Policy Letters

To ensure the integrity of organic farming and an equitable food system is maintained, we often submit letters to policy makers and institutions.

Here are a collection of letters that support our positions on various issues from labeling to genetically modified organisms to just food systems. 

To see NOFA-NY Policy Resolutions, please click here

To see Action Alerts, please click here

NOFA-NY letter on Student Loan Debt to HELP Committee (February 22, 2018)

Organic agriculture is one of the fastest growing segments of food and agriculture in New York, in both sales of organic products as well as organic acreage and farms. Organic is a growth opportunity for our farmers, yet our farmers are aging – the average age of New York farmers is 55, and young farmers are hampered by debt that limits their ability to own or grow their farm operation.

According to a 2017 national survey of young farmers in the U.S. conducted by the National Young Farmers Coalition, student loan debt is the #2 challenge young farmers face - second only to land access.

Read the full letter here.

NOFA-NY and NODPA letter to NY Congressional Delegation (November 9, 2017)

Organic dairy in the Northeast is in crisis. 2017 saw a massive drop in pay price for most producers, and an oversupply of organic milk that we anticipate will take until well into 2018 to adjust. Even though the Northeast is an organic milk deficit area, all producers have been hit by a $2.00-8.00 drop in pay price (a $10 drop for some by spring of 2018) and most have had a form of quota applied. Farm families have been hit twice: once with a 25% drop in pay price and then a restriction on how much milk they can produce. Despite the fact that retail sales of organic milk in the Northeast have increased, the national oversupply of milk has hit organic producers hard, many of whom have no safety net.

Read the full letter here.

GIPSA letter to President Trump (November 7, 2017)

On October 17, 2017, U.S. Secretary of Agriculture Sonny Perdue announced that he would withdraw two of the three rules collectively known as the Farmer Fair Practices Act, which would have restored the intent of the Packers & Stockyards Act (P&S Act) of 1921.1 While these rules were issued in 2016 under the prior administration, their development has been an ongoing process led by farmers and ranchers since 2010. The prior administration simply did not get the job done. You, Mr. President, have the opportunity to make the difference in the future of rural America and preserve America’s family farmers and ranchers.

Read the full letter here.

NOFA-NY's Comments to the National Organic Standards Board (October 11, 2017)

NOFA-NY strongly believes that the foundation of organic production, as laid out in the Organic Foods Production Act is in the natural ecological system based in the soil, and that it does not include the continuous inputs of fertilizers, nutrients, and other inputs to sustain the growing of organic crops.

Read the full letter here.

200+ Organization Letter to Congress on Agricultural Consolidation in 2018 Farm Bill (October 4, 2017)

U.S. farm income is significantly depressed, with disastrous ripple effects through our rural economy. Since the last Farm Bill debate, these trends have only worsened. As Congress starts the debate on the next Farm Bill, you must address negative trends in agricultural market control and anti-competitive business structures if we are to have any hope of restoring the economic health of rural America.

Read the full letter here.

Letter to Governor Andrew Cuomo regarding the release of the GE Moth (July 17, 2017)

On July 6, 2017 USDA/APHIS released a final environmental assessment (EA) and a Finding of No Significant Impact (FONSI) for an open air field release of genetically engineered diamondback moths and confirmed it will issue a permit to Cornell University for this release at the NYS Experiment Station in Geneva, NY.

Cornell’s plan is to release up to 30,000 Genetically Engineered male moths each week during the cabbage planting cycle (about three to four months), beginning the summer of 2017 into a 10-acre field at the Geneva Experiment Station. The males are genetically engineered with a lethal gene that they pass on to females when they mate, which causes the female offspring to die, usually as caterpillars directly on the food plants they target: broccoli, cabbage and other brassica. The males develop to moths and continue to mate. The researchers claim the released moths will not leave the site, even though Diamondback Moths arrived in New York from the south by traveling thousands of miles on wind currents.

Read the full letter here.

Letter to Secretary of Agriculture Sonny Perdue to support Organic Agriculture (July 12, 2017)

We are writing as farms, businesses, research centers and organizations representing a broad spectrum of perspectives about food and agriculture to express our strong, shared support for the USDA organic label and the federal marketing, research and data collection programs that support the label.

