Policy Letters

To ensure the integrity of organic farming and build an equitable food system, we often submit letters to policy makers and institutions.

Below is an open record of letters that reflect NOFA-NY's position on a range of issues, from labeling, to genetically modified organisms, to just food systems. 


To see NOFA-NY Policy Resolutions, please click here.

To see Action Alerts, please click here.

Letter in Support of the Food and Agribusiness Merger Moratorium and Antitrust Review Act of 2018 (November 1, 2018) 

 

In a letter to the United States Senate and House of Representatives, 213 farm, food, rural, community, consumer, faith and other advocacy organizations endorsed the Food and Agribusiness Merger Moratorium and Antitrust Review Act of 2018 (Sen. Booker S. 3404/Rep. Pocan H.R. 6800). This legislation would offer a much needed strategic pause in food and agribusiness merger-mania in order to assess the impact corporate consolidation has on farmers, workers, consumers and communities and recommend improvements to antitrust enforcement.

Read the full letter here.

 

Press Release from ETC Group Opposing New Genetic Forcing Technology (October 16, 2018) 

 
More than 200 global food movement leaders and organizations (including NOFA-NY) representing hundreds of millions of farmers and food workers  set out their clear opposition to “gene drives” – a controversial new genetic forcing technology. Their call for a stop to this technology accompanies a new report, Forcing the Farm, that lifts the lid on how gene drives may harm food and farming systems.
 
Read the full release here
 

Letter to Governor Cuomo, New York State Senate and Assembly Leaders on Protecting Pollinator Populations (October 5, 2018) 

 
Given the magnitude of the current crisis faced by pollinators, we believe New York State must act quickly to: (1) prohibit unnecessary uses of harmful systemic insecticides, such as neonicotinoids (neonics); and (2) take comprehensive regulatory action to address other pollinator-toxic pesticide uses, including the use of neonic-treated seeds.
 
Recent collapses of pollinator populations, both here and around the world, have particular significance for New Yorkers and the state’s environment. Pollinators are important or essential to more than $360M of state agricultural products each year—including apples, squash, blueberries, and peaches—and provide benefits to hundreds of millions more. Overall, the state estimates these pollination-dependent crops contribute $1.2 billion annually to the local agricultural economy. Yet in the 2017-2018 season, New York beekeepers lost over 40% of their bee colonies, and the loss rate has hovered at or above that number for the past five years. These losses not only impose costs on farmers and beekeepers, but also suggest the potential for similar catastrophic losses for the state’s 450 pollinating species, critical to the survival of native plants and wildflowers.
 
Read the full letter here

 

 

NOFA-NY's Testimony to Regulated Marijuana Workgroup Listening Session (October 1, 2018) 

 

Testimony to Regulated Marijuana Workgroup Listening Session
October 1, 2018
Newburgh, New York

Founded in 1983, the Northeast Organic Farming Association – New York (NOFA-NY) is the premier statewide organization growing a strong organic and sustainable agriculture movement in New York State. NOFA-NY provides education and assistance to local organic and sustainable farmers; connects consumers with organic and sustainable farmers; advocates policies that support a sustainable food and farm system at both the state and federal levels; and we are the largest USDA-accredited organic certifier in New York certifying over 1,000 organic operations
in the state.

NOFA-NY’s interest in testifying before the Marijuana Workgroup Listening Session is on behalf of a fair system that allows New York’s family farms to participate in this new opportunity of marijuana production and prevents total takeover of marijuana agricultural production by large, industrial, vertically-integrated corporations. New York regulators are uniquely posed to preserve this opportunity for our family farmers.

In January 2018, NOFA-NY members passed the following resolution outlining these points:

Share Cannabis Production among Family Farmers
NOFA-NY Policy Resolution, January 2018

Whereas, following the example of states like Colorado and California, it seems likely that NYS will legalize the production of medicinal and recreational cannabis;

And whereas, cannabis is a highly profitable crop to grow organically, and a small acreage can assure the economic viability of a farm if legislation can be passed that prevents consolidation of control of this industry in just a few hands;

And whereas, the State of Massachusetts has passed legislation that provides New York with a good model for regulating the market and allowing the lucrative market for this crop to be shared among many smaller farms. MA Bill 3818 provides for a schedule of cultivator license fees commensurate with cultivation size and regulations, to create a craft marijuana cultivator cooperative system, including:

(1) A limitation on ownership of interests in a marijuana cultivator cooperative;

(2) A limit on the total marijuana produced by a craft marijuana cultivator by the number of plants, surface area used for cultivation, or output by weight; and

(3) A reasonable fee for licensure as a craft marijuana cultivator cooperative.

RESOLUTION: The members of NOFA-NY resolve that the Department of Agriculture and Markets should promote and encourage full participation in the regulated marijuana industry by self-employed farmers and businesses of all sizes.

 
 

NOFA-NY's Comments in support of petition "18-05" to change the Food Safety and Inspection Services Standards and Labeling Policy Book on “Product of U.S.A.” label (August 17, 2018) 

 

 June 17, 2018

U.S. Department of Agriculture
Food Safety and Inspection Service
1400 Independence Avenue, SW Washington, D.C. 20250-3700

Attention: Ms. Mary Porretta, Petitions Manager Office of Policy and Program Development Petition “18-05”

USDA/FSIS:

The Northeast Organic Farming Association – New York submits the following comments to support the petition “18-05” to change the Food Safety Inspection Service (FSIS) policy towards the use of the “Product of U.S.A.” label for meat and meat products, which has been submitted by the Organization for Competitive Markets (OCM) and American Grassfed Association (AGA) to the FSIS.

Founded in 1983, the Northeast Organic Farming Association – New York (NOFA-NY) is the premier statewide organization growing a strong organic and sustainable agriculture movement in New York State and is part of a regional network of seven Northeast Organic Farming Associations. NOFA-NY provides education and assistance to local organic and sustainable farmers; connects consumers with organic and sustainable farmers; advocates policies that support a sustainable food and farm system at both the state and federal levels; and is the largest USDA-accredited organic certifier in New York certifying over 1,000 organic operations in the state.

Read the full letter here.

