax dollars! 

The range of materials, both written and verbal, and scope of subjects covered was 

very appropriate for this moment in time when the NOP was asserting its authority 

under FACA, reviewing the new Sunset procedures face to face, and outlining future 

policies and procedures which differ considerably from the traditional way in which 

the NOSB has operated from its inception to present.

Listening to Board members it was clear that many board members had not read the 

materials in the New Member Guide, with all of its links to rule making etc.. Some 

had never read the PPM, and most had never read the Charter. So such training is 

vital for ongoing and new Board members alike. 

HIGHLIGHTS: Melissa and Lisa’s and Emily’s presentations. 

The graphic presentation of Rule Making, using the lengthy scroll down the table 

was an excellent way to highlight the complexities of Rulemaking and the exercises 

to show how to write better checklists was great, and could have used more time. 

Melissa and Lisa and Emily have superb presentation skills and excellence in 

answering questions. They are sensitive to individual board member’s knowledge 

base and experience, and are professional at all times. Their presentations should 

be primary at future trainings.

LOW LIGHTS: 

1. The FACA presentation by Karen Carrington in which we had a finger shaken at us 

and were told to “Stay in Lane” and not to do things which could lead to NOP/USDA 

being sued. This was over the top, unprofessional, and inappropriate. It was as 

though the attorney failed to understand that we are not USDA employees, but 

dedicated, hardworking volunteers with a diversity of experience, expertise and 

opinion. Just because the NOSB had been operating under a set of traditional, 

discretionary procedures for many years, procedures which were now recognized 

as being beyond the scope of a FACA Board, does not justify her behavior or the 

manner in which she answered questions.

2. The NOP failed to effectively involve NOSB leaders in developing the content and 

presentation of the training. (see suggestions below)

3. Not having any organic milk in the USDA Cafeteria and actually not even being 

able to get Whole conventional milk!!!! (Did they have an organic section? If not – 

now is the time!)
SUGGESTIONS for future trainings: 

1. There should be a training before every public meeting. I suggest 3 morning 

hours in length.

2. Training should cover how to write Checklist Proposals and Discussion 

Documents with examples of good ones. This is now our primary function and it 

would be good to do it better. In line with this it is important that both the NOP and 

NOSB members understand that the NOSB is not a technical review board. 

3. Training can include a very brief reminder of FACA and OFPA and Charter and 

other documents – looking at them on line at training would be good, thus there is 

no excuse that everything is too hard to find. Do this after the ‘how to write good 

proposals” and “how to make the Public meeting and comments work best”

4. Training must include a member of the NOSB in tandem with staff so that the 

nuances and practical aspects of drafting documents can be fleshed out and shared 

at the training. This should increase efficiency and effectiveness of NOSB.

5. I know that it is sometimes difficult for NOP to deal with the NOSB and individual 

members, but please do keep on trying to guide us with patience. NOP and AMS 

staff are public servants and the NOSB members are volunteers who deserve respect 

and even kindness as they struggle to do their very best with complex and often 

nuanced data in an increasingly competitive organic market place. 

6. Representative: You have already noted that this is an important word to me in 

how it should, shall, may, be used in various contexts. Learning Law you start with 

understanding definitions, and the definition varies depending on the statute you 

are working from. In this case we have the OFPA statute AND FACA. The word 

Representative should be discussed at trainings. Under FACA we are 

“Representatives” for COI and must speak in “we” language for our stakeholders. 

That is one legal definition. HOWEVER, I believe that when working under OFPA, if 

that is taken literally by all Board members we would have solid voting blocks of 3 

consumer reps with 3 environmental reps and maybe some of the smaller farmers, 

voting against the 2 handlers, 1 retail and wherever the rest scatter. Thus getting 

two thirds to approve materials would be difficult. The legislative intent was for the 

NOSB to reflect broad national stakeholder groups, but for individual members to 

use their education, experience, and expertise in making decisions which benefit the 

organic community as a whole. We need to be able to discuss and clarify this at our 

trainings each year.

7. Sharing files, e-mails and information. This has come up regularly over the last 2 

years. ( reaching a messy pinnacle this last week!!!) . Most of us follow Zea’s 

discipline of not sharing any physical work product or e-mail outside NOSB and 

NOP. (we certainly talk with people). I find sharing e-mails, e-mail threads and 

draft written materials outside the NOP and NOSB unethical, and potentially 
damaging to the integrity of the organic label . The NOSB and NOP must jointly 

provide a clear statement on this. This is not simply a legal statement.

8. Public Meetings and use of public comment: It is clear that structure and function 

and use of these evolve over the years . Thus each training should clearly lay out 

what the present understanding is for who does what and when, including chairing 

meetings, what constitutes substantive change of a document or amendment etc...

OK all for now

Thank you for asking for this feed back and for suggestions.

Jean 

PS I like the Sparkly Sprinkles exercise which you sent us home with! Maybe you 

could assign an exercise BEFORE the Training so we can come prepared?
From: Jean Richardson

To: McEvoy, Miles - AMS

Cc: Arsenault, Michelle - AMS; Calvin Walker; Carmela Beck; Colehour Bondera; Francis Thicke; Harold Austin; Jay

 Feldman; Jennifer Taylor; joe.dickson@wholefoods.com; John Foster; Mac Stone; Nick Maravell; Tracy Favre;

Wendy Fulwider; Zea Sonnabend; Brines, Lisa - AMS; Brown Rosen, Emily - AMS

Subject: Re: Updated NOSB "syllabus"

Date: Monday, November 03, 2014 3:30:05 PM

Sounds fine to me

Jean

Sent from my iPhone

On Nov 3, 2014, at 3:21 PM, "McEvoy, Miles - AMS" <Miles.McEvoy@ams.usda.gov>

 wrote:

I’d like to use the term ‘2015 agenda’ (including Spring agenda and Fall agenda) rather

 than “syllabus” if there are no objections.

Thanks,

Miles McEvoy

Deputy Administrator

National Organic Program

From: Arsenault, Michelle - AMS 

Sent: Thursday, October 30, 2014 11:42 AM

To: Calvin Walker; Carmela Beck; Colehour Bondera; Francis Thicke; Harold Austin; Jay

 Feldman; Jean Richardson; Jennifer Taylor; joe.dickson@wholefoods.com; John Foster;

 Mac Stone; Nick Maravell; Tracy Favre; Wendy Fulwider; Zea Sonnabend

Cc: Brines, Lisa - AMS; Brown Rosen, Emily - AMS; McEvoy, Miles - AMS

Subject: Updated NOSB "syllabus"

Hello folks,

Attached and in Dropbox, please find the most updated syllabus for Spring 2015.

This is the version I will be projecting this afternoon

Thanks,

Michelle

Michelle Arsenault

Advisory Committee Specialist

USDA National Organic Program

1400 Independence Ave SW; Room 2641S

Washington, DC 20250-0268
Temporary office phone: (202) 260-8209

Office voicemail only: (202) 720-0081

Mobile: 

michelle.arsenault@ams.usda.gov

This electronic message contains information generated by the USDA solely for

 the intended recipients. Any unauthorized interception of this message or the use

 or disclosure of the information it contains may violate the law and subject the

 violator to civil or criminal penalties. If you believe you have received this

 message in error, please notify the sender and delete the email immediately.

(b) (6)
From: Jean Richardson

To: Arsenault, Michelle - AMS

Cc: Harold Austin; "Tracy Favre"; McEvoy, Miles - AMS; Brown Rosen, Emily - AMS

Subject: Re: Updated agenda

Date: Monday, April 13, 2015 9:03:24 AM

Hi Michelle

Yes looks Ok.

(I forgot that the second crops material was withdrawn immediately before posting)

Good job

Jean

On Apr 12, 2015, at 8:26 PM, Arsenault, Michelle - AMS wrote:

Hi Jean,

Here is the latest iteration with several changes you noted below. For everyone’s 

benefit:

EPA requested to speak Monday morning as they have a conflict later in the week.

There are only 2 materials that were withdrawn. I have removed the strike out. I think 

that makes sense since you will still mention them at the meeting.

I moved the seed panel to within the MS block.

If this looks good let me know so I can make the external version and get it posted.

Thanks,

Michelle

From: Jean Richardson [mailto:

Sent: Saturday, April 11, 2015 9:55 AM

To: Arsenault, Michelle - AMS

Cc: Harold Austin; 'Tracy Favre'; McEvoy, Miles - AMS; Brown Rosen, Emily - AMS

Subject: Re: Updated agenda

Hi Michelle

Why have we moved the EPA presentation to Monday? It works much better on 

Wednesday afternoon to break up Sunset agenda, and we can fit more Public 

comment in on Monday which was our plan on the Exec call I thought. Can we 

not start public comment at 10.30 on Monday?. 

And if we put EPA on Wednesday and we went to 6 pm, Crops would still have 3 

hours - And Thursday still looks flexible, which is good.

Petitions withdrawn - I think the NOSB would prefer to not have the 3 substances 

deleted from agenda, ie do not have line through agenda item for these 3 

materials. NOSB will talk about these materials at the meeting. But yes, have the 

notation that they were withdrawn.

Should the Seed Purity Panel be part of Materials SC? - MS organized it and I am 

sure they will have questions.

(b) (6)
Thank you

Jean

On Apr 10, 2015, at 6:59 PM, Arsenault, Michelle - AMS wrote:

Hello folks,

Attached, please find the updated internal tentative agenda. I could use some eyes on 

this to make sure I didn’t miss anything in the reshuffle. Notice the minor tweaks to 

timing on Monday. Shorter break, longer day. Longer day Tuesday. Dinner Wednesday 

(still waiting to confirm that with the restaurant - no private room that night so we will 

have to be outside on the balcony in a private space).

Let me know by Monday if there are any typos or errors!

Michelle

Michelle Arsenault

Advisory Committee Specialist

USDA National Organic Program

1400 Independence Ave SW; Room 2641S

Washington, DC 20250-0268

Office: (202) 720-0081

Mobile: 

michelle.arsenault@ams.usda.gov

<2015 Tentative Agenda_Internal.docx>

<2015 Tentative Agenda_Internal.docx>

(b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Fwd: Update on Organic Hydroponic

Date: Thursday, April 09, 2015 5:20:59 PM

Assume you saw this, but FYI

Jean

Begin forwarded message:

From: Dave Chapman <

Date: April 9, 2015 10:33:55 AM EDT

To: undisclosed-recipients:;

Bcc: 

Subject: Update on Organic Hydroponic

Hi All.