With the establishment of the National Organic Program in 2001, consistent national standards were created to govern the labeling of organic food and the use of the USDA organic seal. Consumer confidence in the integrity of the USDA organic seal has been a driving factor in the exponential growth in the organic sector. In 2000, organic sales of products labeled under various conflicting state and private organic labels totaled only $6 billion. Today, as a result of the establishment of the consistent federal organic standards, total sales of organic food and beverages are nearly $50 billion. Domestically, the organic sector is home to nearly 24,000 certified organic family farms and other businesses.

Read the full letter here.

NOFA-NY comments to the USDA regarding the Importation, Interstate Movement, and Environmental Release of Certain Genetically Engineered Organisms (June 19, 2017)

NOFA-NY submits the following comments in response to the APHIS proposed rule revising its regulations of genetically engineered (GE) organisms.

NOFA-NY believes that USDA has the authority provided by the Plant Protection Act to implement regulations to protect farmers, the environment, and our communities from unwanted harm and impacts from GE organisms. This proposal would significantly weaken existing regulations and provide loopholes that would deceive the public into believing that GE organisms are indeed being regulated adequately. We urge the Department to withdraw this proposal and use your authority to develop and implement stronger regulations to protect the citizens and the environment of the United States.

Click here for the full document.

Letter to Secretary Perdue and Members of Congress to Protect Funding for Programs that Benefit Organic Agriculture and the Organic Industry (June 15, 2017)

With the establishment of the National Organic Program in 2001, consistent national standards were created to govern the labeling of organic food and the use of the USDA organic seal. Consumer confidence in the integrity of the USDA organic seal has been a driving factor in the exponential growth in the organic sector. In 2000, organic sales of products labeled under various conflicting state and private organic labels totaled only $6 billion. Today, as a result of the establishment of the consistent federal organic standards, total sales of organic food and beverages are nearly $50 billion. Domestically, the organic sector is home to nearly 24,000 certified organic family farms and other businesses.

Organic farmers are required to use farming practices that preserve and enhance natural resources, and organic processors are required to use ingredients that have passed strict environmental and human health reviews. Consumers are willing to pay higher prices for products that meet these higher standards. As a result, organic farmers and processors enjoy a higher price to reward them for their extra costs and efforts.

Click here to read the full letter.

National Organic Program Organic Livestock and Poultry Practices Second Proposed Rule (June 5, 2017)

As we noted in our comprehensive comments to you in July 2016, attached and excerpted below, we strongly believe that these Organic Livestock and Poultry Practices Rules must be implemented as soon as possible.

Let us be clear: No further review is needed. NOFA-NY believes that the U.S. Department of Agriculture should follow through with its original intentions and implement Action Number (1): “Let the rule become effective. This means that the rule would become effective on November 14, 2017.” [FR Vol. 82, No. 89, May 10, 2017]. Do Not Delay.

Click here to read the full letter.

NOFA-NY comments on the December 2016 Environmental Assessment of the Proposal to permit the field release of genetically engineered diamondback moth in New York (May 19, 2017)

NOFA-NY objects to the short 30-day comment period for this Environmental Assessment, especially since April and May are in the middle of the planting window for New York State farmers. On April 21, NOFA requested an extension, but never received a response. This is unfortunate for the farmers of the region who may be significantly affected by these trials.

NOFA-NY considers the first-in-the-world open air release of the Genetically Engineered Diamondback moth – a novel organism – to be a major activity with potentially significant and heretofore unknown health and environmental effects. We have expressed concern about the proposed trials of the Genetically Engineered Diamondback Moth (GDM) for many years, and continue to be significantly troubled at the prospect of an open-air release of a novel organism in New York State without comprehensive health, safety, and environmental review. If approved, the proposed experiments would likely be the first to utilize GE insects with a female-killing trait anywhere in the world. Yet, the owner of this technology (originally, Oxitec UK – now Intrexon) has not completed comprehensive, independent health, safety, and environmental review required by international protocols.

Click here to read the full letter.

Written Statement on FY 2018 Appropriations Requests on behalf of the Seeds and Breeds for the 21st Century Coalition (May 15, 2017)

In recent decades, public resources for the development of improved plant varieties and cultivars have dwindled, while resources have shifted toward genomics and biotechnology, with a focus on a limited set of major crops.

Farmer access to regionally adapted seeds and breeds is paramount to fostering the competitiveness of agriculture in all regions of the U.S. As agricultural research has shifted toward an emphasis on lab-based and molecular breeding, seed choice has not kept up with demand, and the diversity of our plant genetic resources has narrowed. Farmers need access to seeds that are bred specifically for their regions and cropping systems. In particular, farmers lament limited cultivar options in major crops, especially publicly held seed varieties and plant cultivars released by land grant universities that are adapted to regional farming needs to satisfy the national market. By improving agricultural productivity and resilience, classical or field-based breeding also improves food security for our growing population.

