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Organic Promotion, Research and Information Order

Room 3071-S, STOP 0201

Agricultural Marketing Service, USDA

1400 Independence Avenue SW

Washington, D. C. 20250-0201

amsadministratoroffice@ams.usda.gov

July 20, 2015

Hello,

Please consider this partial proposal on the proposed new organic industry-funded promotion, research, 

and information order, which would be developed under the Commodity Promotion, Research and 

Information Act of 1996.

This proposal is submitted on behalf of the Midwest Organic and Sustainable Education Service (MOSES). As 

a 501(c)3 educational non-profit with a mission “MOSES educates, inspires, and empowers farmers to thrive 

in a sustainable, organic system of agriculture,” we are committed to helping in whatever way we can to 

increase the number of organic farms, acres, farmers and products in our region of the upper Midwest and 

across the United States. 

MOSES organizes the largest organic farming conference in North America, at the end of February in La 

Crosse WI each year, with over 3500 attendees in 2015. Our monthly enews is sent out to over 11.000 email 

addresses each month, and our year round educational activities include the organic info phone line, ask the 

specialist form on our website, field days, workshops, fact sheets and our Organic Broadcaster bi monthly 

newspaper. These interactions with organic producers of all types keeps us informed on the needs and 

desires of the organic community.

After reading the proposal submitted by the Organic Trade Association, we feel it is imperative that two 

items be modified to better represent the will of those who are National Organic Program certified organic 

operations.

We believe the definition of organic research must be modified to detail aspects of agricultural production 

not covered in the original proposal. While there are challenges in all aspects of production and marketing, 

the largest challenges are based in understanding natural systems and mimicking them to produce food 

and fiber on the farm without the use of NOP prohibited materials or practices. Consumers depend on 

organics to lead the way in this type of agricultural production, and sadly, we have many knowledge gaps in 

organic agricultural production. There is much innovation on organic farms, but the amount of peer 

reviewed research, so important in developing systems, seeds and livestock breeds that thrive in an organic 

system of agriculture, is not anywhere sufficient enough to provide the tools necessary to increase our 

domestic organic agricultural production. 
Our proposed definition for §12XX.27 Research is as follows: 

§12XX.27 Research. 

Research means any type of investigation, study, evaluation, or analysis (including 

related education, extension, and outreach activities) designed to improve organic farm 

production systems and practices, increase farm profitability and productivity, expand 

organic farming opportunities, and enhance quality of life for farm families and their 

communities; enhance plant and animal breeding and varietal development for organic 

systems and improve the availability of other production inputs; optimize natural 

resource conservation, biodiversity, and environmental outcomes of organic 

agriculture; identify and explore solutions to economic, marketing, trade, and policy 

constraints on the expansion of organic agriculture; advance organic farm and food 

safety objectives; enhance or increase the consumption, image, desirability, use, 

marketability, or production of organic products; or to do studies on nutrition, market 

data, processing, environmental and human health benefits, quality of organic 

products, including research directed to organic product characteristics and product 

development, including new uses of existing organic products, new organic products or 

improved technology in the production, processing and packaging of organic products. 

In addition, we request that the percentage of dollars allocated to all research and specifically 

for organic agricultural research be modified as illustrated in bold below. 

§12XX.50 Budget and expenses. 

(a) At least 60 calendar days prior to the beginning of each fiscal year, and as may be 

necessary thereafter, the Board shall prepare and submit to the Department a budget for the 

fiscal year covering its anticipated expenses and disbursements in administering this part. The 

budget for research, promotion or information may not be implemented prior to approval by 

the Secretary. Each such budget shall include: 

(1) A statement of objectives and strategy for each program, plan or project; 

(2) A summary of anticipated revenue, with comparative data for at least one preceding fiscal 

year, which shall not include the initial budget; 

(3) A summary of proposed expenditures for each program, plan or project. This shall include 

the following allocation of expenditures: 

(i) The funds shall be allocated as follows: 65 percent for research, 20 percent for 

information, 10 percent for promotion, and 5 percent for discretionary funds; and 

(ii) Of the funds allocated to research, no less than half shall be allocated to produceroriented research. This research should take into account regional differences and 

priorities for producer-oriented research. Funds should be allocated equitably to reflect 

regional producer research needs. 

(iii) Any expenditures designated for the categories set forth in (i) and (ii) of this section that 

are not spent in a fiscal year shall carry over for the same category for the following fiscal year.

Second, the organic community is known for its passion and its participation in the 

development of the organic law and the subsequent regulations. This new organic research 

and promotional board must also be transparent in its dealings. There is no provision for this 
transparency in the original proposal, and we strongly recommend that this wording, or other 

wording that accomplishes the same goal, be added to any proposal that would be voted 

upon by the organic stakeholders. Transparency is a way of protecting fairness and ensuring 

the common good. The stakeholders must be able to understand how decisions are made 

and have a chance to ensure that decisions treat everyone equally and to hold the board 

members representing their interests accountable. Inadequate public access to information 

allows corruption to flourish, and back-room deals to determine spending in the interests of 

the few rather than many. As proposed, there will be many organic certificate holders that 

would not be assessed, unless they choose to do so voluntarily. However, the work and 

dissemination of funds of this Board will affect their livelihoods and they must have access to 

the Board transcripts in order to understand the rationale behind the Board’s actions.

Our recommendation is as follows:

§12XX.44 Procedures

(f) All meetings shall be publically noticed with the date, time and location no later than 

60 days prior to the meeting on the National Organic Program website and/or the 

official website designated by the Board. Assessed participants in the program shall be 

allowed to attend these Board meetings and an allowance for their presence should be 

provided when choosing the location.

(g) Complete written transcripts of the Board’s meetings shall be available to all organic 

certificate holders on the National Organic Program website and/or the official website 

designated by the Board.

Thank you for your serious consideration of these necessary improvements to the Organic 

Trade Association’s original Organic Research and Promotion proposal.

Sincerely,

Harriet Behar

MOSES Senior Organic Specialist