Since my last letter I have heard back from two more folks planning to 

volunteer for the organic hydroponic task force. First is Jack Algiere, 

Four Season Farm Director at Stone Barns Center, the amazing farm and

 school in the NY Hudson Valley. The second is Sam Welsch, organic 

inspector and CEO of OneCert Inc in Lincoln Nebraska. He is also the 

former executive director of OCIA International. 

Sam also wrote that he "just attended the IOIA (Independent Organic 

Inspectors Association) annual meeting and most inspectors also support

 the NOSB recommendation. The only ones that I spoke with who 

support organic certification for hydroponics are also consulting with

hydroponic growers. I have been contacted by several hydroponic 

operators this month asking about certification. It is a good sign that 

some are concerned that the ability to certify hydroponics as organic

may be close to ending."

It is great to get people signing up for the task force from other parts of 

the country! Please keep coming. We need you. The only way that we 

can stop this takeover of the organic standards is by speaking up.

Davey Miskell and I met last week with Tom Berry, Senator Leahy's 

chief of staff in Vermont. We had a very productive meeting. Senator 

Leahy sent Miles a letter last year urging the NOP to act in support of

the NOSB recommendation. Clearly this hasn't happened yet, so Tom

said that he will talk with the Senator about how they might go forward 

to urge a positive action in maintaining the integrity of the standards. 

One idea that came up in the meeting was for the NOP to create a 

(b) (6) (b) (6)

From: Jean Richardson

To: Harold Austin

Cc: Tracy Favre; Mac Stone; Brown Rosen, Emily - AMS; Arsenault, Michelle - AMS; McEvoy, Miles - AMS; Calvin

Walker; Jay Feldman; Nick Maravell; Carmela Beck; John Foster; Jennifer Taylor; Wendy Fulwider; Francis

Thicke; COLEHOUR BONDERA; Zea Sonnabend; joe.dickson@wholefoods.com

Subject: Re: Update about Mac

Date: Sunday, July 13, 2014 3:51:37 PM

Harold - Well said indeed.- Jean

On Jul 13, 2014, at 3:27 PM, Harold Austin wrote:

Mac,

While you served as our Board Chair these past 18 months, you did so in a manner that 

demanded respect from all of us! Not once did I ever hear you complain, nor were there very

 many sub-committee calls (even those you were not on) that you actually did you miss 

during this time. You went way above and beyond the call of duty for the position you served 

and we are all very much aware of that.

 

Your friend and fellow NOSB family member,

Harold

>>> Tracy Favre <tfavre@favrehouse.com> 7/13/2014 8:20 AM >>>

That's what friends are for. 

T

Sent from my iPhone

> On Jul 11, 2014, at 2:29 AM, "Mac Stone" < wrote:

> 

> 

(b) (6)

(b) (6)

(b) (6)

(b) (6)
> 

> Mac

> 

> -----Original Message-----

> From: Jean Richardson [mailto

> Sent: Thursday, July 10, 2014 7:44 AM

> To: Arsenault, Michelle - AMS

> Cc: Calvin Walker; Carmela Beck; COLEHOUR BONDERA; Francis Thicke; Harold

> Austin; Jay Feldman; Jennifer Taylor; joe.dickson@wholefoods.com Dickson;

> John Foster; Mac Stone; Nick Maravell; Tracy Favre; Wendy Fulwider; Zea

> Sonnabend; Brown Rosen, Emily - AMS; Miles - AMS McEvoy

> Subject: Update about Mac

> 

> Hi Michelle and everyone

> 

> 

> Thank you everyone for all the work on Sunset especially Cheers from Vermont

> Jean

> 

> 

> 

(b) (6)

(b) (6) (b) (6)

From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: Tuesday morning

Date: Friday, January 30, 2015 4:18:18 PM

OK

I have my meeting with Senator Leahy and staff on Friday morning

Jean

On Jan 30, 2015, at 3:35 PM, McEvoy, Miles - AMS wrote:

Administrator Alonzo would like to meet with you on Tuesday morning. She will be in 

touch. See you next week.

Miles

Jean’s contact information - <image001.jpg>

Miles McEvoy

Deputy Administrator

National Organic Program

This electronic message contains information generated by the USDA 

solely for the intended recipients. Any unauthorized interception of 

this message or the use or disclosure of the information it contains 

may violate the law and subject the violator to civil or criminal 

penalties. If you believe you have received this message in error, 

please notify the sender and delete the email immediately. <Jean 

Richardson.vcf>
From: Jean Richardson

To: Eckhouse, Sara - AMS

Cc: McEvoy, Miles - AMS; Alonzo, Anne - AMS

Subject: Re: Tuesday morning

Date: Saturday, January 31, 2015 12:00:19 PM

Hi Sara

My first meeting on Tuesday Feb 3 is with Miles at 12.30pm

So late morning would be best - or breakfast at hotel?. 

Depending on the weather, I get to DC late Monday night

I will be staying at the Hotel Lombardy, 2019 Pennsylvania

Thank you

Jean

On Jan 30, 2015, at 5:23 PM, Eckhouse, Sara - AMS wrote:

Thanks, Miles!

Jean,

We’re looking forward to seeing you next week. Depending on your schedule on 

Tuesday and where you are staying, it may be possible for Anne to meet you that

morning. Do you have meetings planned for the morning, or is your schedule open? If 

the morning doesn’t work, we will find another time. Please let me know when you are

 available.

Thank you, and have a great weekend.

All the best,

Sara

From: McEvoy, Miles - AMS

Sent: Friday, January 30, 2015 3:36 PM

To: Jean Richardson

Cc: Eckhouse, Sara - AMS; Alonzo, Anne - AMS

Subject: Tuesday morning

Administrator Alonzo would like to meet with you on Tuesday morning. She will be in 

touch. See you next week.

Miles

Jean’s contact information - <image001.jpg>

Miles McEvoy

Deputy Administrator

National Organic Program
This electronic message contains information generated by the USDA 

solely for the intended recipients. Any unauthorized interception of 

this message or the use or disclosure of the information it contains 

may violate the law and subject the violator to civil or criminal 

penalties. If you believe you have received this message in error, 

please notify the sender and delete the email immediately.
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Automatic reply: updating New Member guide

Date: Tuesday, May 22, 2012 11:49:43 AM

I am currently out on vacation. Please contact Rita Meade (rita.meade@ams.usda.gov) at 202-

720-3252 if you need immediate assistance.

This electronic message contains information generated by the USDA solely for the intended

 recipients. Any unauthorized interception of this message or the use or disclosure of the

 information it contains may violate the law and subject the violator to civil or criminal

 penalties. If you believe you have received this message in error, please notify the sender and

 delete the email immediately.
From: McEvoy, Miles - AMS

To: Tucker, Jennifer - AMS

Cc: Jean Richardson (

Subject: FW: updating New Member guide

Date: Tuesday, May 22, 2012 12:49:07 PM

Please provide to Jean. Thanks.

-----Original Message-----

From: Jean Richardson [mailto

Sent: Tuesday, May 22, 2012 11:49 AM

To: McEvoy, Miles - AMS

Subject: updating New Member guide

Miles:

Listening to your presentation this morning it seems that much of your slide material could be very useful to

 incorporate into the up dating of the New NOSB Member guide.

I am taking the lead role in this editing up date.

Can you e-mail some of this mornings material to me?

Thank you, Jean

This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

(b) (6) (b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS; Sarah Flack; Gwyneth Flack

Subject: Fwd: WaPo: How the government allows chemicals in “organic” food

Date: Tuesday, April 28, 2015 1:48:48 PM

jean in Post

Begin forwarded message:

From: "Jones, Samuel - AMS" <Samuel.Jones@ams.usda.gov>

Subject: WaPo: How the government allows chemicals in “organic” 

food

Date: April 28, 2015 1:44:41 PM EDT

To: "Jean Richardson ( <

Loved your quote. J Hope meeting is going well.

Thanks,

Sam Jones-Ellard

Public Affairs Specialist

USDA | Agricultural Marketing Service

202.660.2268

FYI

How the government

allows chemicals in

“organic” food

By Peter Whoriskey April 28 at 11:09 AM

You might think the USDA "organic" label is reserved for foods 

produced without any man-made chemicals. But under 

government rules, "organic" food may be grown or processed with 

the aid of scores of synthetic substances, as long as those

chemicals have been deemed essential.

Exactly which chemicals should be allowed?

This week, in a process that is largely invisible to consumers but 

(b) (6) (b) (6)
that has become a semi-annual ritual of controversy within the 

world of organic politics, a committee called the National Organic 

Standards Board is selecting those synthetic substances that 

organic farmers and processors may use.

For a movement largely built around skepticism toward synthetic 

pesticides and additives, the task of choosing the exceptions can 

be particularly delicate.

The 15-member board, composed of farmers, processors and other

 organic experts selected by the USDA, often finds itself balancing 

the ideal of chemical-free food against the practical requirements

of farming.

For while many would prefer to exclude the use of any synthetic 

chemicals, there are some substances - including herbicides, 

fungicides, emulsifiers and other additives - that some organic 

farmers say they cannot do without.

At its meeting this week, for example, the NOSB is weighing the 

merits of more than 200 substances that at least some farmers say

 are necessary to produce organic food. Others, including 

consumer groups, meanwhile urge caution.

The pleadings unfold in a blur of chemistry and agronomy. Among

 the dozens of public commenters on Monday were a potato 

grower from Oregon is asking for the board to approve a chemical 

to keep his stored spuds from sprouting; a maker of organic 

lecithin - lecithin is an emulsifier common in may foods - who 

wants the board to close the loophole that allows synthetic 

lecithin; and an organic advocate from Vermont who, speaking for

 some strawberry farms, wants the board to preserve the exception

 for ferric phosphate, a chemical used as a slug and snail bait.
The potato grower, Derin Jones, from Chin Family Farms, 

acknowledged that a natural substance, clove oil, can be used to 

keep potatoes from sprouting. But a chemical known as "3-

decene-2-one" or "3D2," works much better, and he showed 

pictures to prove his point.

"Clove oil has been a wonderful product," he said. But "we don't 

feel it is effective enough. It's hurting our business."

At stake, however, is the value of the organic label, a word whose 

value to consumers is the foundation of a growing $32 billion 

industry.

Organic farms use only a small fraction of the synthetic chemicals 

allowed on conventional farms. But watchdog groups argue that 

the board should more forcefully move minimize the exceptions or

 risk degrading the meaning of the label.

The USDA organic label "may have been in the lead 10 or 15 years 

ago, but they're not anymore," said Urvashi Rangan, executive 

director of food safey and sustainibility at Consumer Reports. 