 

NOFA-NY's Comments on proposed regulations to implement the National Bioengineered Food Disclosure Standard (June 29, 2018) 

 

 June 29, 2018


U.S. Department of Agriculture
Agricultural Marketing Service
1400 Independence Avenue SW
Washington, DC 20250


Docket No.: AMS-TM-17-0050

Re: Comments on proposed regulations to implement the National Bioengineered Food Disclosure Standard

 

Dear Secretary Perdue,

Founded in 1983, the Northeast Organic Farming Association – New York (NOFA-NY) is the premier statewide organization growing a strong organic and sustainable agriculture movement in New York State. NOFA-NY provides education and assistance to local organic and sustainable farmers; connects consumers with organic and sustainable farmers; advocates policies that support a sustainable food and farm system at both the state and federal levels; and, we are the largest USDA-accredited organic certifier in New York, certifying over 1,000 organic operations in the state.

NOFA-NY submits the following comments on the USDA’s proposed regulations to implement the National Bioengineered Food Disclosure Standard.
Throughout its 35-year history, NOFA-NY has always believed in transparency and disclosure in the food supply. NOFA-NY’s membership has passed a number of policy resolutions clarifying our position on GMOs. In 1999, our members passed a Comprehensive Food Labeling resolution that stated that all foods sold in the United States should label any ingredients derived from genetically-engineered organisms.

Read the full letter here.

 

NOFA-NY's Memo of Support for the the NYS Net Metering Bill (May 24, 2018) 

The Northeast Organic Farming Association of New York strongly supports the passage of the VDER Moratorium bill A.10474/S.8273

Founded in 1983, the Northeast Organic Farming Association – New York (NOFA-NY) is the premier statewide organization growing a strong organic and sustainable agriculture movement in New York State. NOFA-NY provides education and assistance to local organic and sustainable farmers; connects consumers with organic and sustainable farmers; advocates policies that support a sustainable food and farm system at both the state and federal levels; and is the largest USDA-accredited organic certifier in New York certifying over 1,000 organic operations in the state.

A.10474/S.8273 — VDER Moratorium
Amends the public service law to restore net energy metering for community solar and directs the Public Service Commission and the Long Island Power Authority to create a methodology to compensate customers for the full and accurate value of their energy generation by 2021.

Read the full memo here.

Letter to Barbara Underwood, Acting Attorney General of New York State, on Bayer-Monsanto Merger (May 2018)

Barbara Underwood

Acting Attorney General of New York State

Office of the Attorney General
The Capitol
Albany, NY 12224-0341

Dear Attorney General Underwood:

My name is Elizabeth Henderson and I represent the Northeast Organic Farming Association of New York (NOFA-NY). Founded in 1983, NOFA-NY is the premier statewide organization growing a strong organic and sustainable agriculture movement in New York State. NOFA-NY provides education and assistance to local organic and sustainable farmers; connects consumers with organic and sustainable farmers; advocates policies that support a sustainable food and farm system at both the state and federal levels; and is the largest USDA-accredited organic certifier in New York certifying over 1,000 organic operations in the state.

As your office may have seen, the European Union has recently approved Bayer AG’s acquisition of Monsanto Co. That same day, the US Department of Justice released a statement noting how its investigation into the merger is ongoing, citing differences in EU and US Markets. Since then, the Wall Street Journal has reported that the Department of Justice plans to approve the merger, though the report has not been confirmed. 

The European Union announced its approval of the merger pending Bayer divest a number of assets to BASF. A list of the divestments can be found here. Given the differences of the European and United States markets, a similar remedy in the U.S. will be ineffective.

Read the full letter here.

2018 Farm Bill Coalition Letter to Senate (May 17, 2018) 

Dear New York Senator,

Food and agricultural policy affects everyone in New York State, from how we access food, to what we
eat, and how we grow that food. The 2018 Farm Bill provides an opportunity to support farmers, the
food system, and the environmental concerns of our urban, rural and suburban communities in a
meaningful and decisive way.

As organizations representing those who serve the food to the insecure and those who grow it, all of
whom are concerned with environmental impacts, we are sharing with you our priorities regarding the
next Farm Bill. This unique group of undersigned organizations has worked together to share and
develop ideas on overarching needs of the next Farm Bill to ensure national and state food security,
increased access to and availability of healthy and affordable foods for all residents, and the long-term
success of our farmers and sustainability of our farms, regional food systems and our environment.

Read the full letter here.

2018 Farm Bill Coalition Letter to the House (May 17, 2018)

Dear New York Representative,

Food and agricultural policy affects everyone in New York State, from how we access food, to what we eat, and how we grow that food. The 2018 Farm Bill provides an opportunity to support farmers, the food system, and the environmental concerns of our urban, rural and suburban communities in a meaningful and decisive way.

As organizations representing those who serve the food to the insecure and those who grow it, all of whom are concerned with environmental impacts, we are sharing with you our priorities regarding the next Farm Bill. This unique group of undersigned organizations has worked together to share and develop ideas on overarching needs of the next Farm Bill to ensure national and state food security, increased access to and availability of healthy and affordable foods for all residents, and the long-term success of our farmers and sustainability of our farms, regional food systems and our environment.

Despite the well-known intentions to reduce spending by the current administration, Congress’ focus should not be on just cutting the price tag of current Farm Bill programs. During the drafting and passage of the 2014 Farm Bill, $23 billion was cut for deficit reduction, and we believe that the Farm Bill is not the place to continue to look for cuts. Neither the struggling farm economy nor the millions of New Yorkers, who despite low unemployment still rely on our nutrition programs, can afford to sustain further cuts to the safety-net systems in place.

Read the full letter here.

Letter in Support of NYFC Working Farm Protection Act (May 2, 0218)

Working Farm Protection Act—introduced by Assemblymember Didi Barrett (D) AD- 106—would add a proven tool to New York’s farmland protection toolbox to keep working farmers on the land. New York farmers age 65 and older own or manage nearly thirty percent of New York farms. Most do not have a farm operator under the age of 45 working alongside them1.

Two million acres—or nearly one third—of New York farmland is, or will soon be, transitioning to new ownership. This is a critical moment of risk when non-farming buyers can outbid working farmers for available land.

Working farm easements address this threat. The Working Farm Protection Act would strengthen the New York State Department of Agriculture and Markets Farmland Protection Implementation Grant Program by funding conservation easements that protect the long-term affordability of farmland for working farmers.

See who else has signed on.

