By Alfred Flores,2014-06-06 20:07
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     January 31, 2008

Mr. Michael Arny, President

    Leonardo Academy

    1526 Chandler Street,

    Madison, Wisconsin 53711

Dear Mr. Arny,

     thWe are writing in follow-up to our conversation on January 17 with Anne Caldas of

    American National Standards Institute (ANSI) to express our concern about the process used to establish the proposed American National Standards Institute Draft Standard for Sustainable Agriculture for Trial Use. We understand the Leonardo Academy’s desire to

    generate and harmonize sustainability standards. It is unfortunate, however, that this standard with its important implications for American agriculture was processed in this manner. We are concerned that the ANSI process has not been followed and that this may have already led to irremediable defects in terms of ANSI’s ability to receive


    Stakeholder concerns and the controversial nature of the standard make procedural issues of utmost importance.

    ; It equates organic practices with best agricultural practices, a conclusion that

    would be soundly rejected by many in the scientific community and an issue that

    will provoke intense debate between the organic and conventional agricultural


    ; It rejects the use of biotechnology, perpetuating scientifically unsound and overly

    precautionary approaches that have been rejected by many governments,

    including our own, and which have provoked significant trade concerns.

    ; It requires that producers follow organic processes rather than achieving specific

    results that can be objectively and metrically validated as sustainable, making it

    unsuitable for the very sectors of agriculture that would be impacted

    ; It requires agriculture to engage in discussions of carbon emission standards that

    are well beyond the technological knowledge and capability of most of the

    participants likely to be engaged in this standards process. Carbon emissions

    standards are the proper focus of climate change discussions and regulatory

    guidance processes, which have just begun.

    ; It applies to biofuels, which are also the subject of many other standard setting

    efforts, including the International Standards Organization (ISO) and the

    Roundtable on Sustainable Biofuels. Food and agriculture stakeholders are also

    participating in other initiatives including legislative discussions.

    We believe that the ANSI process is not being followed and we would like to highlight several concerns.

    ; The draft standard for trial use was not notified to “materially affected

    stakeholders” prior to its adoption for trial use by the Leonardo Academy.

    ; The draft standard has not since been notified effectively to materially affected

    stakeholders both domestically and internationally.

    ; The standards stated purpose is to define sustainable agriculture. However, the

    draft standard as written clearly pertains to “sustainable organic agriculture” only

    and does not meet the definition of “sustainable agriculture” as defined in law by

    the 1990 Farm Bill. Therefore, had it been notified as a standard for “sustainable

    agriculture”, it would have been misleading and inaccurate.

    ; Because the Leonardo Academy has demonstrated that it has little knowledge of

    or experience with the broad range of stakeholders that will be affected by this

    standard, we are concerned that the process it is following will not accurately

    reflect the balance or scope required by its rules and by ANSI’s.

    ; We are concerned that the Leonardo process will not garner sufficient input to

    ensure that this standard is credible, particularly since Leonardo has not

    established a group composed of government experts.

    We encourage the Leonardo Academy to narrow the scope of this standard to organic agriculture and work with other ongoing standard setting efforts. We believe that the inevitable years of intense debate on irresolvable conflicts that this standards process will provoke can and should be avoided.

American Farm Bureau

    American Seed Trade Association

    American Soybean Association

    American Sugar Alliance

    Animal Health Institute

    Biotechnology Industry Association

    California Association of Wheat Growers

    California Citrus Quality Council

    California Dried Plum Board

    California Grain and Feed Association

    California Grape & Tree Fruit League

    California Pear Growers

    California Seed Association

    California Warehouse Association

    California Tree Fruit Agreement Croplife America

    Cotton Incorporated

    Del Monte Foods

    Florida Fruit and Vegetable Association Grocery Manufacturers Association Lodi-Woodbridge Winegrape Commission National Association of Wheat Growers National Cattlemen’s Beef Association

    National Corn Growers Association National Cotton Council

    National Oilseed Processors Association National Sorghum Producers

    North American Millers’ Association


    United Soybean Board

    U.S. Rice Producers Association United States Soy Export Council USA Rice Federation

    cc. Mr. Joseph Bhatia, President

     Ms. Anne Caldas, Director

     Procedures and Standards Administration

     Accreditation Services

     American National Standards Institute

     25 West 43 Street, 4th Floor

     NY, NY 10036

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