Segregate Data for Organic Almonds: Comments of the Organic Trade Association on AMSís Notice of Request for Extension and Revision of a Currently Approved Information Collection
Docket No. FV02-981-1 NC
Submitted by Tom Hutcheson,
Associate Policy Director
January 22, 2002
On May 29, 2001, OTA commented to AMS (Docket No. FV01-989-2 PR) regarding information collection on organic raisins. The comment was in support of requiring handlers to report to the Raisin Administrative Committee (RAC) information on acquisitions, shipments, and inventories of organic raisins.
OTA would like to take this opportunity to encourage AMS to require handlers and growers to report to the Almond Board of California information on acquisitions, shipments, and inventories of organic almonds.
Organic almonds have a substantially different market compared to conventionally grown almonds. They are produced differently and their pricing in the marketplace reflects the value consumers put on those production methods.
This means that demand for organic almonds can be rising at the same time demand for conventionally grown almonds is falling. Any limitations on the production of organic almonds, including set-asides, based on the demand for conventional almonds, is therefore unreasonable, and any information which can be collected towards the end of demonstrating the particulars of this situation are most welcome.
Collecting this information is of course only the first step in differentiating these two kinds of almonds in relation to the Federal marketing order for California almonds. When the information collected shows that there are indeed differences in pricing and volume, as OTA expects, the Federal marketing order should be revised to take this information into account. Two options are 1) to exempt organic almonds from the Federal marketing order and 2) to establish a marketing order solely for organic almonds, which OTA trusts would only be done with the full consent of the producers involved.
OTA believes that the small reporting burden placed on handlers of organic almonds will be more than worthwhile in the long run, as the information collected will allow USDA to demonstrate that organically-grown almonds have a substantially different market from conventionally-grown almonds. This in turn will allow handlers of organic almonds more flexibility in bringing their product to market.
In the prior case of organic raisins, OTA greatly appreciates the flexibility demonstrated by AMS in proposing that they be separated through the mechanism of declaring them a separate varietal type, but proposed a further policy change which would allow organic commodities to be recognized by their production standard (in this case, organic production as defined by 7 CFR 205). OTA would like AMS to review its programs thoroughly so that organic production can be incorporated into these and similar programs as a separate, new, and well-defined production method.