Letter to Chairmen, Ranking Members, and Secretary Perdue on Addressing America’s Dairy Crisis (April 23, 0218)

As you are aware, America’s dairy farmers are in crisis. Farmer milk prices are currently at $15 per hundred pounds (cwt) of milk, well below the cost of production of $20/cwt – and USDA’s Economic Research Service (ERS) forecasts a 19.2 percent drop in dairy farm net cash income from 2017 to 2018. In the last few months, dairy marketing cooperatives have provided suicide hotline information to members along with milk checks. Small, family-run dairy farms play a vital role in the rural economy while providing a safe, affordable food to consumers. If the current cycle of low prices and contracted dairy markets continues, we will see virtually all of these farms go out of business, with serious impacts on the economic and social health of rural America.

Family farmers are being pushed out of the dairy business due to inefficiencies of the Federal Milk Marketing Order (FMMO) pricing structure; dairy handlers' acceptance of milk from large dairy operations outside their regions instead of from local small family farmers; and the absence of any meaningful dairy safety net. The recent changes to the Margin Protection Program and the dairy provisions proposed in the House farm bill will do little to change the situation for most dairy farmers.
Therefore, the undersigned member and allied organizations of the National Family Farm Coalition call for immediate action by both Congress and USDA to address this crisis in rural America.

Read the full letter here.

NOFA-NY letter on Student Loan Debt to HELP Committee (February 22, 2018)

Organic agriculture is one of the fastest growing segments of food and agriculture in New York, in both sales of organic products as well as organic acreage and farms. Organic is a growth opportunity for our farmers, yet our farmers are aging – the average age of New York farmers is 55, and young farmers are hampered by debt that limits their ability to own or grow their farm operation.

According to a 2017 national survey of young farmers in the U.S. conducted by the National Young Farmers Coalition, student loan debt is the #2 challenge young farmers face - second only to land access.

Read the full letter here.

NOFA-NY sign-on to American Farmland Trust Coalition letter to NYS Assembly and Senate regarding funding of Farmland Protection and the Farmland for a New Generation programs in the 2018 NYS Budget

Thank you for your leadership and support from the New York State Assembly in protecting land for farming and growing food in New York. Fertile land is the irreplaceable foundation of New York’s farm economy which annually generates nearly $40 billion in economic activity, and is vital for producing healthy, locally grown food for state residents all over New York and beyond.

With the legislature’s support, New York has now provided over $140 million to protect nearly 60,000 acres of farmland. These investments strengthen the state’s rural economy and provide capital for farm businesses to expand and adapt to new markets while permanently protecting this irreplaceable fertile soil. Put simply, these dollars are well spent.

Read the full letter here.

NOFA-NY and NODPA letter to NY Congressional Delegation (November 9, 2017)

Organic dairy in the Northeast is in crisis. 2017 saw a massive drop in pay price for most producers, and an oversupply of organic milk that we anticipate will take until well into 2018 to adjust. Even though the Northeast is an organic milk deficit area, all producers have been hit by a $2.00-8.00 drop in pay price (a $10 drop for some by spring of 2018) and most have had a form of quota applied. Farm families have been hit twice: once with a 25% drop in pay price and then a restriction on how much milk they can produce. Despite the fact that retail sales of organic milk in the Northeast have increased, the national oversupply of milk has hit organic producers hard, many of whom have no safety net.

Read the full letter here.

GIPSA letter to President Trump (November 7, 2017)

On October 17, 2017, U.S. Secretary of Agriculture Sonny Perdue announced that he would withdraw two of the three rules collectively known as the Farmer Fair Practices Act, which would have restored the intent of the Packers & Stockyards Act (P&S Act) of 1921.1 While these rules were issued in 2016 under the prior administration, their development has been an ongoing process led by farmers and ranchers since 2010. The prior administration simply did not get the job done. You, Mr. President, have the opportunity to make the difference in the future of rural America and preserve America’s family farmers and ranchers.

Read the full letter here.

NOFA-NY's Comments to the National Organic Standards Board (October 11, 2017)

NOFA-NY strongly believes that the foundation of organic production, as laid out in the Organic Foods Production Act is in the natural ecological system based in the soil, and that it does not include the continuous inputs of fertilizers, nutrients, and other inputs to sustain the growing of organic crops.

Read the full letter here.

200+ Organization Letter to Congress on Agricultural Consolidation in 2018 Farm Bill (October 4, 2017)

U.S. farm income is significantly depressed, with disastrous ripple effects through our rural economy. Since the last Farm Bill debate, these trends have only worsened. As Congress starts the debate on the next Farm Bill, you must address negative trends in agricultural market control and anti-competitive business structures if we are to have any hope of restoring the economic health of rural America.

Read the full letter here.

Letter to Governor Andrew Cuomo regarding the release of the GE Moth (July 17, 2017)

On July 6, 2017 USDA/APHIS released a final environmental assessment (EA) and a Finding of No Significant Impact (FONSI) for an open air field release of genetically engineered diamondback moths and confirmed it will issue a permit to Cornell University for this release at the NYS Experiment Station in Geneva, NY.

Cornell’s plan is to release up to 30,000 Genetically Engineered male moths each week during the cabbage planting cycle (about three to four months), beginning the summer of 2017 into a 10-acre field at the Geneva Experiment Station. The males are genetically engineered with a lethal gene that they pass on to females when they mate, which causes the female offspring to die, usually as caterpillars directly on the food plants they target: broccoli, cabbage and other brassica. The males develop to moths and continue to mate. The researchers claim the released moths will not leave the site, even though Diamondback Moths arrived in New York from the south by traveling thousands of miles on wind currents.

Read the full letter here.

Letter to Secretary of Agriculture Sonny Perdue to support Organic Agriculture (July 12, 2017)

We are writing as farms, businesses, research centers and organizations representing a broad spectrum of perspectives about food and agriculture to express our strong, shared support for the USDA organic label and the federal marketing, research and data collection programs that support the label.

With the establishment of the National Organic Program in 2001, consistent national standards were created to govern the labeling of organic food and the use of the USDA organic seal. Consumer confidence in the integrity of the USDA organic seal has been a driving factor in the exponential growth in the organic sector. In 2000, organic sales of products labeled under various conflicting state and private organic labels totaled only $6 billion. Today, as a result of the establishment of the consistent federal organic standards, total sales of organic food and beverages are nearly $50 billion. Domestically, the organic sector is home to nearly 24,000 certified organic family farms and other businesses.