"This is something they need to focus on."

Mark Kastel, co-founder of the Cornucopia Institute, a watchdog 

group devoted to organics, blamed the rapid pace of the 

deliberations for preventing the public from weighing in. He 

called the meetings this week "organic regulatory theater."

Others, however, defended the process. Jean Richardson, a maple 

syrup producer and professor emerita from the University of 

Vermont, is the chairperson of the panel. She notes that the 

decisions they make must balance the livelihoods of farmers 
against the consumer demand for purity.

"We're romantic realists," Richardson said. "Our values are really 

strong - we want the world to be a better place in every way. But 

we're realistic...We recognize that there is not a perfect answer."

The board findings are sent to the USDA, and serve as the basis 

for the final rules regulating what is and what isn't organic.
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: FW: WaPo Article on Hydroponics/Organic

Date: Sunday, February 23, 2014 7:15:17 AM

See Burlington free press article.

Miles V McEvoy

Deputy Administrator

National Organic Program

From: Jones, Samuel - AMS 

Sent: Thursday, February 20, 2014 9:49 AM

To: McEvoy, Miles - AMS; Tucker, Jennifer - AMS; Morris, Erin - AMS; Bailey, Melissa - AMS

Subject: WaPo Article on Hydroponics/Organic

http://www.washingtonpost.com/lifestyle/home/hydroponics-organic-label-is-allwet/2014/02/18/e5d174f6-91f2-11e3-b3f7-f5107432ca45_story.html

Here is the Burlington Free Press Article as well:

http://www.burlingtonfreepress.com/article/20140216/GREEN01/302160013/How-organicare-vegetables-when-they-re-grown-in-hydroponic-greenhousesThanks,

Sam Jones-Ellard

Public Affairs Specialist

USDA | Agricultural Marketing Service

202.660.2268

This electronic message contains information generated by the USDA solely for the intended

recipients. Any unauthorized interception of this message or the use or disclosure of the

information it contains may violate the law and subject the violator to civil or criminal

penalties. If you believe you have received this message in error, please notify the sender and

delete the email immediately.
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: WaPo Article on Hydroponics/Organic

Date: Sunday, February 23, 2014 8:40:07 AM

OK saw inaccurate quote of mine in Burlington paper -always disappointing when I spent an 

hour with him!! But that is the way it goes.

On Feb 23, 2014, at 7:15 AM, McEvoy, Miles - AMS wrote:

See Burlington free press article.

Miles V McEvoy

Deputy Administrator

National Organic Program

From: Jones, Samuel - AMS

Sent: Thursday, February 20, 2014 9:49 AM

To: McEvoy, Miles - AMS; Tucker, Jennifer - AMS; Morris, Erin - AMS; Bailey, Melissa - AMS

Subject: WaPo Article on Hydroponics/Organic

http://www.washingtonpost.com/lifestyle/home/hydroponics-organic-label-is-allwet/2014/02/18/e5d174f6-91f2-11e3-b3f7-f5107432ca45_story.html

Here is the Burlington Free Press Article as well:

http://www.burlingtonfreepress.com/article/20140216/GREEN01/302160013/Ho

w-organic-are-vegetables-when-they-re-grown-in-hydroponic-greenhousesThanks,

Sam Jones-Ellard

Public Affairs Specialist

USDA | Agricultural Marketing Service

202.660.2268

This electronic message contains information generated by the USDA 

solely for the intended recipients. Any unauthorized interception of 

this message or the use or disclosure of the information it contains 

may violate the law and subject the violator to civil or criminal 

penalties. If you believe you have received this message in error, 

please notify the sender and delete the email immediately.
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: Virtual presence at NOSB meeting

Date: Tuesday, July 21, 2015 10:47:11 AM

OK - new date?

Jean

On Jul 21, 2015, at 10:27 AM, McEvoy, Miles - AMS wrote:

> Yes, though the NOC meeting has been postponed.

>

> -----Original Message-----

> From: Jean Richardson [mailto

> Sent: Tuesday, July 21, 2015 10:09 AM

> To: McEvoy, Miles - AMS

> Subject: Virtual presence at NOSB meeting

>

> Hi Miles

> How about adding Harold's situation to our discussion with Abby tomorrow. Lets get NOC buy in to reduce

 fussing with Colehour at meeting Jean

(b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: Vermont visit

Date: Thursday, July 05, 2012 2:21:54 PM

Sounds good. I will book a table. Jean

On Jul 5, 2012, at 2:00 PM, McEvoy, Miles - AMS wrote:

Thanks for the invite. It would be nice to stay with you but I need to stay with the audit

 team up in Burlington. Let’s do Wednesday night and go to Starry Night. 6 pm?

Miles

From: Jean Richardson [mailto:

Sent: Tuesday, July 03, 2012 6:04 PM

To: McEvoy, Miles - AMS

Subject: Re: Vermont visit

Hi Miles, It would be great to see you.

And of course you would be most welcome to stay at my house. 3 spare 

bedrooms.

I can give you a spare key so you can come and go.

I have inspections and NOSB phone calls of course....

My place is 30 minutes drive south from airport/Burlington.

And I am free any of those nights. If we have dinner on Wednesday I could take 

you to my favorite restaurant, Starry Night cafe (closed Monday and Tuesday)

Jean

On Jul 3, 2012, at 5:04 PM, McEvoy, Miles - AMS wrote:

Jean –

I will be in Burlington next week. Are you around? Could we meet for dinner? I’ll be 

flying in Monday afternoon and leaving Thursday afternoon. It would be great to see 

you.

Miles McEvoy

Deputy Administrator

National Organic Program

202-720-3252

(b) (6)
This electronic message contains information generated by 

the USDA solely for the intended recipients. Any 

unauthorized interception of this message or the use or 

disclosure of the information it contains may violate the law 

and subject the violator to civil or criminal penalties. If you 

believe you have received this message in error, please notify 

the sender and delete the email immediately.
From: McEvoy, Miles - AMS

To: "Jean Richardson"

Subject: RE: Vermont schedule

Date: Tuesday, January 20, 2015 2:39:48 PM

I'm scheduled to arrive at 4:17 in Burlington and leave at noon on Sunday. We may not be able to fit skiing in.

-----Original Message-----

From: Jean Richardson [mailto

Sent: Tuesday, January 20, 2015 12:48 PM

To: McEvoy, Miles - AMS

Subject: Vermont schedule

Hi Miles

Just planning dinner on Friday 13 with Nate. Enid, Nicole and wonder what time you get in Friday the 13th./ Dinner

 is at 7 pm And also if we ski Sunday ... do you depart Sunday evening? Monday morning?

thanks Jean

This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.

(b) (6)
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: Vermont logistics

Date: Wednesday, February 11, 2015 10:17:38 AM

Ok

Sent from my iPhone

> On Feb 11, 2015, at 8:15 AM, McEvoy, Miles - AMS <Miles.McEvoy@ams.usda.gov> wrote:

>

> Sounds like a great plan. I just wrote to Sara that I don't think I have the clothes for the ski trip - also it will

 provide more time to hang out at NOFA.

> I have one checked bag so that will take a few minutes to pick up through baggage claim. I'll text you when I land

 and let you know if there are any delays to my flight.

>

> Best, Miles

>

> -----Original Message-----

> From: Jean Richardson [mailto

> Sent: Wednesday, February 11, 2015 7:59 AM

> To: McEvoy, Miles - AMS

> Subject: Vermont logistics

>

> Hi Miles

> Your plane gets in at 1.10 pm Friday. Text me when it lands so I can cruise by the exit doors and pick you up.

> I will be driving a black Honda Truck

> Will you just carry one a bag or check one? We cannot park by doors so this will help me estimate time.

>

> I will probably be on the Exec Call on headset and phone in Truck and you can join if you want as we drive home

 (25 mins). Then you can do the Materials call.

> Dinner is in Burlington at Hen of the Woods at 7 pm with Nate, Enid, Nicole and me.

>

> Saturday we will go in to University. We will be walking between buildings at zero and below zero before any

 wind. So it will be horribly cold. Snow on ground. Really warm jacket, down vest, and really warm boots, (dress

 shoes not needed). I probably don't need to say these things but would not like you to be cold.

> Workshop 10.45 am - noon, (Terrill) check in at Registration at 10.15 (Davis) Leahy and speakers 12 .30 ? (Davis

 )

>

> 1-2 Round Table (Davis)

> Then Sarah will ski with you at Bolton (not far west of Burlington) and there is a NOFA Social if you want from

 5.15-7.30, then dinner with Sarah, Johanna from PCO and Nate again at Hen of Woods! Nate's favorite place!

 Unless you want to eat at home (valentines night, no tables anywhere)

>

> Sunday you can snow shoe here at home out back, or ski, before getting noon plane

>

> Off to do a slaughter facility inspection. Not my favorite type of inspection.

> Jean

>

>

>

>

>

> This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

(b) (6)
 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.
From: Jean Richardson

To: Tracy Favre

Cc: McEvoy, Miles - AMS; Arsenault, Michelle - AMS

Subject: Re: vehicle emissions

Date: Saturday, October 18, 2014 1:17:57 PM

Hi all

I do not remember this poor chap in San Antonio.

can someone please reassure him that although this is an issue for human health over time on 

all farm lands next to major highways, it will not impact his organic certification, ...but that 

yes, he has no rights regarding public highways !!!

And also help him know that it is beyond NOSB and NOP control

Jean

On Oct 17, 2014, at 8:02 PM, Tracy Favre wrote:

Any resource I can point him to?

Tracy

Sent from my iPhone

Begin forwarded message:

From: "Tim P. Miller" <millbergfarm@austin.rr.com>

Date: October 17, 2014 at 1:53:57 PM CDT

To: <tfavre@favrehouse.com>

Subject: vehicle emissions

I have been trying to reach out to someone who would listen to my 

very damaging problem on my 25 year Certified Organic farm in Kyle 

Texas. A major new highway is being planned within 100 feet of my 

operation(5 acres). From what I can find out vehicle emissions are 

totally unhealthy and the vehicle emissions and vehicle dust will be

impacting me negatively. My rainwater collection system will now be 

polluted with no way to remove it with any economical filtering 

system. I have told the group and County Commissioners this with 

no response back. Can the city, county and state legally pollute me

out of business with vehicle emissions? My TDA certifier has not 

been of any help only saying they don’t test for vehicle emission..but

they do test for heavy metals. My only source of water is my 

rainwater collection system but TDA said they are not responsible for

testing water..Health Dept is. which leads me to believe they will get 

me for out of compliance with vehicle emissions in my water source 

after the highway is built.
What does the EPA say about this matter on allowable limits of 

vehicle emissions in water,in soil, on crops inside crops on Certified 

Organic farms? What standards exist surely the NOP has something I 

can’t find it. I spoke about his briefly in San Antonio and would have

thought I would get a response back from the NOSB but nothing. The 

highway project is pushing forward and I am concerned with my 

rights.Tim P. Miller Millberg farm
From: Jean Richardson

To: McEvoy, Miles - AMS; Tracy Favre

Subject: Vaccines comment-Hue Karreman

Date: Saturday, April 11, 2015 12:20:26 PM

Interesting vaccine comment from Hue Karreman -Allow all types.

