Policy Comments
April 18, 2013 NOC FY2014 Senate Agriculture Appropriations Testimony
April 17, 2013 House Organic Caucus Letter to the House Ag Appropriations Subcommittee Calling for Funding of Organic Programs in the FY 2014 budget
March 20, 2013 NOC FY2014 House Agriculture Appropriations Testimony
March 11, 2013 NOC Comments on Antibiotics
January 29, 2013 NOC Letter to National Organic Program regarding GMO Vaccines
January 29, 2013 NOC Letter to National Organic Program and National Organic Standards Board Regarding discussions by the Board during NOSB public meetings.
January 29, 2013 NOC Letter to Secretary Vilsack Regarding Public Cultivars
January 21, 2013 NOC Letter to National Organic Standards Board Regarding Confidential Business Information
January 8, 2013 NOC Comments to Secretary Vilsack
December 26, 2012 NOC Comments to USDA on Sunset Review of Nutrient Vitamins and Minerals
November 23, 2012 NOC Press Release Regarding USDA Advisory Committee on Biotechnology and 21st Century Agriculture (AC21)
November 7, 2012 NOC Letter to Secretary Vilsack regarding USDA Advisory Committee on Biotechnology and 21st Century Agriculture (AC21)
October 10, 2012 NOC Letter to National Organic Program Regarding Aquaculture Standards
September 24, 2012
NOC Comments to National Organic Standards Board, September 2012
Comments from Center for Food Safety to National Organic Standards Board, September 2012
August 2012 | Comments to USDA/AC21 Committee on Biotechnology
NOC Comments to USDA/AC21 Committee on Biotechnology, August 2012
FWW Comments to USDA/AC21 Committee on Biotechnology, August 2012
MOSES Comments to USDA/AC21 Committee on Biotechnology, August 2012
Beyond Pesticides Comments to USDA/AC21 Committee on Biotechnology, August 2012
Center for Food Safety Comments to USDA/AC21 Committee on Biotechnology, August 2012
Organic Seed Alliance Comments to USDA/AC21 Committee on Biotechnology, August 2012
June 5, 2012
Sign on letter from 100 agricultural businesses, organizations, and scientists asking for support of Senator Tester’s amendment to the Senate Farm Bill to designate a small percentage of the USDA's Agriculture and Food Research Initiative budget for classical plant and animal breeding.
May 22, 2012
NOC Testimony to the National Organic Standards Board, May 22, 2012
May 8, 2012
Testimony of NOC member, Russell Libby, Executive Director, Maine Organic Farmers & Gardeners Association, before the Subcommittee on Nutrition and Horticulture, Agriculture Committee,U.S. House of Representatives, May 8, 2012: “Small Changes Make Big Differences on the Ground”
May 3, 2012
NOC Comments to the National Organic Standards Board Docket, May, 2012
March 29, 2012
NOC FY2013 Senate Agriculture Appropriations Testimony
March 22, 2012
NOC letter to AFRI re: "Prospective Comments on FY 2013 RFA for Agriculture and Food Research Initiative" regarding Public Plant and Animal Breeding
January 31, 2012
NOC letter to Kathleen Merrigan regarding National Genetic Resources Advisory Committee (NGRAC)
January 27, 2012
NOC follow up with Kathleen Merrigan regarding the Agriculture and Food Research Initiative (AFRI) and the importance of that program for meeting classical breeding and public needs
November 13, 2011
NOC FINAL NOSB COMMENTS 11-13-11
NOSB Principles of Organic Production, 2001
November 13, 2011
Comments to NOSB from Food and Water Watch on Aquaculture Organic Standards.
November 13, 2011
Comments to NOSB from Center for Food Safety
October 25, 2011
Letter to House and Senate Agriculture Committee Leaders, with over 300 names, asking to keeping funding for Organic Programs in the Farm Bill.
September 16, 2011
Letter to Secretary Vilsack on behalf of the 139 organizations representing thousands of American farmers, consumers, and retailers, asking him to implement his authority under the Plant Protection Act of 2000 (PPA) to fully protect the public health, the environment, and the economic interests of the United States.
August 12, 2011
Organic Seed Alliance response to USDA National Organic Program “Draft Guidance: Seeds, Annual Seedlings, and Planting Stock in Organic Crop Production” (June 13, 2011)
August 3, 2011
Detailed letter to USDA regarding APHIS implementation of the Plant Protection Act of 2000
August 3, 2011
Sign-on Letter to USDA's Grain Inspectors Packers and Stockyards Administration asking for Congress to allow USDA to move forward on regulation to strengthen and clarify the Packers and Stockyards Act with protections for farmers and ranchers.