Read the full letter here.

NOFA-NY comments to the USDA regarding the Importation, Interstate Movement, and Environmental Release of Certain Genetically Engineered Organisms (June 19, 2017)

NOFA-NY submits the following comments in response to the APHIS proposed rule revising its regulations of genetically engineered (GE) organisms.

NOFA-NY believes that USDA has the authority provided by the Plant Protection Act to implement regulations to protect farmers, the environment, and our communities from unwanted harm and impacts from GE organisms. This proposal would significantly weaken existing regulations and provide loopholes that would deceive the public into believing that GE organisms are indeed being regulated adequately. We urge the Department to withdraw this proposal and use your authority to develop and implement stronger regulations to protect the citizens and the environment of the United States.

Click here for the full document.

Letter to Secretary Perdue and Members of Congress to Protect Funding for Programs that Benefit Organic Agriculture and the Organic Industry (June 15, 2017)

With the establishment of the National Organic Program in 2001, consistent national standards were created to govern the labeling of organic food and the use of the USDA organic seal. Consumer confidence in the integrity of the USDA organic seal has been a driving factor in the exponential growth in the organic sector. In 2000, organic sales of products labeled under various conflicting state and private organic labels totaled only $6 billion. Today, as a result of the establishment of the consistent federal organic standards, total sales of organic food and beverages are nearly $50 billion. Domestically, the organic sector is home to nearly 24,000 certified organic family farms and other businesses.

Organic farmers are required to use farming practices that preserve and enhance natural resources, and organic processors are required to use ingredients that have passed strict environmental and human health reviews. Consumers are willing to pay higher prices for products that meet these higher standards. As a result, organic farmers and processors enjoy a higher price to reward them for their extra costs and efforts.

Click here to read the full letter.

National Organic Program Organic Livestock and Poultry Practices Second Proposed Rule (June 5, 2017)

As we noted in our comprehensive comments to you in July 2016, attached and excerpted below, we strongly believe that these Organic Livestock and Poultry Practices Rules must be implemented as soon as possible.

Let us be clear: No further review is needed. NOFA-NY believes that the U.S. Department of Agriculture should follow through with its original intentions and implement Action Number (1): “Let the rule become effective. This means that the rule would become effective on November 14, 2017.” [FR Vol. 82, No. 89, May 10, 2017]. Do Not Delay.

Click here to read the full letter.

NOFA-NY comments on the December 2016 Environmental Assessment of the Proposal to permit the field release of genetically engineered diamondback moth in New York (May 19, 2017)

NOFA-NY objects to the short 30-day comment period for this Environmental Assessment, especially since April and May are in the middle of the planting window for New York State farmers. On April 21, NOFA requested an extension, but never received a response. This is unfortunate for the farmers of the region who may be significantly affected by these trials.

NOFA-NY considers the first-in-the-world open air release of the Genetically Engineered Diamondback moth – a novel organism – to be a major activity with potentially significant and heretofore unknown health and environmental effects. We have expressed concern about the proposed trials of the Genetically Engineered Diamondback Moth (GDM) for many years, and continue to be significantly troubled at the prospect of an open-air release of a novel organism in New York State without comprehensive health, safety, and environmental review. If approved, the proposed experiments would likely be the first to utilize GE insects with a female-killing trait anywhere in the world. Yet, the owner of this technology (originally, Oxitec UK – now Intrexon) has not completed comprehensive, independent health, safety, and environmental review required by international protocols.

Click here to read the full letter.

Written Statement on FY 2018 Appropriations Requests on behalf of the Seeds and Breeds for the 21st Century Coalition (May 15, 2017)

In recent decades, public resources for the development of improved plant varieties and cultivars have dwindled, while resources have shifted toward genomics and biotechnology, with a focus on a limited set of major crops.

Farmer access to regionally adapted seeds and breeds is paramount to fostering the competitiveness of agriculture in all regions of the U.S. As agricultural research has shifted toward an emphasis on lab-based and molecular breeding, seed choice has not kept up with demand, and the diversity of our plant genetic resources has narrowed. Farmers need access to seeds that are bred specifically for their regions and cropping systems. In particular, farmers lament limited cultivar options in major crops, especially publicly held seed varieties and plant cultivars released by land grant universities that are adapted to regional farming needs to satisfy the national market. By improving agricultural productivity and resilience, classical or field-based breeding also improves food security for our growing population.

Click here to read the full letter.

Letter Regarding the Proposed Merger of Monsanto Company and Bayer AG (May 9, 2017)

We are a group of 137 farmer, consumer, and environmental groups deeply concerned about growing concentration in the agricultural products sector and, in particular, about the proposed merger of Monsanto Company and Bayer AG.

As you know, the merger was proposed in the fall of last year and is currently under review by the Department of Justice (DOJ).

As you consider the nomination of Makan Delrahim to lead the Antitrust Division at DOJ we urge you to ensure that he will fully and skeptically evaluate the proposed merger, devote all necessary resources to the investigation, and hold the welfare of farmers, consumers, workers, and innovation foremost in his mind as he decides whether to block the merger.

Read the full letter here.

Letter of Request for Genetically Engineered Diamondback Moth data (April 19, 2017)

We write regarding the caged field trials of genetically engineered (GE) diamondback moths conducted at Cornell NYSAES in summer 2015. We are aware of the trials summary published online, however this leaves many unanswered questions about the findings of these trials. We are particularly interested in the actual data from the caged trials with GE DBM that took place in summer of 2015.

Read the full letter here.

Letter of NOFA-NY Organic Checkoff Comments (April 11, 2017)

NOFA–NY opposes the Organic Research, Promotion and Information Order submitted to the USDA by the Organic Trade Association because it is not farmer friendly, will benefit US organic sales, not production, and will negatively impact all organic certificate holders, whether or not they are assessed. Given its stated purposes, it is unlikely to benefit the growth, sustainability or profitability of organic farmers in the U.S., yet will require burdensome paperwork for all, and is an unfair tax.

Read the full letter here.

Letter of Support for the Young Farmer Success Act (April 6, 2017)

American agriculture faces a crisis of attrition. Two-thirds of our farmland is on the cusp of transition as farmers age and retire, and there are few young farmers positioned to manage this resource. Farmers over the age of 65 outnumber farmers under the age of 35 by a margin of 6-to-1, and the number of farmers under the age of 35 grew by only 1% between 2007 and 2012.