Biologics, Vaccines: No alternatives have emerged since the last review and I doubt if there 

ever will be. The only thing which is close are the homeopathic class of compounds called 

nosodes. However, a true nosode is to be made from actual disease materials and used in the 

face of an outbreak, much like it was in the human epidemic of yellow fever.

Vaccine help to prevent disease. And yes, all types of vaccines should be allowed. In fact, 

most of the newest ones, such as the recently tested new Ebola vaccine is derived from utant 

bovine cells through genetic engineering. This is also the case with the newest Foot and Mouth

 vaccines as they can be generated rapidly instead of waiting the 6 months orr so the typical 

conventionally produced vaccines take to come to market.

Jean
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Re: vaccines

Date: Tuesday, April 07, 2015 10:45:13 AM

Yes, That avoids the fact that most certifiers do not track vaccines, that there is no APHIS or other list that is

 perfect, that the definition of excluded methods needs a re-write, and is not the same definition as the one APHIS

 uses; Further if certifiers did track vaccines, which change in formulations, they would find that 99% of them are

 non-gmo, and by not throwing it back to NOSB you are not alerting consumers that there is any issue.

Obviously the salmonella vaccine should be petitioned!

I was out teaching a university class on organics this morning.

Jean

On Apr 7, 2015, at 8:18 AM, McEvoy, Miles - AMS wrote:

> How about this -

>

> The NOP has received the NOSB's recommendation on livestock vaccines made with excluded methods. The

 NOP appreciates the complexity of this issue and the great amount of work that NOSB has invested in this review.

 The NOP suggests that vaccines produced from excluded methods be considered on a case by case basis, using the

 petition process. The NOSB can then evaluate the need, benefits and any risks from the specific types of vaccines in

 question. 

>

> Miles

>

> -----Original Message-----

> From: Jean Richardson [mailto

> Sent: Monday, April 06, 2015 6:10 PM

> To: McEvoy, Miles - AMS

> Subject: Re: vaccines

>

> Let me think about this.

> The logical thing is to continue doing what we are doing which is mostly to allow all the vaccines.

> What do the Canadians do?

> You want to talk it through ?

>

> On Apr 6, 2015, at 5:51 PM, McEvoy, Miles - AMS wrote:

>

>> Can you suggest a different response?

>>

>> -----Original Message-----

>> From: Jean Richardson [mailto:

>> Sent: Monday, April 06, 2015 5:42 PM

>> To: McEvoy, Miles - AMS

>> Subject: Re: vaccines

>>

>> So the impossibility is that this goes to the very heart of the issue, namely that we cannot say, and neither can

 APHIS, which vaccines for sure meet or do not meet the Excluded Methods standard. We can fudge it and say use

 the "R". But the NOSB does not have the capacity to weigh risks and benefits.... We could put it on our Research

 agenda? the petition process is a good idea.

>> you want to chat about this? ACA hopes we all ignore this for now

>>

(b) (6) (b) (6)
>> On Apr 6, 2015, at 5:27 PM, McEvoy, Miles - AMS wrote:

>>

>>> How's this?

>>>

>>> NOP Response:

>>>

>>> The NOP has received the NOSB's recommendation on livestock vaccines made with excluded methods. The

 NOP appreciates the complexity of this issue and the great amount of work that NOSB has invested in this review.

 The NOP will not be able to provide guidance regarding identification of vaccines produced from excluded

 methods, unless the NOSB can provide additional information by recommending the types of methods used in

 vaccine production that should be considered excluded. In the meantime, NOP suggests that vaccines produced

 from excluded methods be considered on a case by case basis, using the petition process. The NOSB can then

 evaluate the need, benefits and any risks from the specific types of vaccines in question. 

>>>

>>> -----Original Message-----

>>> From: Jean Richardson [mailto

>>> Sent: Saturday, April 04, 2015 7:50 AM

>>> To: McEvoy, Miles - AMS

>>> Subject: vaccines

>>>

>>> Hi Miles

>>> You mentioned yesterday that NOSB will get vaccines back again and suggested we work with the R on the

 APHIS List.

>>> I am not sure who at NOP has written the NOP response, but all stakeholders, including APHIS agreed that we

 do not have a functional List that would allow us to do that. So hopefully you are providing some detailed

 direction?

>>> I am going to look at the Canadian language.

>>> Jean

>>>

>>

>

(b) (6)


favoritism and collaboration with the corporate sector.

Cornucopia, in 2009, collaborated with a Washington Post investigation exposing a sweetheart deal between a powerful industry lobbyist and Dr. Barbara Robinson, 

then head of the USDA’s organic program. She allegedly illegally approved materials for use in organics, overruling her staff and bypassing the NOSB. Cornucopia

subsequently called upon both President Obama and USDA Secretary Vilsack to remove Dr. Robinson, which ultimately occurred later that year.

"For those of us who were practicing organic agriculture prior to Congress authorizing the USDA to oversee this industry, the behavior of current management at the

NOP is a big disappointment," said Helen Kees, Cornucopia's Board President and an organic beef and vegetable producer from Wisconsin. "The authority of the

NOSB has been undermined, and it doesn't really matter whether Miles McEvoy is the chief architect or just willingly carrying out orders. The organic community

needs an independent voice that can be universally respected to head this important regulatory body," Kees asserted.

-30-

MORE

In the past, the process by which the NOSB operated was developed by the Board itself, in collaboration with organic stakeholders, after being officially noticed in the

Federal Register.

"The Policy Procedure Manual (PPM) was developed by the Board, after extensive public input, and approved by the USDA during the Bush administration," according

 to former NOSB Chairman Dr. Flamm.

During his five years on the NOSB, Dr. Flamm also served for four years as the chairman of the Policy Subcommittee, which developed the NOSB’s PPM.

"You don't need to take The Cornucopia Institute's word alone in supporting the thesis that the USDA has overstepped their legal authority and undermined the unique

 process Congress set up to assure organic stakeholders that corporations would not wield undue influence in promulgating organic law," Cornucopia’s Kastel added.

Last year, in a blunt letter, the two primary authors of the enabling legislation, the Organic Foods Production Act of 1990, Representative Peter DeFazio and the

Senate's longest-serving member, Patrick Leahy, both clearly expressed that, in their unique position to judge, the edict reversing the Sunset procedures clearly

violated the will of Congress.

The two congressional leaders were echoed in another letter to Secretary Vilsack, by three prominent past chairman of the NOSB: James Riddle, founder of

Independent Organic Inspectors Association; Jeff Moyer, a longtime organic farming educator/leader with the Rodale Institute; and Dr. Barry Flamm, a natural 

resource and environmental consultant, the first certified organic cherry producer in Montana, and board secretary of The Cornucopia Institute.

More Organic Regulatory Theater

Since the NOSB was designed to have broad industry representation, and is not a scientific panel, Congress gave the body the authority to engage scientific experts

to do Technical Reviews of synthetics and other materials up for consideration. This part of the law has never been respected. Instead, the USDA has hand-picked the

 contractors. In the earlier history of the organic program, they chose agribusiness executives and consultants to review materials petitioned by corporate

agribusiness. This was a clear conflict of interest, thoroughly outlined in Cornucopia’s white paper, The Organic Watergate.

Currently, the USDA is contracting nonprofit organizations funded by corporate agribusiness to conduct the materials reviews. In one case, the nonprofit wing of the

powerful industry lobby group, the Organic Trade Association, is preparing Technical Reviews for the NOSB.

“This is a clear conflict of interest and the proverbial fox watching the organic chicken coop,” stated Cornucopia’s Kastel. “A further cloak of secrecy the USDA has

donned, regarding the conflicts exposed in The Organic Watergate report, is that the agency is now refusing to disclose the names of the scientists writing the 

Technical Reviews for this public body —this makes critiquing potential conflicts of interest impossible.”

Along with the nearly insurmountable workload imposed on the NOSB by the USDA, the agency has refused to spend adequate dollars to pay for Technical Reviews

the NOSB has requested. Instead, NOP officials are touring the country in what some have charged is an expensive public relations campaign selling organics. “This

leaves the NOSB ill-equipped to rigorously review many of the synthetic and non-organic materials that are up for review and that were not properly scrutinized when

they were added to the National List in the first place,” stated Kastel.

HAVING TROUBLE VIEWING THIS? CLICK HERE FOR A WEB VERSION.

READ RECENT PRESS RELEASES FROM THE CORNUCOPIA INSTITUTE.

CLICK HERE TO UNSUBSCRIBE.

The Cornucopia Institute

is a nonprofit organization engaged in research and educational activities supporting the ecological principles and economic wisdom underlying sustainable and organic agriculture.

Through research and investigations on agricultural and food issues, The Cornucopia Institute provides needed information to family farmers, consumers, stakeholders involved in the

good food movement, and the media.

P.O. Box 126 Cornucopia, Wisconsin 54827

TEL: 608-625-2000 | FAX: 866-861-2214 | www.cornucopia.org
From: Jean Richardson

To: McEvoy, Miles - AMS; Brown Rosen, Emily - AMS

Subject: Fwd: USDA Listening Session

Date: Monday, October 20, 2014 1:52:17 PM

FYI, 

I answered him and thanked him for his comments

No need to circulate this I think.

I will make some opening comments on the Tuesday morning, very short, asking us all to

work together etc.

Jean

Begin forwarded message:

From: <Zareb.Herman@hain.com>

Date: October 20, 2014 10:40:56 AM EDT

To: <

Subject: USDA Listening Session

Hello Dr. Richardson, we exchanged emails following the Portland meeting. I feel 

compelled to email you concerning the USDA listening session on Thursday. If you 

listened, you may have noticed that only one organic food company commented on the

 new sunset policy. While the NOP was heavy-handed in the way they announced the 

new policy, the vast majority of organic handlers support the policy because we cannot 

make our products without ingredients from the national list. Under the old policy a 

minority of Board members could vote most substances off the list, and they were 

planning to do just that. If we support the new policy, why don’t we speak up?