July 28, 2011
NOC Comments to USDA on National Leafy Greens Marketing Agreement
June 28, 2011
NOC Comments on Periodic Residue Testing Proposed Rule AMS–NOP–10–0102; NOP–10–10
June 16, 2011
NOC Testimony submitted to the Senate Subcommittee on Agriculture, Rural Development, Food and Drug Administration, and Related Agencies regarding Fiscal Year 2012 Appropriations Requests
June 15, 2011
Memo to USDA: AFRI Classical Breeding Analysis
May 31, 2011
NOC 2012 Farm Bill Testimony for Senate Agriculture Committee at Michigan Field Hearing
April 2011
NOC Comments to National Organic Standards Board - (NOSB) April 2011
March 1, 2011
Letter to the Senate regarding FY 2011 Appropriations Cuts to Rural America.
February 9, 2011
Letter to "Republican Study Committee" supporting National Organic Certification Cost Share Program
February 7, 2011
NOC Comments to USDA/ARC on proposed changes to ARC 1012
January 24, 2011
NOC Comments to GE Alfalfa FEIS
January 7, 2011
Letter to Secretary Vilsack regarding the GE Alfalfa FEIS stakeholder process.
December 6, 2010
NOC's Comments on NOP draft guidance policies 5021, 5022, 5024, 5025, and 5026
December 6, 2010
NOC Comments to USDA strongly opposing USDA's proposal to allow the commercial planting and sale of genetically engineered, "Roundup Ready" sugar beets before the agency has completed the court-ordered review of that crop's impacts (Docket No. APHIS-2010-0047).
November 24, 2010
Letter to Catherine Woteki, (USDA Under Secretary for Research, Education and Economics), regarding the importance of the Agriculture and Food Research Initiative (AFRI) investments in classical plant and animal breeding, signed by the National Organic Coalition, National Sustainable Agriculture Coalition, Organic Farming Research Foundation, Organic Trade Association, Rural Advancement Foundation International, and Union of Concerned Scientists.
November 22, 2010
NOC Comments to FDA on GE Salmon labeling.
October 21, 2010
NOC's comments to the Federal Register on DL Methionine.
October 13, 2010
NOC's comments to National Organic Standards Board - (NOSB) October 2010.
September 30, 2010
Letter to Miles McEvoy regarding Cloning -- supporting the NOSB recommendation prohibiting cloned animals and their progeny in organic food
September 24, 2010
National Sustainable Agriculture Coalition (NSAC) letter to Secretary Vilsack regarding a resolution adopted at the NSAC meeting. One of the points in the resolution was that the USDA AFRI needed to increase classical breeding for public cultivars and that this work should be funded through a separate RFA.
September 15, 2010
NOC Testifies before the Senate Committee on Agriculture, Nutrition and Forestry. For the hearing: "The National Organic Law at 20: Sowing Seeds for a Bright Future"
July 21, 2010
NOC Testimony to the Subcommittee on Horticulture and Organic Programs House Committee on Agriculture for the hearing to Review Specialty Crop and Organic Agriculture Program in Advance of the 2012 Farm Bill
July 12, 2010
NOC Comments to FDA Docket No.Docket No. FDA 2010 N 0085: Preventive Controls for Fresh Produce.
NOC Attachments to Comments [Referenced Food Safety Studies] to FDA Docket No.Docket No. FDA 2010 N 0085: Preventive Controls for Fresh Produce.
June 7, 2010
Union of Concerned Scientists submits written comments in response to the June 2, 2010 AFRI stakeholder meeting recommending the AFRI FY11 RFA fund classical breeding through a funding line distinct from genomics and other technologies
May 2010
NOC joins over 140 organizations signing on to a letter submitted by Pesticide Action Network North America (PANNA) to make sure that The Global Food Security Act (H.R.3077) remains technologically neutral and does not include a clause mandating research funding for one particular agricultural technology (genetically modified crops).
April 20, 2010
NOC signed on to Consumers Union letter to FDA/USDA about the US position [Codex] on GE/GM labeling
April 19, 2010
NOC Comments on NOP "Access to Pasture Rule" Including NOC proposal for an "Organic Grassfed Label."