Read the full letter here.

Letter sent in Support of the Three Arrested Farmworkers (March 22, 2017)

In the past several years NOFA has had the distinct fortune of working with the Vermont-based Migrant Justice organization, whose stated mission “is to build the voice, capacity, and power of the farm worker community and engage community partners to organize for economic justice and human rights. We gather the farm worker community to discuss and analyze shared problems and to envision collective solutions.” In a number of aspects its work parallels that of NOFA, including farm worker issues about the dignity of work, achieving a livable wage, freedom from discrimination, and access to health care. These issues are endemic to farmworkers across the Northeast.

Read the full letter here.

Letter sent regarding 2018 Farm Bill (February 22, 2017)

The undersigned organizations, representing America’s agriculture, nutrition, conservation, rural development, finance, forestry, energy, trade, local government, plant/animal health, agricultural sciences and veterinary medicine,  labor, outdoor recreation, equipment manufacturing, cooperatives, hunters, anglers and crop insurance sectors, strongly urge you to reject calls for additional cuts to policies within the jurisdiction of the Senate Committee on Agriculture, Nutrition and Forestry or the House Committee on Agriculture.  

Read the full letter here.

Letter Opposing The Proposed Dow-DuPont, Monsanto-Bayer and Syngenta-ChemChina Mergers (February 13, 2017)

On behalf of our millions of members and supporters around the country, the undersigned organizations oppose the impending mergers of the world’s largest agrochemical and seed companies. The proposed mergers—of Dow Chemical with DuPont, Monsanto with Bayer AG, and Syngenta with ChemChina—are each problematic on their own, with many likely negative impacts on farmers, businesses, workers, and consumers. When taken together, they pose the threat of major oligopolistic outcomes in the industries of farming inputs, research, development, and technology. We urge the United States Department of Justice to conduct a thorough investigation to determine the impacts of these takeovers (alone and most importantly in combination) and to enjoin the mergers when it becomes clear that these impacts will prove detrimental to farmers, businesses, workers, consumers, the environment and our American food system.

Read the full letter here

Organizational Sign-on Letter Opposing Scott Pruitt for EPA Administrator (January 13, 2017)

We, the undersigned environmental, health, labor, faith, community, business, and advocacy organizations, and elected officials, write to urge your strong, unqualified, and robust opposition to Oklahoma Attorney General Scott Pruitt’s appointment to head the Environmental Protection Agency (EPA). Pruitt has a record of advocating against any and all protections for our water, air and climate. Allowing him to lead the EPA would not only be a disaster for the environment, but for every person in the United States who drinks water or breathes air.

Read the full letter here

Letter to Governor Cuomo (November 15, 2016)

NOFA-NY supports American Farmland Trust in the creation of a "Farmland for a New Generation" program.
"Agriculture in New York, like the nation, is undergoing a major transition as a new generation of farmers seek to enter farming. The Beginning Farmer Workgroup that you established in 2014, as well as reports by American Farmland Trust, American Farm Bureau Federation, GrowNYC, National Young Farmers Coalition, United States Department of Agriculture and others have identified that securing access to farmland is one of the greatest barriers facing new and next generation farmers in New York, and across America."
 
Read the full letter here
Read about the "Farmland for a New Generation" program here

Letter sent to National Organic Standards Board (October 26,2016)

NOFA-NY is a member of the National Organic Coalition (NOC) - a national alliance of organizations working to provide a "Washington voice" for farmers, ranchers, environmentalists, consumers and industry members involved in organic agriculture. The coalition works to assure that policies are fair, equitable, and encourage diversity of participation and access. In order to achieve this goal, NOC submits letters to the National Organic Standards Board (NOSB), which is the federal advisory board that considers and makes recommendations on a wide range of issues involving the production, handling, and processing of organic products. Please see our Fall 2016 letter to the NOSB.

Read the full letter here.

Letter sent in support of the Standing Rock Sioux Tribe's water protection efforts to halt the Dakota Access Pipeline (September 29, 2016).

NOFA-NY declares our solidarity with the Standing Rock Sioux Tribe’s opposition to the Dakota Access Pipeline. We affirm the treaty rights, tribal sovereignty, and protection of their lands, waters, cultural and sacred sites of the Standing Rock Sioux Tribe. We are grateful to the Native Peoples who are acting as protectors of our waters and lands and we pledge to stand with them for the sake of the healthy soils and clean waters necessary for healthy food production from our farms and gardens, and for life itself.

Read the letter here

Letter sent to the Cornell University College of Agriculture and Life Sciences regarding GE Diamondback Moth Trials (September 13, 2016)

Since spring 2015, NOFA-NY and our colleagues from Consumers Union, Food & Water Watch, Center for Food Safety, Friends Of the Earth, and Genewatch UK have been attempting to get answers to various questions regarding the permitting process – federal, state, and University – as well as impacts on health and environment regarding the proposed open air trials of the Genetically Engineered Diamondback moth (GDM) at the New York State Agriculture Experiment Station (NYSAES).  We have had good conversations with various people, but have not specifically received answers to questions we have continued to ask. 

Read the letter here

Letter regarding Okanagan Specialty Fruit GE non-browning “Arctic” Fuji apple (September 12, 2016)

One of the latest applications for GE foods comes Okanagan Specialty Fruit for their non-browning “Arctic” Fuji apple. NOFA-NY certifies 78 organic apple producers and four handler/processors who use organic apples in their products and we work to enhance the organic apple production, while fighting the invasion of GMO foods in our farm system. We requested that the USDA deny the application for these GE apples, based on the following rationale:

  • The Nature of Apples: It is the nature of apples to brown, indicating any damage it has incurred; thus, warning consumers of a potential problem.
  • Food Safety:  The intended market is pre-sliced, ready to eat apples, which is a frequently recalled food product, since the whole fruit is at risk of pathogens. No independent testing has been done on the safety or unintended consequences of silencing the genes that make apples turn brown when exposed to oxygen. Babies are the intended test market for these easy to use, pre-sliced apples.
  • Pollen and Gene Flow: The pollen gene flow from apple orchards is significant and accomplished by insects, including bees, which can become contaminated with GE pollen, and, thus jeopardize entire organic honey productions. In addition, it is unclear how pollen gene flow may contaminate organic apples, resulting in a loss of future markets, or even suspension of organic certification.
  • Consumer Preference: Avoidance of genetically engineered food is one of the explicit reasons that consumers purchase organic products. There is increased potential for GE apples to be purposely or inadvertently used in organic products, such as organic apple juice or apple sauce. 