In San Antonio, my colleague, Allyson Kelly, made a strong statement in support of the 

new policy. While she was speaking, Mark Kastel of Cornucopia took a photo of her and

 put it up on their web site. They attacked our company on their web site and on 

Facebook and twitter. They called for a boycott of our products. After the meeting, 

another leader of Cornucopia came up to me and threatened to harm our company. 

This type of thing has been happening for the past 5 years. Any company that speaks 

up gets attacked. We have lost a lot of sales. These groups say that we are using toxic 

chemicals in our foods, which is not true.

This is why so few companies say anything at NOSB meetings. It’s a form of extortion. 

Members of the Organic Consumers Association have even gone into stores and put 

horrible stickers on companies’ products. Whole Foods hasn’t done anything because 

they are afraid of these groups too.

I just wanted to let you know this, in case you are unaware. You are a fair and objective 

person, and you will be an excellent Board Chair. I request that you not say anything 

publicly that would identify my company. This would increase the attacks on us.

(b) (6)
Sincerely,

Zareb

Zareb Herman

Regulatory Affairs Director

Azusa, CA Office

The Hain Celestial Group

16007 Camino de la Cantera

Azusa, CA 91702

phone: 626-385-0639

fax: 626-969-9821

zareb.herman@hain.com

** This e-mail is sent by The Hain Celestial Group, Inc. and/or one

 of its subsidiaries. The information and attachments contained in 

this e-mail message may contain privileged and confidential 

information and is for the exclusive and confidential use of the 

intended recipient. If you are not the intended recipient, you are 

hereby requested not to read, distribute, copy or take action in 

reliance upon this communication. If you have received this 

communication in error, please notify us immediately by telephone 

or return e-mail and delete this e-mail and any attachments from 

your computer system. **
From: Jean Richardson

To: Bradley, Mark - AMS

Cc: mac.stone@kysu.edu; tfavre@favrehouse.com; Arsenault, Michelle - AMS; McEvoy, Miles - AMS

Subject: Re: USDA certification of wild Alaska fish as organic

Date: Tuesday, September 30, 2014 8:33:29 AM

Great Mark. I will wait till I get that additional piece and put it all together for them so I can 

chat about it with them next Tuesday. Hopefully this will work!

Best

Jean

On Sep 30, 2014, at 8:11 AM, Bradley, Mark - AMS wrote:

Hi Jean,

When we met with Mike and Dennis, I also mentioned that there are other 

options to provide verified marketing claims. Specifically, we have the USDA 

Process Verified Program for 3rd party claims verification. I described the 

marketing logos that are available through that program. I also gave him the link 

to the Process Verified Program and explained that it may be a good interim step:

Link to USDA Process Verified Program

http://www.ams.usda.gov/AMSv1.0/ams.fetchTemplateData.do?

template=TemplateN&navID=GradingCertificationandVerfication&leftNav=Gradin

gCertificationandVerfication&page=ProcessVerified.usda.govHomePage

The former program manager for PVP, Jim Riva, just retired. I’ll find out who the 

best functional person would be and cc you guys with the info.

Thanks,

Mark

From: Jean Richardson [mailto:

Sent: Monday, September 29, 2014 7:29 PM

To: Bradley, Mark - AMS

Cc: mac.stone@kysu.edu; tfavre@favrehouse.com; Arsenault, Michelle - AMS; McEvoy, 

Miles - AMS

Subject: Re: USDA certification of wild Alaska fish as organic

Hi Mark

Thank you for discussing this with me. As you suggested I chatted with Mike 

Szymanski in Alaska. He talked at length about a desire to be able to label as 

organic deep water wild fish which grow in a managed sector of the Bering Sea. I

 described the annual organic certification process for wild crop harvesting in 

terrestrial ecosystems, and necessary level of management verification. He 

(b) (6)
already has considerable management oversight. I described the new AMS 100% 

grass fed certification program and suggested an analogous certification for wild 

caught fish may be an alternative to spending time trying to seek organic 

certification. He is keen to continue our conversation and wants to include 

Dennis Moran in Seattle to join us in a call on Tuesday October 4. I offered to

find out who they should talk with at AMS about possible certification like the 

100% grass fed.

Any suggestions?

They are keen to have some sort of a seal in order to compete with the organic 

farmed fish.

Seems like a nice guy.

What can we do to help him?

Thank you

Jean

On Sep 23, 2014, at 1:16 PM, Jean Richardson wrote:

Very helpful

Thank you

Jean

On Sep 23, 2014, at 12:48 PM, Bradley, Mark - AMS wrote:

Hi Jean,

As I mentioned, there is a bit of history in the discussion regarding organic 

certification of wild caught fish. The discussion goes back to the earliest days of 

the NOP rule. I’ve pasted in some links and summary discussion to the earlier

documents here.

2001 Task Force Report on Aquatic Animals

http://www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELDEV3104580

The Task Force concludes that operations that capture wild aquatic animals do not reflect 

the

degree of producer management, continuous oversight, and discretionary decision-making 

that

are characteristic of an organic system. The regulated capture of aquatic animals from wild

populations is unquestionably a managed system, but it does not afford producers the

opportunities to exercise the specific production responsibilities that are required by the 

OFPA.

Producing aquatic animals without violating the livestock origin, feed ration, health care, 

and living

conditions requirements in the OFPA does not make for an organic production system. The

inclusion of those requirements in the OFPA necessitates that they be pro-actively 

managed and

that in doing so a producer intentionally choose materials and practices that are consistent 

with
the standards. Since wild capture aquatic animal operations do not allow producers to make

these essential decisions, the Task Force recommends that the NOSB not develop 

standards for

the certification of aquatic animals captured in the wild.

2001 NOSB recommendation on aquaculture

http://www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELDEV3104581

Aquatic Animal Task Force Recommendations - The NOSB accepted the report 

of the

aquatic animal task force and approved the following recommend:

1. No standards be developed for wild caught aquatic animals;

2. Standards be developed for the production of farmed aquatic animals that 

reflect an

innovative approach to organic certification while remaining fully consistent with 

the

statutory requirements of the Organic Foods Production Act; and

3. If standards are developed for farmed aquatic animals, we recommend that the

National Organic Program and the National Organic Standards Board use the 

aquatic

animal task force report as guidance.

Eric Sideman moved to approve and Willie Lockeretz seconded the motion. (14 in

 favor,

0 opposed, 0 abstaining)

More recently, the NOSB and supporting Aquaculture Working Group also opted 

to not include wild caught seafood in the pending regulations for organic seafood.

Interim Final Report of the Aquaculture Working Group

http://www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELPRDC5062436

Item for public comment -

http://www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELDEV3025623

Members for the wild-caught working group have not yet been named, because of

 a low response to the call for nominations.

Thanks,

Mark

<image001.jpg> Mark A. Bradley | Assistant to the Deputy Administrator | 202.690.0725 | FAX 

202.205.7808 | Cell 

USDA – AMS – NATIONAL ORGANIC PROGRAM | 1400 Independence Ave. 

SW | Washington, DC 20250

Organic Integrity from Farm to Table, Consumers Trust the Organic Label

Register to receive NOP Announcements -

http://bit.ly/NOPOrganicInsiderRegistration

(b) (6)
From: Jean Richardson [mailto:

Sent: Tuesday, September 23, 2014 9:02 AM

To: Bradley, Mark - AMS

Cc: mac.stone@kysu.edu; tfavre@favrehouse.com; Arsenault, Michelle - AMS; McEvoy, 

Miles - AMS

Subject: Re: USDA certification of wild Alaska fish as organic

Mark

Apart from the OFPA citation below from 7 USC Section 6506, you comment below 

that you briefed them on the status of wild caught sea food. Can you direct Tracy, 

Mac and I to any additional written documents on this subject which would be helpful 

to us as we work together to determine possible next steps.

We would like to have the maximum amount of detail on the history of this discussion

 before opening up a conversation on the potential for organic certification of wild

caught seafood.

I am very familiar, as a producer and inspector, with the "Wild-crop harvesting 

practice standard" at 205.207 which is used for mushrooms and maple sap 

production. - pasted below

We could set up a conference call between the 5 of us, and Betsy once we have 

more detailed information.

Thank you

Jean

7 USC ch 94 S 6506

(c) Wild seafood

(1) In general

Notwithstanding the requirement of subsection (a)(1)(A) of this section requiring

 products be produced only on certified organic farms, the Secretary shall allow, 

through regulations promulgated after public notice and opportunity for comment, 

wild seafood to be certified or labeled as organic.

(2) Consultation and accommodation

In carrying out paragraph (1), the Secretary shall—

(A) consult with—

(i) the Secretary of Commerce;

(ii) the National Organic Standards Board established under section 6518 

of this title;

(iii) producers, processors, and sellers; and

(iv) other interested members of the public; and

(B) to the maximum extent practicable, accommodate the unique 

characteristics of the industries in the United States that harvest and process 

wild seafood.

(b) (6)
Title 7: Agriculture

PART 205—NATIONAL ORGANIC PROGRAM

Subpart C—Organic Production and Handling Requirements

§205.207 Wild-crop harvesting practice standard.

(a) A wild crop that is intended to be sold, labeled, or represented as organic 

must be harvested from a designated area that has had no prohibited substance, as 

set forth in §205.105, applied to it for a period of 3 years immediately preceding the 

harvest of the wild crop.

(b) A wild crop must be harvested in a manner that ensures that such harvesting

 or gathering will not be destructive to the environment and will sustain the growth and

 production of the wild crop.

On Sep 22, 2014, at 11:28 AM, Bradley, Mark - AMS wrote:

Good morning,

Last week Miles and I met with two representatives of an Alaskan seafood company 

called Fisherman’s Finest. They were interested in finding out how wild caught seafood

 could be certified as organic. They were aware of the provisions in OFPA for wild 

caught seafood, but were not aware of the discussion since the regs came into effect.

We briefed them on the status of wild caught seafood and organic certification; We did

 not give them any impression that certification of wild caught seafood would be likely 

to happen soon. Miles and I explained that new initiatives such as this would normally 

be presented by a board member for possible inclusion on the NOSB’s workplan. As 

such, it would most likely come through a committee chair or the Board chair. Mr. 

Szymanski asked for appropriate contact information for each of you and, as you can 

see below, we have opted to allow you the opportunity to protect your email if you so

choose.