April 13, 2010
Union of Concerned Scientists submits written comments for the USDA workshop on stakeholder priorities in the area of Plant and Pest Biology recommending NIFA play a more active role in reinvigorating breeding of public cultivars.
March 19, 2010
Press Release - NOC Enthusiastic about USDA/OIG Report on National Organic Program
March 19, 2010
NOC Testimony to House on FY 2011 Appropriations
March 17, 2010
NOC's letter to Blanche Lincoln, Chairman; Committee on Agriculture, Nutrition, and Forestry urging to include language in the Child Nutrition Reauthorization bill to remove the barriers of access to organic foods within the WIC program.
March 3, 2010
Comments on the Draft Environmental Impact Statement (EIS) Recommending the Deregulation of Genetically Engineered Alfalfa, Docket No. APHIS-2007-0044
January 27, 2010
Letter to Secretary Vilsack, copied to Dr. Kathleen Merrigan, Deputy Secretary; Dr. Molly Jahn, Acting Under Secretary; Dr. Roger Beachy, NIFA Director signed by the National Organic Coalition, National Sustainable Agriculture Coalition, Organic Farming Research Foundation, Rural Advancement Foundation International, and Union of Concerned Scientists urging segregated funding streams in the FY 10 RFA for conventional plant and animal breeding.
January 27, 2010
Post-Hearing brief on proposed Leafy Green Marketing Agreement (NOC and FWW)
January 4, 2010
NOC's Comments on Guides to Minimize Microbial Food Safety Hazards
January 4, 2010
Food and Water Watch comments to FDA Guidance on Melons
January 4, 2010
Food and Water Watch comments to FDA Guidance on Leafy Greens
January 4, 2010
Food and Water Watch comments to FDA Guidance on Tomatoes
December 7, 2009
In a letter to Dr. Beachy, specific recommendations for Establishment of AFRI Conventional Plant and Animal Breeding Programs were offered by the National Organic Coalition, National Sustainable Agriculture Coalition, Organic Farming Research Foundation, Seeds and Breeds for the 21st Century Coalition, and Union of Concerned Scientists
November 2, 2009
Comments of NOC to the National Organic Standards Board
November 1, 2009
Letter to Senate Finance Committee on the nomination of Mr. Siddiqui to the USTR.
October 28, 2009
OFRF Comments: CSP Interim Final Rule
October 27, 2009
NOC letter to Senator Stabenow regarding the Senator's draft legislation regarding allowable agriculture and forestry offset credits for climate change legislation.
September 14, 2009
Sign-on letter of comments regarding the implementation of the Cooperative State Research, Education, and Extension Service (CSREES) Agriculture and Food Research Initiative (AFRI), as authorized by the 2008 Farm Bill.
September 11, 2009
National Sustainable Agriculture Coalition written comments on fiscal year 2009 AFRI RFA strongly recommended that two new, separate national programs for conventional plant and animal breeding be established within AFRI, beginning with the FY 10 RFA.
August 11, 2009
NOC Comments to NRCS regarding Conservation Practice Standard
August 11, 2009
OFRF Substantive Comments to NRCS regarding Conservation Practice Standard to which NOC is a signatory
View Comments
August 6, 2009
USDA Seeks Independent Oversight of National Organic Program
NOC press release
July 13, 2009
Letter to Senate Agriculture Committee on Climate Change
July 13, 2009
Letter to Senate environment and Public Works Committee on Climate Change
June 29, 2009
NOC and CFS Sign-on letter (nearly 200 signators) to USDA/APHIS regarding The Proposed Rule and Programmatic Environmental Impact Satement for the Introduction of Genetically Engineered Organisms, APHIS Docket 2008-0023.
May 31, 2009
National Sustainable Agriculture Coalition letter to Research, Education, and Extension Office (REEO) Directors recommended the USDA REEO Roadmap include increased coordination and major investments in classical plant and animal breeding.
May 4, 2009
NOC Comments to the National Organic Standards Board on several topics related to the NOSB Agenda.
April 22, 2009
NOC testimony submitted to the House Subcommittee on Agriculture, Rural Development, Food and Drug Administration, and Related Agencies regarding Fiscal Year 2010 Appropriations Requests.
April 20, 2009
NOC Comments to the National Organic Standards Board on the "Peer Review Panel" and NOP compliance with Accreditation standards, ISO 17011 (formerly 61).
