Ms. Terri Joya
Agriculture and Food Research Initiative
Competitive Programs Unit
National Institute of Food and Agriculture
U.S. Department of Agriculture
1400 Independence Avenue
Washington, DC 20250-2240
VIA ELECTRONIC MAIL
June 7, 2010
RE: Docket Number NIFA-2010-0001, Solicitation of Input From Stakeholders Regarding the Agriculture and Food Research Initiative (AFRI)
Dear Ms. Joya,
The Organic Trade Association (OTA) thanks you for this opportunity to comment. OTA is the membership-based business association for organic agriculture and products in North America. Its members include growers, shippers, processors, certifiers, farmers' associations, distributors, importers, exporters, consultants, retailers and others. OTA’s Board of Directors is democratically elected by its members. OTA's mission is to promote and protect the growth of organic trade to benefit the environment, farmers, the public and the economy (www.ota.com).
OTA thanks NIFA for considering stakeholder input in developing the Fiscal Year 2011 solicitations for AFRI. OTA fully supports multidisciplinary and integrated research, and understands that of the AFRI funds allocated to research activities, section 7406 directs 60 percent toward grants for fundamental (or basic) research, and 40 percent toward applied research. Of the AFRI funds allocated to fundamental research, not less than 30 percent of AFRI grants will be directed toward research by multidisciplinary teams. In addition, the law specifies that of the total amount appropriated for AFRI, not less than 30 percent is to be used for integrated programs.
We urge USDA to orient research towards an agriculture of the future, based on planning and producing a host of ecosystem functions, including biodiversity, water quality and soil fertility. Such a system relies only minimally on external inputs, especially those from fossil fuels; is as internally regenerative as possible, maintaining and conserving natural resources, especially soil quality, the foundation of the sustainability of any agriculture; and is ecologically resilient in the face of fluctuating environmental stresses such as drought.
Agriculture should also be studied in the context of providing optimal nutrition for both the people of the United States and the world and of the sustainability of industrial uses of agricultural products. The primary purpose of agriculture is to ensure proper nutrition, and research in agroecological landscape planning can show how sound agricultural practices can help satisfy the nutritional needs of localities and regions while providing the environmental benefits of biodiversity and soil and water quality.
The 2008 Organic Production Survey of the National Agricultural Statistics Service showed that organic farms are more profitable than non-organic farms. Research should be broad enough to include consideration of such systems of inputs and marketing that lead to increased profitability. Such research could also evaluate the social benefits of avoiding negative economic externalities.
Research must study whole systems, from inputs to marketing to nutrition, in order to understand the complex interactions that comprise any specific production system. The study of whole systems requires more attention to on-farm research, which includes the practitioner as a partner in research design and implementation. Without taking into account the context within which agriculture exists, research may fail to address “real world” problems or may encounter limited acceptance by producers.
Following are OTA’s specific comments on the various categories of grants in AFRI. Many of these areas have shown promising results in preliminary research, and would benefit from larger trials or comprehensive replications.
(A) Plant health and production and plant products
OTA encourages further research into soil ecology as the basis for plant health in agroecosystems. Preliminary research shows that ecologically balanced soils with diverse micro- and macro-fauna produce plants with higher natural immunity to pests and diseases. Other plant systems, including perennial and agroforestry production, should also be studied in more detail regarding the systemic effects of ecologically healthy soils. Research is particularly needed into conventional (non-GMO) plant breeding for pest/disease resistance, storage quality, nutritional quality, and regional adaptation.
(B) Animal health and production and animal products
OTA supports a focus on evaluation of the role of pasture in ruminant health, and the role of cage-free production in poultry health, especially with reference to prevalence of pathogenic organisms in livestock and poultry products and manure.
Research should also be directed at nontraditional, i.e., herbal, homeopathic, and other alternative therapies, for livestock veterinary care. Feeding studies that compare the health and productivity of livestock under organic management with comparable breeds that are managed conventionally would also be very useful.
(C) Food safety, nutrition, and health
OTA would be interested in seeing research into the potential for more regionalized food production of basic commodities as a strategy for ensuring food security within the U.S. and worldwide. We also suggest research to evaluate the “nutrient density” or phytonutrient (vitamins, minerals, fats) content of organically produced versus conventional plant products of the same variety. In addition to analysis of individual nutrient content this should entail animal feeding trials as well as evaluation of taste, brix, and other qualitative factors. Another valuable area for additional research would investigate the use of biological agents and probiotics to enhance food safety pre- and post-harvest
(D) Renewable energy, natural resources, and environment
Research is needed on the environmental effects of organic production systems and their contribution to maintaining and improving soil and water quality. Benefits of organic systems for mitigating climate change and reducing greenhouse gas emissions should receive priority for investigation. Studies should be done to evaluate organic production systems’ consumption of fossil fuel, emissions of greenhouse gases other than CO2, and carbon sequestration in soil organic matter in comparison to overall productivity.
(E) Agriculture systems and technology
Organic production and handling are both treated as process-based systems by the USDA-NOP regulations, which address all aspects of the production chain from farm inputs to final package labeling. Technologies that affect any link in this chain have impacts on all others. OTA encourages research to develop and assess new technologies for compatibility with organic principles, including refinements and improvements to currently used technologies such as biological control agents for pests, weeds, diseases,
minimum tillage systems that do not require use of herbicides, farm-produced energy sources, and farm-scale composting systems.
(F) Agriculture economics and rural communities
Organic production and handling, as is true of conventional agriculture, is global, with many products being traded across borders. Organic products are currently imported in substantial quantity, while we believe somewhat lesser amounts are exported - efforts are underway to quantify international organic trade. We strongly support research into economic barriers (as well as incentives) to entry into or expansion of organic production in the U.S. As previously noted, recent surveys indicate that organic farms are more profitable than their conventional counterparts. We would encourage studies of the multiplier effect of organic production systems for rural communities, such as increased employment opportunities, as well as social benefits such as improved quality of life, incentives for new entry farmers, and intergenerational transfer benefits. Other fruitful areas of research would be the potential for community organic waste recycling via on-farm composting systems and the potential value-added and market opportunities for rotation crops.