The Honorable Thomas Vilsack, Secretary
United States Department of Agriculture (USDA)
1400 Independence Avenue SW
Washington, DC 20250
March 4, 2014
Re: Docket No. APHIS-2013-0047
Dear Secretary Vilsack:
The Pennsylvania Association for Sustainable Agriculture (PASA) is one of our nation’s largest member-based, sustainable farming organizations, with about 6,000 mostly farmer members located primarily throughout Pennsylvania and across the Mid-Atlantic region. Our mission is to promote profitable farms that produce healthy food for all people while respecting the natural environment. In keeping with this mission, we wish to express our grave concerns regarding the issue of “Enhancing Coexistence” as framed by the Report of the AC21 Committee in 2012. Continue reading
Every year I try to use my chance to speak at our annual conference to raise some of the most important issues facing us in the sustainable farming community. And with each succeeding year the urgency of these issues seems to increase. This is partly because some of the negative situations we face are actually getting worse, and partly because the positive solutions our movement offers are increasingly met with resistance and denial by those who represent the status quo.
Let’s back up just a bit and review some of the challenges we have encountered over the past year. First and foremost, 2013 will always in my mind be the year of proposed rules coming from the Food and Drug Administration (FDA) aimed at implementing the Food Safety Modernization Act (FSMA). What a long slog it was! At conference time last year we were still reviewing about 1,200 pages of material – with hundreds more to come – and were just starting to think about some of the implications involved should the proposed rules go into effect.
At the beginning, we were very much outnumbered and outspent in terms of being able to influence the final outcome, but what we had going for us was beyond the ability of any other group to purchase with mere dollars. We had a devoted coalition of dozens of groups from across the country working feverishly together, with meetings every week throughout most of the year, and many of us in smaller groups attending FDA listening sessions held across the country. We also found some new partnerships that we hadn’t really expected, including with faculty and students at the Law Schools of Harvard, Georgetown and Emory Universities, the leadership of the United Fresh Produce Association – a powerful group that had fought us hard in the legislative phase of FSMA, and even the National Association of State Departments of Agriculture (NASDA). At one point NASDA even shared a post I had written on my Write to Farm blog with the Departments of Agriculture in all fifty states. Continue reading
The past year has been an extraordinary one in the world of sustainable agriculture for many reasons, some of which may not be fully understood for many years to come. That year (November ’12 thru November ’13) included much attention across the country to labeling of genetically engineered foods, including two high-profile public referendums that went down to defeat in California and the state of Washington. For many, this effort, occurring state-by-state, has become the holy grail of the effort to promote local, sustainable and organic food and farming systems for the future.
But for me and many of my closest colleagues across the country, the past year has been about something much less glamorous, i.e. the drive to understand, explain and then fix the problems in proposed regulations associated with the federal Food Safety Modernization Act (FSMA). This was certainly a long slog by any measure, with dozens of folks working together to generate hundreds of pages of public commentary in response to thousands of pages of material we were given to digest last January. It was an extraordinary experience that I wouldn’t want to repeat, but the sort of work that had to be done at a critical moment in our sustainable food system movement. Continue reading