April 16, 2009
NOC Comments on the Organic Conversion Assistance program within the NRCS Environmental Quality Incentives Program, recently passed in the 2008 Farm Bill
April 13, 2009
Memo to Carol Jett from UCS, NSAC, and OFRF, in follow up to a request made for additional information on the groups’ recommendations for classical breeding.
March 6, 2009
NOC comments to the USDA Audit Review and Compliance Branch (ARC) regarding recent changes to its auditing procedures.
December 22, 2008
NOC comments to USDA NOP on the Proposed Access to Pasture Rule with suggested changes to the Proposed Rule, and support for the line-by-line changes suggested by Federation of Organic Dairy Farmers (FOOD Farmers).
November 3, 2008
Food and Water Watch comments to the National Organic Standards Board Livestock Committee's proposed organic aquaculture standards, specifically the recommendations on "Fish Feed and Related Management Issues" and "Net Pens and Related Management Issues"
September 2008
Union of Concerned Scientists stakeholder comments to CSREES on the Agriculture and Food Research Initiative (AFRI), urging significant funding for classical breeding.
September 24, 2008
NOC comments to CSREES on the Agriculture and Food Research Initiative (AFRI) newly authorized in the 2008 Farm Bill regarding the provisions of the Act which specify conventional plant and animal breeding as a priority area of research within AFRI.
September 23, 2008
NOC letter expressing concern about a "Sustainable Agriculture Label" to the members of the Leonardo Academy's "Sustainable Agriculture Draft Standard for Trial Use Standards Committee"
September 19, 2008
National Certification Cost Share letter to USDA Agriculture Marketing Service (AMS) from various organizations.
September 19, 2008
Sustainable Agriculture Coalition letter to Dr. Hefferan following USDA Listening Session on AFRI recommending AFRI establish two new national programs for conventional plant and animal breeding beginning with the FY 09 RFA.
May 20, 2008
NOC Comments to the National Organic Standards Board May 2008 meeting regarding materials being reviewed by the board.
May 20, 2008
NOC Comments to the National Organic Standards Board May 2008 meeting regarding the certification of Grower Groups.
March 7, 2008
NOC testimony to the Senate Subcommittee on Agriculture, Rural Development, Food and Drug Administration, and Related Agencies regarding Fiscal Year 2009 Appropriations Requests
March 12, 2008
NOC testimony to the House Subcommittee on Agriculture, Rural Development, Food and Drug Administration, and Related Agencies regarding Fiscal Year 2009 Appropriations Requests
February 14, 2008
NOC letter to House and Senate Farm Bill conferees urging inclusion of the organic conversion program with mandatory access to funding in the 2008 Farm Bill.
February 6, 2008
NOC letter to House and Senate Farm Bill conferees opposing the specialty crop marketing provision in the House version of the Farm Bill
November 12, 2007
NOC comments to the National Organic Standards Board regarding organic certification of "grower-groups" and multi-site operations
July 17, 2007
Letter to Representative Kagen supporting his amendment to the 2007 Farm Bill to increase funding for organic research
July 13, 2007
CFS and allied consumer organizations letter supporting mandatory implementation of country of origin labeling (COOL).
June 18, 2007
Letter to Chairman of the House Agriculture Committee opposing section 123 of the House Farm Bill
April 25, 2007
National Organic Coalition letter to USDA Secretary Johanns regarding grower group certification under USDA organic standards
April 24, 2007
NOC Testimony of Kathy Arnold, Twin Oaks Dairy, before the Senate Committee on Agriculture, Nutrition and Forestry addressing the economic challenges and opportunities faced by American agricultural producers
April 18, 2007
NOC Testimony of Bea James, National Cooperative Grocers Association, before the House Committee on Agriculture, Subcommittee on Specialty Crops and Organic Programs, hearing on Organic Agriculture and Rural Development
March 4, 2007
Testimony of NOC's Legislative Coordinator Steve Etka before the House Subcommittee on Agriculture, Rural Development, Food and Drug Administration and related agencies, regarding the fiscal year 2008 appropriations request
View NOC FY08 Appropriations Request Chart
December 22, 2006
NOC letter to the USDA Agricultural Marketing Service supporting clear, objective, and enforceable pasture standards for organic livestock
March 30, 2006
NOCcomments to Congress on FY 2007 organic agriculture appropriations.
May 20, 2005
NOC letter to the National Organic Standards Board regarding pasture requirements for organic livestock production