The organic checkoff debate – Are you at the table or on the menu?
My brief Mexican vacation has come to an end, and watching from a distance the disaster of what has become of US national politics I felt more than a little anxious about going back. But really, there is no place to escape it--certainly not the beaches of Puerto Escondido.
There was plenty of activity worthy of comment from the organic front in my absence. One issue that seems to generate the most outrage in the grassroots world is the Generic Research and Promotion Order for Organic, known as GRO Organic. This is a proposal made by the Organic Trade Association (OTA) to establish an organic check-off program, similar to the generic marketing and promotion programs for dairy, beef, and eggs, but one that would cover the whole gamut of organically produced agricultural goods. A few years in development, it was one of several organic-related regulatory actions taken by USDA in the final moments of the Obama administration, including the long-awaited final rule on animal welfare. Any of which could be undone by an agency run by Sonny Perdue, carrying out the policies of a President whose name I cannot utter.
Last spring during my visit to Washington, DC for the Organic Confluences Summit I attended an open meeting for OTA members, at which a primary agenda item was to drum up support and enthusiasm for the GRO Organic proposal. After reading the literature and listening to the spiel, I decided that it sounded reasonable to me, and added my name to the list of those supporting it--making a mental note to investigate the details before getting too excited about it. Since then I have heard from several well-respected organic farmers who are really not happy about this proposal.
What do the critics say?
Now that the GRO Organic program is one step closer to implementation it seemed important to take a closer look. Most arguments against the proposal I have read boil down to three basic concerns:
1. USDA is not to be trusted. The history and track record for other commodity check-off programs has been abyssmal for small-scale and organic farmers. This one can’t be any different.
2. OTA is not to be trusted. They are only looking to line the pockets of the big corporate orgo-biz players, who will call all the shots. They will also benefit from increased market demand, which will be met primarily with cheaper organic imports from places like China and Turkey where organic integrity is questionable. This will drive down domestic organic farm prices, and make it harder for interested conventional farmers to embark on a financially risky organic transition.
3. Smaller organic producers will have little or no say in how this program is administered or how the projected $30 million budget will be spent. Farmers will be forced to either contribute or go through extensive bureaucratic hoops to opt out, but will derive little if any benefit. Too little of the budget will be allocated to research that helps organic farmers.
Frequent messages from more industry-friendly sources fill my inbox to urge support for the proposal. Arguments on both sides are lengthy and detailed. Some of the complaints are serious ones that should raise concerns.
But I am not swayed by arguments that amount to lack of trust in either USDA or OTA, which basically assert that these people are all nasty bureaucrats or a greedy corporate bunch who are up to no good, no matter what they do or say. Nor am I convinced by arguments based on previous bad experience with conventional commodity checkoff programs. This one is clearly different.
The GRO Organic FAQ site runs down the list of how this checkoff is different from all other checkoffs, declaring that “it is unlike any other check-off that has preceded it.” It does appear to offer provisions that would sweeten the deal for those complaining about lack of farmer representation—the 17 member Board is now 50-50 farmers and handlers, with one “at large” member appointed by the Secretary of Agriculture. There is a process for producers to elect their Board members based on a regional representation scheme. Research and inventions developed will remain in the public domain, and administrative costs will be capped. And all members get to vote after seven years on whether they want the program to continue—if they don’t like it they can decide to end it.
The program can also be amended by a referendum of participants. One particular issue that stands out for me as problematic is the way “net organic sales” is calculated for farmers. While the cost of purchased inputs such as feed, seed and fertilizer can be deducted from gross sales, there is no deduction for the hired labor needed to produce and handle the farm-generated inputs that are the hallmark of the best organic operations. It may be possible to partially address this by placing a value on the farm produced feed, seed, and compost inputs that gets counted as a cost of production—a finer detail that must be worked out.
No doubt there are many more complexities and devilish details that could make GRO-Organic unable to deliver on every promise. How burdensome will it be for farmers to document their net organic sales every year, and what counts as a cost of producing the products they sell? Will manufacturers and handlers who will pay the lion’s share of the 0.1% assessment on net organic sales simply pass their costs along to farmers in the form of lower contract prices? Will the promised 25% of producer assessments used to fund research amount to more than a hill of beans? How much will program administration actually end up costing? Some of these answers cannot be known until we try it, and under the new federal regime the economic projections could easily be blown out of the water.
The regulatory sausage factory
The regulatory proposal that is now open for public comment (until March 20th) is not the substance of the GRO Organic plan itself, but a process for holding a referendum by eligible participants. Any public comment should primarily address the method of voting outlined in the proposal, rather than the merits of the program itself. Any “interested member of the public” can submit comments, but only “eligible participants” can vote in the referendum. The referendum will take place once this process has been finalized, and will determine whether or not the program will be established.
An “eligible participant” is any entity that holds a valid organic certificate. Although OTA had proposed that voting be based on the number of certificate holders, USDA amended this to stipulate that only one vote could be allocated to any one entity as represented by a distinct tax ID number, no matter how many different subdivisions hold their own certificates. Small producers and handlers – ones making less than $250,000 in organic sales per year— would not be required to participate, but could opt in voluntarily. In order to vote in the referendum you must agree to status of “assessed entity,” whether mandatory or voluntary. If you are opposed to the program entirely you are stuck if the referendum passes. But after seven years of paying in you can vote to terminate it.
What this all means is that those opposed to the proposal entirely now have the opportunity to scuttle it, if their claim of representing the majority of organic producers is accurate. It is a gamble for those who would have to voluntarily opt in. If they lose, they will have to pay up, at least for one year. At 0.1 percent of net organic sales, even a farm with gross organic sales close to $250,000 will not pay a significant amount.
As I see it, many of those who complain the loudest also have a long history of shunning OTA and attacking “industrial organic” production methods. They long ago decided that big corporate entities and/or USDA (and the people who work for them) can’t possibly care about organic principles and are only in it for the money. As long as you believe that anyone working within “the system” is not to be trusted, you will only get what you expect. Attacking potential allies is a sure route to defeat.
Less than 1% of US farmland is organically managed today, and everyone involved expresses some desire to see that increase. Given a new administration that is explicitly hostile to such a goal, what other strategies will allow us to expand organic acreage quickly enough to begin mitigating and finally reversing climate chaos? The urgency of unity within the diverse constituencies of the food movement - including the "industrial organic" end of the spectrum - has never been greater. Lets keep working on solidarity and finding common ground rather than attacking the good for failing to be perfect.
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