Read the full letter here.

Sign the petition telling the USDA to say NO to the new GMO apple here

Letter to Commissioner Richard Ball regarding Farmland Protection (August 15, 2016)

We are writing to share our appreciation of Commissioner Ball’s leadership and to express our sincere thanks for the support given to protect farmland in New York.  The purchase of conservation easements on working farms has helped hundreds of farm families meet their goals and reinvest in the viability of their operations, while growing the state’s farm economy and bolstering local food production. This is an important year as 2016 is the 20th anniversary of the State of New York investing in protecting working farmland. We greatly appreciate the state’s allocation of $140 million to conserve approximately 60,000 acres of farmland on over 230 farms in 29 counties through the Farmland Protection Implementation Grant program (FPIG). This 20th anniversary was recently celebrated with a joint New York State Legislative Resolution commemorating the past two decades of state funding for protecting farmland. 

The process of completing these permanent farmland protection projects, which frequently involve multiple generations of farm families, local governments and private land trusts, can be intricate and time consuming.  The work that Governor Cuomo and the Department of Agriculture have invested in ensuring state-funded farmland conservation projects are completed at a quicker pace has been meaningful to farmers and to the conservation groups and local governments with whom they collaborate.  We urge the Department of Agriculture and Markets to make state funding for protecting farmland available on an annual basis to maintain the high level of interest among farmers as well as ensure a regular schedule of farmer PDR trainings as well as pre-application procedures and other activities conducted at the local level.  Ultimately, this regular annual application process will ensure the state receives high-quality projects that are poised to be completed quickly.

Read the full letter here   

 

National Organic Program Organic Livestock and Poultry Practices Proposed Rule (July 12, 2016)

It is a basic tenet of organic production for animals to be treated humanely, and consumers  believe that animals bearing the organic label have had significant access to the outdoors The final rule implementing Organic Foods Production Act, (OFPA) notes that animals should have living conditions “which accommodate the health and natural behavior of the livestock.” [regulation].  This is clearly stated in the law, the Regulations, as well as congressional intent language.

Indeed, the concept of accommodating health and natural behavior of animals is already a certifiable standard, and NOFA believes that additions to the regulations should enforce that principle as well as make it more consistently implemented, without losing each farm’s unique manner of complying with these standards. Successful organic systems rely on practices that attempt to approach natural systems, and therefore can be significantly different in terms of practices, feed, as well as genetics for livestock and poultry.  As organic evolves its standards to reflect these differences, we expect to see a decreasing reliance on conventional systems that are used with organic input substitutions, and an increase in wholly more organic, welfare-based sustainable systems.

Read the full letter here

New York State Minimum Wage Statement (July 2016)

Raising the minimum wage in New York State is a complex issue involving many interrelated parts that must be considered together. NOFA-NY does not provide blanket support of an increase in the minimum wage to $15 in NYS. It should not happen without due consideration of these interrelated parts. 

NOFA-NY advocates first for farmers to retain a larger share of the food dollar. Organic family farmers contribute much to their communities in the form of healthy food, carbon restored to the soil, cleaner environmental conditions, and healthy local economies. Yet these farmers are often compelled to augment their farm income by obtaining additional employment off the farm. It is only when they can earn a living wage from farming that they can securely and consistently provide higher wages to farm workers.

NOFA-NY is not just an organization of farmers and consumers, but also of farm workers. Many of our members who would identify themselves as farmers when given our usual breakdown of options—farmer, gardener, consumer—actually turn out to be interns, apprentices, farm workers, assistant managers, and farm managers. While their interests are not always identical with farm owners’, in this case NOFA-NY speaks for them all when we point out that the minimum wage has not kept pace with inflation.  Farm employees find it difficult to make financial ends meet and need to be compensated at a higher wage for the hard work they do. We believe these two issues are linked. 

NOFA-NY understands these are complex issues and is dedicated to working towards equitable solutions for the good of the local, organic, food system. 

 

