January 31, 2008
Mr. Michael Arny, President
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 standard’s 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
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
American National Standards Institute
25 West 43 Street, 4th Floor
NY, NY 10036