If you like, you may contact Mr. Szymanski at his email below. It may be that you would

 prefer to decide amongst yourselves who would be the best point of contact for him 

and let one person do the communicating. Your call.

Please let me know if you choose to pass on this conversation and I can advise Mr. 

Szymanski to send a generic letter to the Board to present his case.

Thanks for all you do for the organic community...

Mark

<image001.jpg> Mark A. Bradley | Assistant to the Deputy Administrator | 202.690.0725 | FAX 

202.205.7808 | Cell 

(b) (6)
USDA – AMS – NATIONAL ORGANIC PROGRAM | 1400 Independence Ave. 

SW | Washington, DC 20250

Organic Integrity from Farm to Table, Consumers Trust the Organic Label

Register to receive NOP Announcements -

http://bit.ly/NOPOrganicInsiderRegistration

From: Bradley, Mark - AMS

Sent: Monday, September 22, 2014 10:26 AM

To: 'Mike Szymanski'

Subject: RE: USDA certification of wild Alaska fish as organic

Hi Mike,

I met with our NOSB advisory board specialist late last week to discuss providing 

contact information for NOSB members. She said the Program had agreed to not 

provide private email addresses for board members unless their information is 

published somewhere already. This is to avoid situations where interest groups direct 

mass mailings to their private accounts.

Jean Richardson is the current NOSB Chair. Tracy Favre is the Livestock Sub-committee 

Chair. Mac Stone is the most recent past Chair and has a background in aquaculture.

I’ll contact them to let them know that you are interested in discussing next steps 

toward making wild caught Alaskan seafood eligible for the USDA organic seal.

Thanks,

Mark

From: Mike Szymanski [mailto:

Sent: Friday, September 19, 2014 9:15 PM

To: Bradley, Mark - AMS

Cc: Dennis Moran

Subject: Re: USDA certification of wild Alaska fish as organic

Hello Mark,

First let me thank you again for meeting with Dennis Moran and I on Tuesday.

I was looking over my notes from our meeting and noted a few names you 

suggest we contact concerning our project of obtaining Organic Standards for 

harvest Alaska wild fish.

Do you have phone and email contact information on these NOSB members? I 

understand that Mac Stone was a proponent of the Aquatic Standards but don’t 

remember what Jean Richardson and Tracy Favre did in this process?

Former Chairman, Robert (MAC) Stone

Jean Richardson, NOSB Member

and I think a Tracy Favre, NOSB Member......

We have a lot to learn about this process and do appreciate your guidance. By the 

(b) (6)

From: Jean Richardson

To: Jones, Samuel - AMS; McEvoy, Miles - AMS

Subject: Washington post article

Date: Friday, June 27, 2014 11:29:01 AM

Hi Sam

I read the article in the Washington Post by Peter Laufer and sent him a short response - his email was in the article-

 his responses to me were astoundingly rude and very defensive!!!! - so if you were to draft a reply to the Post I

 would be happy to be the person sending it in over my signature- it would look less self serving (government

 response) so to speak - in fact I am happy to have my signature used on other articles you may long to get out

 there!. It would be good to get some reasonable press for a change! One thing to emphasize is the tiny percentage

 of organic in the context of US agriculture.

I have contacted PR people for each of the retiring board members this year, but it is slow progress so far! My goal

 with these would be to get in house (places of work of board members) articles written which NOP could then

 capture and distribute etc.

I did a TV interview type video here in Vermont on Organics 101. It may be distributed by utube. I have not yet

 seen the edited version! My dachshund sits on my knee throughout!! People love dogs!

Best Regards,

Jean
From: McEvoy, Miles - AMS

To: Jean Richardson

Subject: Automatic reply: Washington post article

Date: Friday, June 27, 2014 11:29:01 AM

I am out of the office through June 27. Please contact Joan Avila at 202-720-3252,

 joan.avila@ams.usda.gov if you need immediate assistance.

This electronic message contains information generated by the USDA solely for the intended

 recipients. Any unauthorized interception of this message or the use or disclosure of the

 information it contains may violate the law and subject the violator to civil or criminal

 penalties. If you believe you have received this message in error, please notify the sender and

 delete the email immediately.
From: Jean Richardson

To: Jones, Samuel - AMS

Cc: McEvoy, Miles - AMS

Subject: Re: Washington post article

Date: Sunday, June 29, 2014 1:09:46 PM

Hi Sam

Thank you for the OTA response. well done.

Jean

On Jun 27, 2014, at 2:00 PM, Jones, Samuel - AMS wrote:

> Hi Jean,

>

> Thanks for reaching out. Not sure if you saw this response from OTA: http://organic-center.org/news/responseto-op-ed-five-myths-about-organic-food/?utm_source=OTA+Members&utm_campaign=ca29d27416-

OTA_News_Flash_June_24_20146_24_2014&utm_medium=email&utm_term=0_03666ec055-ca29d27416-

414393125.

>

> I will touch base with Miles on Monday about the op-ed piece and we will get back to you. And, thanks for offer

 up your signature.

>

> Can't wait to check out your video! We will touch base next week, and you have a great weekend!

>

> All the best,

> Sam Jones-Ellard

> Public Affairs Specialist

> USDA | Agricultural Marketing Service

> 202.660.2268

>

>

> -----Original Message-----

> From: Jean Richardson [mailto

> Sent: Friday, June 27, 2014 11:29 AM

> To: Jones, Samuel - AMS; McEvoy, Miles - AMS

> Subject: Washington post article

>

> Hi Sam

> I read the article in the Washington Post by Peter Laufer and sent him a short response - his email was in the

 article- his responses to me were astoundingly rude and very defensive!!!! - so if you were to draft a reply to the

 Post I would be happy to be the person sending it in over my signature- it would look less self serving (government

 response) so to speak - in fact I am happy to have my signature used on other articles you may long to get out

 there!. It would be good to get some reasonable press for a change! One thing to emphasize is the tiny percentage

 of organic in the context of US agriculture.

>

> I have contacted PR people for each of the retiring board members this year, but it is slow progress so far! My

 goal with these would be to get in house (places of work of board members) articles written which NOP could then

 capture and distribute etc.

>

> I did a TV interview type video here in Vermont on Organics 101. It may be distributed by utube. I have not yet

 seen the edited version! My dachshund sits on my knee throughout!! People love dogs!

> Best Regards,

> Jean

>

>

(b) (6)
>

>

>

> This electronic message contains information generated by the USDA solely for the intended recipients. Any

 unauthorized interception of this message or the use or disclosure of the information it contains may violate the law

 and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please

 notify the sender and delete the email immediately.
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Webinars article for NODPA

Date: Sunday, June 28, 2015 9:15:32 AM

Attachments: NODPA News July 2015 Jean Richardson.docx

Hi Miles

Please could you give this a quick look over.?

Ed Maltby asked for this to put in the NODPA Notes to do "damage control" for our Webinars.

Thank you

Jean
From: Jean Richardson

To: Arsenault, Michelle - AMS

Cc: Brown Rosen, Emily - AMS; "Tracy Favre"; McEvoy, Miles - AMS

Subject: Re: Webinars and NOC

Date: Monday, June 29, 2015 5:32:04 PM

Hi Michelle

Yes I explained this to Ed as well. I have not written a detailed answer but rather addressed 

individual items for clarification. But it does give us a sense of where they are coming from.

Thank you

Jean

On Jun 29, 2015, at 5:26 PM, Arsenault, Michelle - AMS wrote:

Hi Jean,

A few notes I’m sure you have addressed already:

How does one schedule a webinar based on occupation or culture? I would argue that 

these two webinars are more convenient than planning a week-long trip to fly to VT, to

deliver comment during a very specific block of time. That seems to me to be more 

exclusive. And we aren’t eliminating that possibility. We could consider moving one of 

the webinars to a different day of the week, but I would be inclined to prioritize the 

time commitment and schedules of the Board members.

I think we need to advertise this in advance of the FR Notice publishing on ~September 

8. It doesn’t give folks enough time to prepare, considering the webinars are scheduled

 for Sept 22 and 29. Perhaps an Insider notice in addition to the outlets you are 

pursuing Jean?

· As for the PPM language, all references to Electronic Bulletin Boards was removed (by 

me and John two + years ago!), as it was clearly outdated. As I’m sure you are well 

aware. Unfortunately the updated version never made it out of PDS! 

Regarding the line in the PPM that says “At this time, full Board conference calls or full

Board assembly via electronic bulletin board is not allowed”. This refers only to full 

Board meetings that are deliberative and are intended to result in a recommendation

to the Secretary. FACA, on which this was based, does not prohibit full Board meetings 

in which “The intent is to obtain information or viewpoints from individual attendees as

 opposed to advice, opinions or recommendations from the group acting in a collective 

mode.” Again, it’s just a case of a poorly written paragraph which is why we embarked

on an update of the PPM.

http://www.gsa.gov/portal/content/100794 Here is the link to GSA FACA management

Thanks,

Michelle

From: Brown Rosen, Emily - AMS
Sent: Monday, June 29, 2015 10:41 AM

To: Jean Richardson; McEvoy, Miles - AMS

Cc: Tracy Favre; Arsenault, Michelle - AMS

Subject: RE: Webinars and NOC

Jean,

I believe it would be good for you to respond on the ‘no substantive comments’ 

statement. Comments in time for the second meeting could have great impact on 

whether you vote to remove or keep a sunset substance up for review. It was only if 

you were not recommending removal (no motion to remove on the table) that it 

would be hard to address the comments. This voting meeting is a key time to have 

public comments on sunset.

Emily

From: Jean Richardson [mailto:

Sent: Sunday, June 28, 2015 1:27 PM

To: McEvoy, Miles - AMS; Brown Rosen, Emily - AMS

Cc: Tracy Favre; Arsenault, Michelle - AMS

Subject: Webinars and NOC

Hi Miles and Emily

FYI one of the e-mails of this weekend from Ed Maltby (NODPA, part of NOC) 

regarding the need to do "damage control" on our Webinar idea which NOC 

perceives negatively because we have "changed the procedures"...

Emily note his reference to the PPM on no use of "Electronic bulletin boards".

Miles and Emily please note the ongoing concern over "no new substantive 

comments"

which appears to continue to need clarification.

When do we need to post notice of the webinar dates and how to access? 

Do we want to try for a different time slot?

Thank you

Jean

The public comment period has always been geared to what suits the 

NOSB members and the NOP. I'm thinking that any change that are made 

should shift that emphasis to accommodating the commenters that are 

not on a salary. The NOSB may be a volunteer Board but usually 2/3 are 

on a good salary.