October 5, 2018   Honorable Andrew Cuomo Governor New York State Capitol Albany, NY 12224   Honorable John Flanagan Majority Leader New York State Senate Albany, NY 12247   Honorable Carl Heastie Speaker New York State Assembly Albany, NY 12247   Honorable Thomas O’Mara Chair, NY Senate Environmental Conservation Committee New York State Senate Albany, NY 12247   Honorable Steven Englebright Chair, NY Assembly Environmental Conservation Committee New York State Assembly Albany, NY 12247   Re: Protecting New York’s Pollinators   Dear Governor Cuomo, Majority Leader Flanagan, Speaker Heastie, Chairmen O’Mara and Englebright:   On behalf of the undersigned organizations and businesses and our hundreds of thousands of New York members, we write to urge you to safeguard the state’s bees, butterflies, and other critical pollinators—in particular, by taking action to reduce the use of pollinator-harming pesticides. Given the magnitude of the current crisis faced by pollinators, we believe the state must act quickly to: (1) prohibit unnecessary uses of harmful systemic insecticides, such as neonicotinoids (neonics); and (2) take comprehensive regulatory action to address other pollinator-toxic pesticide uses, including the use of neonic-treated seeds.   Recent collapses of pollinator populations, both here and around the world, have particular significance for New Yorkers and the state’s environment. Pollinators are important or essential to more than $360M of state agricultural products each year—including apples, squash, blueberries, and peaches—and provide benefits to hundreds of millions more.1 Overall, the state estimates these pollination-dependent crops contribute $1.2 billion annually to the local   1 USDA, 2017 State Agriculture Overview: New York (last visited Oct. 4, 2018),  https://bit.ly/2HpaXtE.     agricultural economy.2 Yet in the 2017-2018 season, New York beekeepers lost over 40% of their bee colonies, and the loss rate has hovered at or above that number for the past five years.3 These losses not only impose costs on farmers and beekeepers, but also suggest the potential for similar catastrophic losses for the state’s 450 pollinating species, critical to the survival of native plants and wildflowers.4   While many factors contribute to the current pollinator crisis, the widespread and growing scientific consensus is that the overuse of neonics play a major and preventable role. The past two years alone have seen a tremendous growth in research confirming neonics’ long- suspected harms to pollinators and the broader environment. This includes findings by the European Food Safety Agency (EFSA) that neonics “pose a risk to bees,”5 decisions by the Canadian Pest Management Regulatory Agency (PMRA) that several approved neonic uses fail to meet environmental safety standards,6 and assessments by the U.S. Environmental Protection Agency (EPA) identifying the direct and indirect risks that many neonic uses pose to pollinators, birds, mammals, fish, and other aquatic animals.7 These agency findings are supported by the most current academic literature, including comprehensive worldwide assessments of neonic impacts on pollinators8 and the largest pollinator field study to date—funded by the pesticide industry itself9—finding neonics caused measurable (and avoidable) harm to both honeybee and wild bee populations.10             2 DEC & NY Dep’t of Ag. and Markets (DAM), New York State Pollinator Protection Plan Update, 8 (Jun. 2018), https://on.ny.gov/2nBYgPW. 3 See Bee Informed Partnership, 2017/18 Total Annual Colony Loss Map, (last visited Oct. 4, 2018), https://bit.ly/2HpheoW, and select “Annual” under the “Season” tab. 4 Cf. DEC & DAM, New York State Pollinator Protection Plan, 5-6 (Jun. 24, 2016),  https://on.ny.gov/2KcTtOQ [hereinafter “NY Pollinator Plan”]. 5 EFSA, Q&A: Conclusions on Neonicotinoids 2018 (Feb. 28, 2018),  https://bit.ly/2jsXsdN. 6 See PMRA, Proposed Re-evaluation Decision PRVD2018-12, Imidacloprid and Its Associated End-use Products: Pollinator Re-evaluation (May 31, 2018),  https://bit.ly/2QlLHVI; PMRA, Proposed Re-evaluation Decision PRVD2017-23, Clothianidin and Its Associated End-use Products: Pollinator Re-evaluation (Dec. 19, 2017) https://bit.ly/2LbpY0b; PMRA, Proposed Re-evaluation Decision PRVD2017-24, Thiamethoxam and Its Associated End-use Products: Pollinator Re-evaluation (Dec. 19, 2018),  https://bit.ly/2wNo5DK. 7 See, e.g., EPA, Preliminary Terrestrial Risk Assessment to Support the Registration Review of Imidacloprid, 8-9 (Nov. 28, 2017),  https://bit.ly/2s7spLK; EPA, Preliminary Bee Risk Assessment to Support the Registration Review of Clothianidin and Thiamethoxam, 14-23 (Jan. 5, 2017),  https://bit.ly/2jfMFon; EPA, Preliminary Aquatic Risk Assessment to Support the Registration Review of Imidacloprid, 8-9 (Dec. 22, 2016), https://bit.ly/2r3Uuyy. 8 See Chiara Giorio, An Update of the Worldwide Integrated Assessment (WIA) on Systemic Insecticides. Part 1: New Molecules, Metabolism, Fate, and Transport, Envtl. Sci. Pollution Research Int’l (Jul. 15, 2017), https://bit.ly/2qVqciQ; Lennard Pisa et al., An Update of the Worldwide Integrated Assessment (WIA) on Systemic Insecticides. Part 2: Impacts on Organisms and Ecosystems, Envtl. Sci. Pollution Research Int’l (Nov. 9, 2017), https://bit.ly/2HqqHwB; Thomas Wood & Dave Goulson, The Environmental Risks of Neonicotinoid Pesticides: A Review of the Evidence Post 2013, Envtl. Sci. Pollution Research Int’l, 24(21): 17285–17325 (Jun. 7, 2017), https://bit.ly/2Hpn8T5. 9 Daniel Cressey, Largest-ever Study of Controversial Pesticides Finds Harm to Bees, Nature (Jun. 29, 2017), https://go.nature.com/2sgJjDk. 10 B.A. Woodcock et al., Country-specific Effects of Neonicotinoid Pesticides on Honeybees and Wild Bees, Science, 356(6345): 1393-1395 (Jun. 30, 2017), https://politi.co/2HrEnDl.   This new evidence has prompted considerable action. Last April, the European Commission voted to ban all outdoor use of three major neonics,11 and Canada’s PMRA recently recommended similar action given the widespread threat neonics pose to aquatic ecosystems.12 In the U.S., states have led the charge, given EPA’s repeated and ongoing delays in its own scientific review of neonics13 and the Trump Administration’s unwillingness to prevent unsafe pesticide use.14 Connecticut and Maryland have passed laws that prohibit over-the-counter sales of neonic products, limiting their use to certified professionals,15 and earlier this year in California, the state Department of Pesticide Regulation put a freeze on any new pesticide approvals that would expand neonic use.16   New York—while an early leader in protections against harms from neonics17—has yet to respond to the new science. At the New York Department of Environmental Conservation (DEC), any major efforts to protect pollinators from neonics have stalled since publication of the 2016 New York State Pollinator Protection Plan, which found that scientific research at the time had produced “conflicting conclusions” regarding neonics’ environmental harms.18 This finding is now well out-of-date and at odds with subsequent research from the Cornell Department of Entomology, showing that the neonic thiamethoxam poses the “greatest total oral exposure risk” to bees in a study of New York apple orchards.19 The current scientific literature on the ecological dangers of neonic use is unequivocal and demands both immediate protections and longer-term comprehensive solutions.   