March 9, 2006
The Honorable Mike Johanns
U.S. Department of Agriculture
Jamie Whitten Building – Suite 200A
1400 Jefferson Place SW
Washington, DC 20250
Dear Mr. Secretary:
We, here at the Organic Trade Association, have read with interest the recent report, “Impact of Harvey v. Johanns and Restoring the NOP to pre-Lawsuit Status: A Report to Congress – March 2006.” Its thorough articulation of the factors at work in the lawsuit, as well as the accomplishments of Congress in restoring many aspects of the organic standards are very helpful to the public understanding of this complex issue.
We certainly agree with your view, as expressed in the Report, that “Congress continued to ensure that any changes to the National Organic Program (NOP) regulations would be done by engaging in notice and comment rulemaking. This ensures that the organic standards will not be weakened, and the organic community’s concerns will be addressed.” We have always understood these transparent and orderly procedures would be followed by you and the Agricultural Marketing Service (AMS), but it is important that they are highlighted again by USDA in the Report.
I speak for the members of the Organic Trade Association in expressing our appreciation for USDA’s attention to the needs of the organic community, and know that these efforts can help us continue to build growth both domestically and globally.
Cc: Deputy Secretary Chuck Conner
Dale Moore, Chief of Staff
Beth Johnson, Deputy Chief of Staff
Dr. Chuck Lambert, Deputy Under Secretary for Marketing and Regulatory Programs
Lloyd Day, Administrator, Agricultural Marketing Service Barbara Robinson, Associate Deputy Administrator, Agricultural Marketing Service