Having three webinars that recognize different time zones, different 

occupations and cultures is making it more convenient for commenters 

and recognizes that they have respect for those that take the time to 

(b) (6)
comment.

My assumption is that the NOP sunset process does not allow new 

substantive comments on the many 2017 sunset materials to be taken 

into account by the NOSB. So, there is little reason for lengthy comments 

at this meeting if the NOP makes that clear. Time is needed for NOSB 

discussion and debate. I believe that the most effective comments will be 

(in most cases) those that summarize evidence (TRs, public comment) 

that has already been presented and draw conclusions from it. This form 

of comment will probably be more effective in written form. So it is 

possible that the fear that the public comment will be more extensive 

than at the spring meeting is exaggerated. Any thoughts on that?

There should probably to a change made to the NOSB By Laws to 

accommodate this change. The Policy and Procedures Manual says:

All Board meetings, conference calls, and bulletin board assembled for the 

purpose of making recommendations to the NOP are subject to FACA (see 

appendix B for FACA facts), In particular, these must be open to the public 

and must meet public notification requirements. Not all meetings are 

subject to FACA and do not require public notification. Examples are: 

assemblies for completing work, planning retreats, training and sharing 

information. At this time, full Board conference calls or full Board assembly

 via electronic bulletin board are not permitted. The date and location of 

periodic full in person Board Meetings (normally twice a year), will to the 

extent possible, be set by consensus of the Board in consultation with the 

NOP.

Clearly, the webinar format was not even considered in writing this. But it 

appears that electronic meetings of the full board are not allowed by the 

PPM.
NOSB is expanding the opportunity for public comment with a pilot 

project of two, 3 hour, Webinars to listen to oral public comment as well 

as in person comment

Jean Richardson – National Organic Standards Board Chair 

The NOP and NOSB have been working collaboratively to find ways to increase opportunities 

for greater participation by a broader range of people over a longer period of time, and by more 

pathways! A couple of ideas we want to run as a trial this fall is to have ‘Oral Public Comment 

by Webinar’ and concentrating public comment on the first day of the NOSB while members are 

still fresh even if we have to run a couple of hours longer on that day. 

In April in La Jolla we blocked out time for 130 oral commenters, and 124 spoke. This took up 

almost 2 days (11 hours) of our 4 day meeting. The idea of the webinars is for those unable to 

travel to have an opportunity to voice their comments on the record within a five minute slot, two 

minutes more than the current allowance of 3 minutes in person. As you heard during our 

meeting presentations in April, the organic community already has a pretty good idea of where 

we are headed with our materials review so you can be writing your comment now and either 

send it in in writing when the public comment period opens, or sign up to make oral comment. 

We hope as many members of the organic community will use this electronic meeting to share 

their thoughts, but especially hope that this makes it easier for farmers to participate as we value 

their perspective on the practicality of NOSB decisions on organic production. The comments 

made in the webinars will be placed on the record, recorded and available for NOSB members to 

play back at their leisure if they are unable to listen to the full six hours. Individuals can choose 

to give oral comment on either the webinars or sign up for an in-person slot as part of the 6 hours 

of in-person comment time on October 26. 

As NOSB Chair I hope that you will use this opportunity to try out new ways of participation and 

give us feedback if it doesn’t work. While many FACA boards hold entirely virtual meetings and 

limit oral comment we realize the importance of involving the whole organic community in 

decisions about the future of organic and institutionalize public participation at all levels of NOP 

and NOSB.

My goal as Chair for the next 4 months is to continue to work to expand opportunities for a 

broader cross section of public comment in a diversity of ways, using modern technology where 

possible, reduce our carbon footprint where possible, and complete this cycle of Sunset Review. 

I believe that working together we can do this. 

Meanwhile, we keep on working to see if we can get a public docket in place so that the public 

can send in public comment all year round as well. Here's where we need patience!

We are also working to determine how to spread the Review of Sunset materials over more 

years, and not review essentially all of then in one large group every five years as we are right 

now. This should make the next few years much easier for us all.

NOSB members are working hard to make the in-person meeting as productive as possible. We 

have doubled up our subcommittee conference calls as needed to work on Sunset Materials in 
Crops, Handling and Livestock, to make sure that we have all our Sunset Templates ready for 

NOP staff on August 26, so they can meet their September 8 Federal Register Posting date. 

In terms of numbers to be voted on at the October meeting in Vermont: Livestock will be 

presenting 42 substances for Sunset 2017 Review; Crops 43; and Handling 105. There will be 

substances of interest to NODPA members in all of these subcommittees. Based on public 

comment submitted so far, it does not appear that any of the livestock materials will be 

recommended for removal from the List in October, with the exception of one or two 

parasiticides. There are 3 parasiticides to be voted on in October: Fenbenzadole, Ivermectin and 

Moxidectin. Ivermectin, and perhaps moxidectin may be removed. We hope to propose 

reduction in the withholding period of fenbenzadole, but keep it on the List. We hope to also be 

voting to reduce the withholding period for Lidocaine and Procaine. We have received public 

comment regarding the use of Nonylphenyl Ethoxylates (NPE’s) used in formulations of teat 

dips containing iodine. NPE’s act as surfactants in complexing iodine. NPE’s, even at very low 

levels, have a toxic effect on aquatic systems. Iodine (205.603(a) and (b)) comes up for Sunset 

Review and vote in October. We expect iodine will be kept on the list, but OMRI has recently 

prohibited the use of NPE’s’s in teat dips so we may not need to propose an annotation. So, we 

would appreciate your comments on all these materials plus any comments of priorities for 

organic research related to livestock.

We all hope to make this October meeting a time for celebrating 25 years of organic agriculture.

Thank you very much, and I look forward to hearing from you. 

Jean
From: Jean Richardson

To: Tracy Favre

Cc: Brown Rosen, Emily - AMS; Daniels Paula; Calvin Walker; Thicke Francis; Arsenault, Michelle - AMS; Stone Mac; 

Bondera Colehour; Swaffar Ashley; McEvoy, Miles - AMS; Brines, Lisa - AMS

Subject: Re: zinc sulfate

Date: Tuesday, April 28, 2015 12:36:03 PM

yes I agree jean

On Apr 28, 2015, at 12:33 PM, Tracy Favre wrote:

If we can change the annotation now, that’s my preference. 

On Apr 28, 2015, at 11:17 AM, Brown Rosen, Emily - AMS 

<Emily.BrownRosen@ams.usda.gov> wrote:

Let me talk to Miles a bit. It seems like the less restrictive annotation 

would allow for use in a less enviro impactful way (individual animals) not 

sure if this is substantive. Copper sulfate has no similar restriction.

Emily

From: Paula Daniels [mailto:pdaniels@goodfoodla.org]

Sent: Tuesday, April 28, 2015 9:15 AM

To: Tracy Favre

Cc: Walker Calvin; Thicke Francis; Arsenault, Michelle - AMS; Stone Mac; 

Richardson Jean; Bondera Colehour; Brown Rosen, Emily - AMS; Swaffar 

Ashley

Subject: Re: zinc sulfate

Fine by me

********

Sent from my iPhone

(tip-typing away)

On Apr 28, 2015, at 9:12 AM, Tracy Favre 

<tfavre@favrehouse.com> wrote:

Folks,

I think we may want to take this back to committee to 

amend the annotation. It seems to me we might be 

inadvertently forcing folks to use a foot bath when

applying topically could get the job done. How would 

you guys feel about taking it back? I’d like to consider 

offering a listing for 205.603(b) without annotation at all.

Thoughts?

T
Begin forwarded message:

From: "Brown Rosen, Emily - AMS" 

<Emily.BrownRosen@ams.usda.gov>

To: "Tracy Favre (tfavre@favrehouse.com)" 

<tfavre@favrehouse.com>

Subject: FW: zinc sulfate

Date: April 28, 2015 at 10:48:25 AM CDT

fyi

From: Mary Yurlina [mailto:yurlina@mofga.org]

Sent: Tuesday, April 28, 2015 6:37 AM

To: Diane Schivera; Katie Webb

Cc: Brown Rosen, Emily - AMS

Subject: Re: zinc sulfate

Yes, hello Emily. Katie Webb and I noticed that the 

petition text appeared delimited to foot-baths, which we

thought was too bad, since most of our producers would 

likely use it as a topical. Thanks for inquiring; we hope 

ZnSO4 is recommended. All the best, Mary

___________________________________________________

Mary Yurlina, Ph.D.

Director, MOFGA Certification Services LLC

Unity, Maine USA

p. 207-568-4142 f. 866-344-0991

www.mofgacertification.org

This message (attachments included) is intended for addressees only. Treat as 

confidential. Unauthorized use and forwarding is prohibited.

On Tue, Apr 28, 2015 at 8:37 AM, Diane Schivera 

<dianes@mofga.org> wrote:

Hi Emily,

Thanks so much for asking! This is such an important 

point! Enough emphasis? 

One product example is Dr. Naylor's hoof and heal. 

http://drnaylor.com/product/hoof-n-heel/

Works well for sheep and goats where they have the 

facility(milking stand) or ability to treat individuals.

Setting up a foot bath for the animals to walk through or 

have to stand and hold them is more difficult for the

farmers to do. I'm guessing there will be more products 

too if this goes through.

The Zn sulfate is also used directly packed in bandages 

hoof warts in cattle sheep and goats too.

Hope that helps. Call if you have other questions, 207-

701-8794. I want to do all I can to help this get allowed!
I'm glad you are hanging in working for the farmers.

go happy,

Diane

Diane Schivera 

Organic Livestock Specialist

Maine Organic Farmers and Gardeners Association, 

MOFGA

294 Crosby Brook Rd., PO Box 170 Unity, ME 04988

207-568-4142 FAX: 568-4141

dianes@mofga.org www.mofga.org

((_))

(oo)_______

(__) )\

 | |---------w| \~

 | | | |

Drink Organic Milk!!

On Apr 27, 2015, at 7:34 PM, Brown Rosen, Emily - 

AMS <Emily.BrownRosen@ams.usda.gov> wrote:

Hi Diane,

I am here at the NOSB meeting, and the 

NOSB is considering zinc sulfate, and a 

couple of commenters have talked about the 

type of product. In addition to foot baths, 

they suggest it should be allowed as a 

topical spray or ointment , which may be 

easier for small farmers that just have a few 

animals (goats or sheep). Have you heard of 

this type of use or seen products that are

geared to this use? Any labels on hand?

