Proposed rider amendment to the Organic Food Production Act

This letter was sent to Washington's two U.S. senators, Maria Cantwell and Patty Murray, and to Senator Patrick Leahy, who has provided leadership on organic standards.

September 20, 2005

Re: "Organic Rider" in budget, as proposed and supported by the Organic Trade Association, suggesting language to clarify the Organic Foods Production Act of 1990

Dear __________,

It appears to us at PCC Natural Markets that the intent of the "organic rider" proposed and supported by the Organic Trade Association is reasonably based and that the specific proposed changes appear to be wholly consistent with the continuation of strong national organic standards. As the largest consumer-owned natural foods retailer in the United States, with 37,000 household members and $89 million in sales 2004, we do not oppose this rider.

Generally speaking, however, we do not like rider amendments. Frequently they are stealth maneuvers made to affect legislation that might not stand if scrutinized fairly and objectively. Rider amendments are tainted because they are undemocratic in their manner.

We have arrived at our decision to not oppose the OTA supported amendment, after consideration of the specific language and their stated rationale (published on the website of the National Organic Cooperative Association [NCGA], www.ncga.coop). PCC is a member of both the NCGA and the OTA. However, we have not been involved with the OTA in their months of work on the proposed amendment, nor have we been in direct contact with them regarding this rider proposal.

We also do not share the perspectives on this matter with the NCGA, which is on record as opposed to the OTA's proposed changes. NCGA is not alone in its perspectives; it is joined by others including the Consumers Union and Organic Consumers Association. The OCA has, in our opinion, inaccurately and somewhat hysterically represented the goals and aims of OTA's proposal, as well as the impact the proposed amendment to the Organic Food Production Act would have on organic standards (see www.organicconsumers.org).

Many citizens (perhaps understandably) have a mistrust of USDA and other large regulatory agencies. They also loathe the use of rider amendments, which we understand, and have a sense that any organization using this means of rule-making is not to be trusted. There also is an increasingly underlying suspicion among organic consumers that "big organic" is somehow trying to "weaken" the standards in general, and especially by this rider proposal. We know that you and others are being lobbied heavily by many well-meaning citizens to vote against the OTA proposed rider.

A member of our staff serves as a consumer representative on the National Organic Standards Board. Although she cannot comment officially on this issue, she has assisted us in helping us understand the background of the Harvey lawsuit. She has shared the perspectives of organic manufacturers and other producers and handlers, as well as consumer concerns and their trust of the organic standards and the organic labels.

This is an emotional and divisive issue within the organic community. We know this is a difficult decision and trust will need to be re-built regarding organic standards — however the issue is resolved.

We trust your judgment. You are solidly in support of the organic and sustainable agricultural community — as we have seen with your great support of organic and sustainable farming research in this State. We want you to know that we do not object to this proposed rider and do not see anything in it that would weaken organic standards.

Sincerely,

Tracy Wolpert
Chief Executive Officer

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