Photo from Iowa, courtesy of factoryfarm.org.
It's easy to get cynical about our ability to influence policy or policymakers - especially when we don't have lots of money or a well-dressed K St. lobby firm to throw around. But I'd venture to say that with all the change-making, democracy-taking action that's been going on recently, many of us are feeling a little more open to the idea that we could play a role in creating a better food system via the policy process.
Right now, at this very second, there are important opportunities to do just that by commenting on four proposed rules. What are proposed rules, you ask? Here's how the whole thing works: after a federal bill is passed and becomes law, the agency in charge of carrying it out has to issue what's called a rule, the set of specific instructions that will govern how the law will be implemented. In most cases, the agency puts out a draft rule, called an interim rule, and then asks for public comments. Based on these comments, the rule gets revised and made final.
I know I'm making the process sound rather wonky and lame, but the truth is that big, exciting things can happen in rulemaking. The organic program is a great example. USDA's 1997 draft rule for organics allowed organic food to be produced using GMOs and sewage sludge and to be irradiated. After a whole lot of mobilization and more than 275,000 public comments, the rule was revised to prohibit all three things and the final standard was immeasurably strengthened.
So this weekend, while you're lounging around waiting for the arrival of spring and looking for things to do in the meantime, there are four really important food and ag-related rules upon which you have the opportunity to comment. One is due Monday; we have more time for the others. We've covered all of these issues here on the blog. Comments don't have to be long and they don't have to be your finest work. They just need to state your case and tell the agency what you want them to do.
Below you will find links to talking points and instructions on how to submit a comment on National Animal ID, GMO regulations, milk protein concentrates, and money to CAFOs from the Environmental Quality Incentives Program. Pick your favorite or take them all on - the more you write, the better you'll feel!
1. National Animal ID - Comments due March 16 (that's Monday - sorry for the short notice). The National Animal ID System, or NAIS, is being sold as a food safety program that would track animals from the slaughterhouse back to the farm - so if an animal shows up to be processed and has some nasty, contagious disease, we'll know where it came from. The program has innumerable issues, some of which you can read about here. NAIS would require all livestock owners - even if you have only one cow - to pay for electronic tracking devices for their animals and register their premises with the government. The program is currently "voluntary," but there's a push to make it mandatory. The proposed rule doesn't technically mandate NAIS, but it essentially does; it prohibits producers from getting common veterinary vaccines and tests for their animals unless they enroll in NAIS.
It's time to submit comments on NAIS through the Organic Consumers Association (you send the letter via their website and they deliver it) or directly to the USDA by following the instructions on La Vida Locavore (click on the link that Jill provides and then on the symbol next to "add comments"). Both sites have great talking points that you can include in your comments. But time is short - comments are due by the end of the day on March 16.
2. Milk Protein Concentrates in yogurt - comments due March 31. Last week, I wrote about MPCs, a cheap, nasty and unregulated ingredient that's been displacing U.S. milk and dairy products to the benefit of dairy processing companies and to the great detriment of U.S. dairy farmers. The industry is already using MPCs in food products even though it's not approved by the FDA, but the biggest companies are also pushing the FDA to change the definition of certain dairy products so they'd legally be allowed to add MPCs. The newest challenge is to the definition of yogurt. The FDA needs to hear from us that yogurt shouldn't contain MPCs. You can read background on the yogurt proposal from The Milkweed [pdf] and follow their instructions for submitting a comment, or click through to the Federal Register via La Vida Locavore, where Jill provides you with some talking points and instructions. Go forth, milk defenders!
3. The Environmental Quality Incentives Program - comments due April 17. EQIP is a federal program that supports conservation and sustainable management practices on farms and ranches across the country. Unfortunately, since 2002, money from the program has been flowing like crap from a broken sewage line towards our nation's largest CAFOs. (For background, see Bonnie's kind writeup of a report I wrote for several Midwestern family farm organizations on EQIP and CAFOs.) The USDA has issued a proposed rule for EQIP and it's more of the same, with no limit on funding to new or expanding CAFOs and no instructions to track how big the operations receiving money are, or what they're doing with the funds. This has got to stop, and it might - if we all leave comments. Follow instructions and snag talking points from the National Sustainable Ag Coalition before April 17.
4. Regulation of genetically engineered crops - comments due sometime in May or June (stay tuned for updates). As we reported in our recommendations for the USDA's first 100 days, in its final hours, the Bush Administration proposed to significantly weaken the process for approving new GM crops for the commercial market. Thanks to the uproar generated by the good-food community, comments on the proposed changes will be accepted for another few months. You can find talking points and submit comments directly to the USDA through the website of the Center for Food Safety.
As my favorite food policy wise man, Mark Ritchie, once said, "Policy makes the future, but it’s only people who make policy." When we submit public comments, we are influencing laws that have already been passed, ensuring that they're implemented in ways that support our vision of a sustainable, just food system. It's critical followthrough. It's not that glamorous, but like most "on the ground" activities, it's pretty darn fulfilling nonetheless. Time to get our hands dirty!