Thanks

Emily

Emily Brown Rosen

Specialist, Standards Division

USDA-AMS-NOP

www. ams.usda.gov/nop

609-737-8630 NJ office

NEW cell

(b) (6)

Sent: Wednesday, April 29, 2015 4:30 PM

To: Pattillo, Devon - AMS

Cc: Brines, Lisa - AMS

Subject: RE: Zinc sulfate

Very good catch , Devon, thanks. So this would be an unintended substantive change. 

What if we suggested they change annotation to 603 (b) zinc sulfate, for use in hoof or 

foot treatments – does that sound correct?

Emily

From: Pattillo, Devon - AMS

Sent: Wednesday, April 29, 2015 4:12 PM

To: Brown Rosen, Emily - AMS

Subject: RE: Zinc sulfate

One other thing to be aware of when considering a change to “topical” applications is 

that there are potentially teat dips that include zinc sulfate. I would assume that such 

use would be outside the petitioned use.

Devon Pattillo

Materials Specialist, Standards Division

National Organic Program

Agricultural Marketing Services

United States Department of Agriculture

Tel: (202) 720-3252

Direct: (202) 740-5061

Devon.Pattillo@ams.usda.gov

www.ams.usda.gov/nop

From: Pattillo, Devon - AMS

Sent: Wednesday, April 29, 2015 4:08 PM

To: Brown Rosen, Emily - AMS

Subject: RE: Zinc sulfate

Hi Emily,

I did not see any comments that advocated for limiting its use to foot baths. In fact, 

most comments are to the contrary and advocate for allowing use on hooves via 

alternate methods. These commenters want to ensure that the substance can be 

applied to hooves topically, on a case by case basis using wraps, treated pads, aerosols,

 etc.. These commenters argued that these application methods (products currently on 

the market) would limit environmental release of zinc compared to foot baths.

Devon Pattillo

Materials Specialist, Standards Division

National Organic Program
Agricultural Marketing Services

United States Department of Agriculture

Tel: (202) 720-3252

Direct: (202) 740-5061

Devon.Pattillo@ams.usda.gov

www.ams.usda.gov/nop

From: Brown Rosen, Emily - AMS

Sent: Wednesday, April 29, 2015 3:31 PM

To: Pattillo, Devon - AMS

Subject: RE: Zinc sulfate

Devon , did you notice any comments that were specifically in favor of limiting to foot 

baths? Or sounded like they might be against other uses? Were there any comments 

against it overall?

Thanks

Emily

From: Pattillo, Devon - AMS

Sent: Tuesday, April 28, 2015 9:26 AM

To: Brines, Lisa - AMS

Cc: Brown Rosen, Emily - AMS; Perry, Andrew - AMS

Subject: RE: Zinc sulfate

After reviewing public comments on zinc sulfate, it’s clear that about six commenters 

(predominantly producers) made comments requesting that its use not be limited to 

foot baths. Other treatment application methods mentioned were wraps, soaking pads,

 and aerosol products. All of the application methods still target hoof issues.

As far as FDA status and oversight, there are no zinc sulfate products (any type of 

application) approved as drugs by the FDA. An email from FDA to NOP in June 2014 

states:

Zinc sulfate products marketed as foot baths to treat or prevent foot rot in 

cattle are unapproved new animal drugs. At this time, we do not have an 

ongoing enforcement action against a hoof bath product containing zinc sulfate

 intended to treat or prevent foot rot in cattle...

In regards to CVM’s position on the petition regarding zinc sulfate as a hoof 

bath additive and its use in the National Organic Program, FDA does not 

evaluate the requirements or support the standards set by USDA in order for a 

product to be considered organic. We just state current FDA position regarding 

the product’s status.

Hope this is helpful.
Devon Pattillo

Materials Specialist, Standards Division

National Organic Program

Agricultural Marketing Services

United States Department of Agriculture

Tel: (202) 720-3252

Direct: (202) 740-5061

Devon.Pattillo@ams.usda.gov

www.ams.usda.gov/nop

From: Brines, Lisa - AMS

Sent: Monday, April 27, 2015 3:01 PM

To: Pattillo, Devon - AMS

Cc: Brown Rosen, Emily - AMS; Perry, Andrew - AMS

Subject: Zinc sulfate

Hi Devon,

There are some questions coming up in public comment about the Livestock proposal 

for zinc sulfate. Some comments are in support of expanding the use (the proposal 

states “for use as a footbath only”).

Can you see what you can find in the written comments about these other uses and 

whether they would be allowed under applicable federal regulations (FDA or APHIS, 

etc.)?

The NOSB is awaiting our feedback on whether this would be considered a substantive 

change to the proposal.

Thanks,

Lisa B.
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Zea"s request

Date: Wednesday, May 06, 2015 4:48:55 PM

Hi Miles

Zea has written a letter to Cornucopia, specifically NOSB members on Cornucopia Board, and wishes me to send

 her your personal e-mail so she can send you a copy.

Please advise

I have contacted both Barry Flamm and Francis about the letter attacking you. Heard a good response from Francis,

 - he was never consulted and strongly disagrees with letter. Silence from Barry so far.

I have a letter drafted to Cornucopia as well about attacks on you personally. I will run it by you before sending.

Jean

organic alternatives. Key congressional sponsors of the original organic legislation (Senator Patrick Leahy of Vermont and representative Peter DeFazio of Oregon)

have expressed their strong objection to the new policies as have several highly respected former chairs of the NOSB.

The USDA has also removed the ability of the NOSB to set their own work plan and agenda as well as effectively conducting their own meetings. The USDA now 

even claims the power to co-chair NOSB meetings. Additionally, the Ag Secretary has made legally questionable appointments stacking the NOSB with corporate 

agribusiness employees who do not meet the criteria established by Congress.

All of these crass and possibly illegal acts by the USDA have the potential to undermine consumer confidence in the certified organic label. Indeed, over the past two

 presidential administrations, the board has adopted a number of policies favorable towards powerful agribusiness interests and failed to address practices that

threaten organic integrity.

Previous research from The Cornucopia Institute has documented how powerful corporate interests, including the industry lobby group the Organic Trade Association

 (OTA), have been gaming the system for years with the help of a friendly USDA.

But in the past few years, farmers, consumers and groups like Cornucopia have stood up and begun challenging industry proposals pushing increased use of

gimmicky synthetics and suspect nutraceuticals in organic food. We have been successful in blocking a number of the industry-backed schemes. In fact, we 

have been so successful that corporate interests and their minions at the USDA have now decided they need to change the rules in the middle of the game.

The future of organic food and agriculture is at a crossroads. Consumers are increasingly hungry for healthy, nutrient-dense food produced in a sustainable manner 

and believe that the farmers growing the food should be able to earn a real living wage. Farmers and consumers must again stand together and forcefully request 

that President Obama step in and force the USDA to back off their power grab and return to the NOSB its rightful powers and authority.

Join with us and sign the petition to President Obama and USDA Secretary Vilsack. Help save the bright future of organic food and agriculture.

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the good food movement, and the media.

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Update Profile / Unsubscribe
From: Jean Richardson

To: Randall George

Cc: Nicole Dehne; McEvoy, Miles - AMS

Subject: White House Award

Date: Thursday, April 16, 2015 6:19:27 PM

Hi Randy

Saw you on TV getting an Award from President Obama for your Red Hen Bakery - VOF/USDA Organic Certified.

Your approach to caring for your employees was especially highlighted.

Red Hen demonstrates high values in so many ways

Well deserved. Well done.

Congratulations

Jean

Jean Richardson

Chair, National Organic Standards Board

Professor Emerita University of Vermont
From: Jean Richardson

To: McEvoy, Miles - AMS

Subject: Fwd: What does "certified organic" mean? Watch our video and find out!

Date: Friday, July 18, 2014 8:15:35 AM

Hi Miles

It is intended to be a "kitchen table" conversation

Just out and it had 100 hits on utube in a few hours! Hilarious!

Trying to make Regulations sort of interesting to the average person.

Note my dog William on my knee. People love dogs!

Cheers

Jean

Begin forwarded message:

From: NOFA Vermont <info@nofavt.org>

Date: July 16, 2014 1:43:36 PM EDT

To: 

Subject: What does "certified organic" mean? Watch our video and find 

out!

Reply-To: info@nofavt.org

Having trouble viewing this email? Click here for webpage version.

Dear Jean,

What DOES certified organic mean? Who determines that 

definition, and how is it enforced?

Get the answers to these questions and more in our 

exclusive interview with Jean Richardson, National Organic 

Standards Board member and organic inspector for VOF.

(b) (6)
What does 

What does "certified organic" mean?

Use the navigation menu at the beginning of the video to jump to the 

topic you're interested in - organic standards, international regulations, 

the three organic categories for processed products, the NOSB, 

enforcement, and more - or watch the full 30-minute interview for a 

comprehensive overview of what, exactly, organic certification means.

Subscribe to our YouTube channel to get the latest Policy Updates, 

Farmer Quick Tips, Farmers Talk interviews, and videos that feature our 

members and programs.

Best wishes,

Caitlin Gildrien

NOFA-VT Outreach Coordinator

PS - Spread the word! Like, share, and comment on the video, and ask 

your local public access TV station to play it, too. They'll find it on the 

Vermont Media Exchange by the name 

PolicyUpdateOrganicCertification.mpg. Thanks!

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(b) (6)
From: Jean Richardson

To: Tracy Favre; Harold Austin; Tom Chapman; Carmela Beck; CALVIN WALKER; Zea Sonnabend

Cc: Arsenault, Michelle - AMS; McEvoy, Miles - AMS; Tucker, Jennifer - AMS

Subject: Webinars for Public comment

Date: Tuesday, June 09, 2015 10:12:05 AM

Hi Everyone

I will not be on the Exec call on Friday but wanted be sure that the Webinars for public comment are getting

 organized.

We are looking at BOTH Tuesday September 22 and Tuesday September 29 from 1 pm -4 pm ET. Speakers allowed

 4 minutes. This will provide us with 6 hours of public comment and thus save us 6 hours at the October meeting.

In April we had 11.5 hours of public comment time.

In October I suggest we have 5 or 6 hours of public comment on the Monday so that the Tuesday through Thursday

 can be our NOSB work.

Michelle will need to get this into the Federal Register by end of June with a clear statement that speakers can do

 oral comment only once. And also that time allotted in October is for 3 minutes each, and that we will only be

 taking public comment on Monday for 5 hours (or 6 hours).

Let me know what you think

Thank you

Jean


be taking public comment on Monday for 5 hours (or 6 hours). > 

> Let me know

what you think

> Thank you

> Jean

> 

> 

>