Materials Working Group
First, I would like to commend to you the work of the Materials Working Group, with which I served, and which is posted as a discussion document regarding the definition of the term “agricultural.” This group dove deep into the issues and has developed a document that can serve well as a foundation for discussing the myriad or issues involved.
Multi-site operation certification issues
I believe you received OTA’s comments on the certification of multi-site operations in your meeting book. These, and some replies to the questions you asked at the end of the current discussion document, will be discussed at length by Grace Gershuny and perhaps Kim Dietz, Co-chairs of OTA’s task force.
Aquaculture issues
Regarding the proposed aquaculture standard, NOSB has taken the first step toward a useful standard by recommending that new sections of the rule be created for aquaculture, in the so-far reserved 205.250 series. However, thinking from terretrial ecological management systems still infuses NOSB thought, and I urge you to acknowledge and celebrate the differences in aquatic ecological management that can make the upcoming recommendation both more useful in growing the organic system and more practical for those wishing to participate. In other words, the terrestrial provisions should not necessarily apply to aquaculture unless they make sense specifically for aquaculture. Therefore, NOSB should recommend, and NOP should implement, re-naming the current rule sections referring to livestock (205.236 to 205.239) to refer to "terrestrial livestock" to help clarify the situation.
Farmed Aquatic Plants
OTA members have indicated support for the NOSB recommendation, and we applaud NOSB for their substantial attention to this field.
Seed Commercial Availability Guidance
Finally, the Joint Committee has made its desires clear, and has laid out a number of practices that could help stimulate the growth of the organic seed trade. The major obstacle to growth cited in the paper, though, was the quality of organic seed, which seems to be left unaddressed. The Joint Committee seems to be proposing a substantial increase in the amount of paperwork required of farmers and certifiers without necessarily getting at the main cause of the problem. These steps might be helpful to some degree, but the recommendation does not give much hope that the problem will be much closer to being solved, even with the substantially ncreased reporting requirements proposed.
OTA generally supports the direction of the carefully crafted and well-thought-out recommendations of the Organic Seed Growers and Trade Association (OSGATA).