In the short term, New York should act by prohibiting unnecessary uses of neonics and similar harmful systemic insecticides that threaten pollinators. These include certain treated crop seed, as described below, as well as neonic use on state public lands and in residential and commercial settings—except in rare circumstances (for example, where it is shown to be necessary to combat invasive species). Home and garden products pose particular dangers for pollinators because of their permissive labeling, with some approved for use at rates up to 120-     11 European Commission, Protecting Bees: EU Set to Completely Ban Outdoor Use of Pesticides Harmful to Bees (Apr. 27, 2018),  https://bit.ly/2HwtNee. 12 See PMRA, Proposed Special Review Decision PSRD2018-01, Special Review of Clothianidin Risk to Aquatic Invertebrates (Aug. 15, 2018), https://bit.ly/2x2MHGk; PMRA, Proposed Special Review Decision PSRD2018-02, Special Review of Thiamethoxam Risk to Aquatic Invertebrates (Aug. 15, 2018), https://bit.ly/2wZbYQZ; PMRA, Proposed Re-evaluation Decision PRVD2016-20, Imidacloprid (Nov. 23, 2016),  https://bit.ly/2Ky4iu4. 13 Friends of the Earth, On Heels of Canada and EU bans, EPA Stalls Review of Bee-Killing Pesticides (Aug. 21, 2018),  https://bit.ly/2x0qiJX. 14 See, e.g., Appeals Court Orders EPA to Ban a Pesticide Known to Harm Children, Time (Aug 10, 2018), https://ti.me/2N2V2UI. 15 See C.G.S. § 22a-50; MD Code, Agriculture, § 5-2A-02. 16 California Dep’t of Pesticide Regulation, Expanding Use of Pesticide Products under Reevaluation (Jan. 3, 2018), https://bit.ly/2GsQhvn. 17 More than a decade ago, New York refused to register outdoor uses of two major neonic chemicals—clothianidin and dinotefuran—citing concerns over water pollution and harms to pollinator health. NY Pollinator Plan at 18; DEC, Denial of Applications to Register the New Active Ingredient Dinotefuran Contained in the Pesticide Products Safari 20 SG Insecticide (EPA Reg. No. 33657-16-59639), Venom 20 SG Insecticide (EPA Reg. No. 33657-17- 59639) and Venom Insecticide (EPA Reg. No. 59639-135) (Jan. 7, 2008),  https://bit.ly/2qWrYAk. 18 NY Pollinator Plan at 9. 19 McArt et al. 2017, High Pesticide Risk to Honey Bees Despite Low Focal Crop Pollen Collection During Pollination of a Mass Blooming Crop, Scientific Reports, 7:46554. doi:10.1038/srep46554 (Apr. 19, 2017), https://go.nature.com/2Ir0o9Y.   times higher than levels used on farm fields.20 Prohibiting use of these products will protect New Yorkers, too, as new research raises concerns about neonics’ adverse impacts on human health.21   DEC should also take comprehensive regulatory action to restrict pesticide uses where the risks to pollinators exceed perceived benefits, including neonic coatings on crop seeds, also known as “seed treatments.” Although seed treatments account for the bulk of neonics entering the environment,22 they often provide little to no crop protection value. For example, roughly half of soybean seeds are treated with neonics, despite EPA findings that those treatments likely “provide $0 in benefits to growers.”23 While existing research supports immediate legislative action to prohibit the use of certain neonic-treated seed, such as treated soybean and corn seed,24 in general, DEC does not track or regulate treated seeds. This represents a major regulatory loophole that must be closed. DEC’s authority over treated seed should be clarified,25 and DEC should be directed to create a comprehensive regulatory plan addressing all pollinator-harming pesticide uses—including treated seed—restricting or prohibiting those uses where appropriate.26   Lastly, while meaningful reductions in the use of pollinator-killing pesticides are essential to reversing population losses, New York should also actively promote the planting of new pollinator habitat. To this end, the state should create a dedicated fund with incentives for private or utility landowners to convert turf or barren land into high-quality habitat. The New York Department of Transportation should also expand its program to create pollinator habitat across its 15,000 miles of highways, and similar programs should be adopted by the state Thruway Authority and Canal Corporation.   While we now better understand the severity of the current pollinator crisis and its causes, pollinator populations continue to crash statewide. The time for a comprehensive program to save these species—crucial to the state’s environment and agricultural economy—is well past due. Although, ultimately, additional protections may be necessary, we believe these actions mark a significant and necessary first step.     20 Jennifer Hopwood et al., How Neonicotinoids Can Kill Bees (2nd Ed.), Xerces Society (2016), https://bit.ly/2IqfQ6h. 21 See Elyse Caron-Beudoin et al., Effects of Neonicotinoid Pesticides on Promoter-Specific Aromatase (CYP19) Expression in Hs578t Breast Cancer Cells and the Role of the VEGF Pathway, Envtl. Health Perspectives (Apr. 2018),  https://bit.ly/2Bafc9B. 22 See Sara LaJeunesse, Rapid Increase in Neonicotinoid Insecticides Driven by Seed Treatments, Penn State (Apr. 2, 2015), https://bit.ly/2nBlcOZ. 23 EPA, Memorandum: Benefits of Neonicotinoid Seed Treatments to Soybean Production, 2 (Oct. 15, 2014), https://bit.ly/2OKvnxl. 24 See id.; Adam Alford & Christian Krupke, Translocation of the Neonicotinoid Seed Treatment Clothianidin in Maize, PLOS ONE 12(10): e0186527 (Mar. 10, 2017),  https://bit.ly/2xZtEgS. 25 DAM exercises limited regulatory authority over seed inspection and sales, mainly related to quality assurance (e.g., to ensure seeds meet germination standards, do not contain excess impurities, and are labeled appropriately). See N.Y. Agric. & Mkts. Law §§ 136-142. It does not regulate the use of pesticidal seed treatments or control the planting of pesticide treated seeds. For all practical purposes, seed treatments are pesticides, and planting treated seeds constitutes a pesticide use, over which DEC has exclusive jurisdiction. See ECL § 33-0303 (DEC has jurisdiction over all matters pertaining to the distribution, sale, and use of pesticides, and responsibility to regulate to ensure pesticide use does not injure health, property, or wildlife, such as pollinators). 26 DEC may regulate, restrict, or prohibit pesticides or particular pesticide uses in order to prevent damage to wildlife. ECL § 33-0303(3)(e). DEC should be directed to do so to protect pollinators from pesticide uses which continue to decimate their populations.     Thank you for your time and attention to this matter. Respectfully, Ana Paula Tavares Executive Director Audubon New York   Katherine Nadeau Deputy Director Catskill Mountainkeeper   Adrienne Esposito Executive Director Citizens Campaign for the Environment   James Doan Owner Doan’s Honey Farm in Hamlin, NY   Elizabeth Moran Water & Natural Resources Director Environmental Advocates of New York   Eric Weltman Senior Organizer Food and Water Watch   Tiffany Finck-Haynes Senior Food Futures Campaigner Friends of the Earth   Daniel Raichel Attorney Natural Resources Defense Council   Russ Haven General Counsel New York Public Interest Research Group   Andrianna Natsoulas Executive Director Northeast Organic Farming Association of New York   Roger Downs   Conservation Director Sierra Club, Atlantic Chapter