他是代表1992年签署于1992年的40名前NOSB成员的讲话。Cornucopia Directors，Goldie Caughlan和Kevin Engelbert和我们的三个顾问博士Joan Dye Gussow博士博士Kirschenmann博士和Jennifer Taylor博士是向美国农业部秘书Vilsack发言的签名者之一。
Read the letter below (PDF版本）：
Dear Secretary Vilsack:
In the last eleven years, the National Organic Program has failed to successfully bring a number of key NOSB recommendations to rulemaking. This failure has led to real damage to trust in and the integrity of the organic program, as the NOP has failed to respond to serious challenges to the meaning of organic from industry. We urge you to take immediate action on the following NOSB recommendations;
- 容器和围栏中陆地植物的生产标准（温室），passed in 2010. This recommendation called for the prohibition of hydroponic production in the organic program: “systems of crop production that eliminate soil from the system, such as hydroponics or aeroponics, can not be considered as examples of acceptable organic farming practices. Hydroponics, the production of plants in nutrient rich solutions or moist inert material, or aeroponics, a variation in which plant roots are suspended in air and continually misted with nutrient solution, have their place in production agriculture, but certainly cannot be classified as certified organic growing methods due to their exclusion of the soil-plant ecology intrinsic to organic farming systems and USDA/NOP regulations governing them.” The NOP issued a statement that they “will develop a proposed rule based on the NOSB final recommendations” on September 30, 2010. This was followed with inaction until 2014, when they issued the statement saying that hydroponic production is now allowed in organic certification. This was followed by a resolution passed by the NOSB in 2016 reaffirming the 2010 NOSB recommendation.
- 美国农业部发布了一项拟议的规则，以关闭与“起源”相关的漏洞Livestock’ (80 FR 23455) in 2015。The proposed Rule would clarify that: “After completion of a one-time, 12-month transition period of an existing conventional dairy herd (or livestock to form new organic dairy operations), all new dairy animals milked on the organic dairy farm would need to be managed organically from the last third of gestation.” Unfortunately, the 2015 rule has never been finalized. Congress included a provision in the Fiscal Year 2020 Agriculture Appropriations bill requiring USDA to finalize the long-delayed rule by June 17, 2020. USDA missed that deadline. On October 21, 2020, the NOP announced plans to publish another Proposed Rule to address enforcement issues raised by USDA’s Office of General Counsel, instead of moving directly to a final rule as required by Congress. NOP has failed to provide a timeframe for issuing the new regulations that are fully enforceable.
- 国家有机计划（NOP）最终确定了一套全面的动物福利标准，称为有机牲畜和家禽实践（OLPP）规则2017年1月。The rule, originally set to take effect in March 2017, was written with broad input from the organic community, and is supported by the vast majority of organic farmers, businesses, consumers, and advocacy organizations. The rule was rejected by the Trump administration. The OLPP should be immediately reinstated in its final form.
- The Pasture Compliance Program。由于大型CAFO行动牧场规则的高度公开例子，美国农业部有机密封的公众信托正在摇摇欲坠。华盛顿邮政的2017年系列文章给这个问题带来了巨大的审查。这些大型生产者应该是规则的举例。
- Grain Fraud.Despite significant Congressional funding to stop fraud in imported grain certified as organic, there has been little regulatory action taken to alter this failure. Action should be taken immediately to protect both American farmers and consumers.
Signed by the following former members of the National Organic Standards Board:
Fred Kirschenmann (1995- 2000)
Eric Sideman (1997-2002)
Goldie Caughlan (2001-2006)
Ann Cooper (2002-2004)
Dennis Holbrook (2002-2007)
Joe Smilie (2006-2011)
Steve DeMuri (2007-2012)
Barry Flamm (2008-2013)
Wendy Fulwider (2010-2015)
Joe Dickson (2010-2015)
Calvin Reuben Walker（2011-2016）
Robert (Mac) Stone (2011-2016)
Colehour Bondera (2011-2016)
Harold Austin (2012-2017)
Harriet Behar (2016-2020)
Jesse Buie (2016-2021)
Dan Seitz (2016-2021)