Click here to read the full letter.

Letter Regarding the Proposed Merger of Monsanto Company and Bayer AG (May 9, 2017)

We are a group of 137 farmer, consumer, and environmental groups deeply concerned about growing concentration in the agricultural products sector and, in particular, about the proposed merger of Monsanto Company and Bayer AG.

As you know, the merger was proposed in the fall of last year and is currently under review by the Department of Justice (DOJ).

As you consider the nomination of Makan Delrahim to lead the Antitrust Division at DOJ we urge you to ensure that he will fully and skeptically evaluate the proposed merger, devote all necessary resources to the investigation, and hold the welfare of farmers, consumers, workers, and innovation foremost in his mind as he decides whether to block the merger.

Read the full letter here.

Letter of Request for Genetically Engineered Diamondback Moth data (April 19, 2017)

We write regarding the caged field trials of genetically engineered (GE) diamondback moths conducted at Cornell NYSAES in summer 2015. We are aware of the trials summary published online, however this leaves many unanswered questions about the findings of these trials. We are particularly interested in the actual data from the caged trials with GE DBM that took place in summer of 2015.

Read the full letter here.

Letter of NOFA-NY Organic Checkoff Comments (April 11, 2017)

NOFA–NY opposes the Organic Research, Promotion and Information Order submitted to the USDA by the Organic Trade Association because it is not farmer friendly, will benefit US organic sales, not production, and will negatively impact all organic certificate holders, whether or not they are assessed. Given its stated purposes, it is unlikely to benefit the growth, sustainability or profitability of organic farmers in the U.S., yet will require burdensome paperwork for all, and is an unfair tax.

Read the full letter here.

Letter of Support for the Young Farmer Success Act (April 6, 2017)

American agriculture faces a crisis of attrition. Two-thirds of our farmland is on the cusp of transition as farmers age and retire, and there are few young farmers positioned to manage this resource. Farmers over the age of 65 outnumber farmers under the age of 35 by a margin of 6-to-1, and the number of farmers under the age of 35 grew by only 1% between 2007 and 2012.

Read the full letter here.

Letter sent in Support of the Three Arrested Farmworkers (March 22, 2017)

In the past several years NOFA has had the distinct fortune of working with the Vermont-based Migrant Justice organization, whose stated mission “is to build the voice, capacity, and power of the farm worker community and engage community partners to organize for economic justice and human rights. We gather the farm worker community to discuss and analyze shared problems and to envision collective solutions.” In a number of aspects its work parallels that of NOFA, including farm worker issues about the dignity of work, achieving a livable wage, freedom from discrimination, and access to health care. These issues are endemic to farmworkers across the Northeast.

Read the full letter here.

Letter sent regarding 2018 Farm Bill (February 22, 2017)

The undersigned organizations, representing America’s agriculture, nutrition, conservation, rural development, finance, forestry, energy, trade, local government, plant/animal health, agricultural sciences and veterinary medicine,  labor, outdoor recreation, equipment manufacturing, cooperatives, hunters, anglers and crop insurance sectors, strongly urge you to reject calls for additional cuts to policies within the jurisdiction of the Senate Committee on Agriculture, Nutrition and Forestry or the House Committee on Agriculture.  

Read the full letter here.

Letter Opposing The Proposed Dow-DuPont, Monsanto-Bayer and Syngenta-ChemChina Mergers (February 13, 2017)

On behalf of our millions of members and supporters around the country, the undersigned organizations oppose the impending mergers of the world’s largest agrochemical and seed companies. The proposed mergers—of Dow Chemical with DuPont, Monsanto with Bayer AG, and Syngenta with ChemChina—are each problematic on their own, with many likely negative impacts on farmers, businesses, workers, and consumers. When taken together, they pose the threat of major oligopolistic outcomes in the industries of farming inputs, research, development, and technology. We urge the United States Department of Justice to conduct a thorough investigation to determine the impacts of these takeovers (alone and most importantly in combination) and to enjoin the mergers when it becomes clear that these impacts will prove detrimental to farmers, businesses, workers, consumers, the environment and our American food system.

Read the full letter here

Organizational Sign-on Letter Opposing Scott Pruitt for EPA Administrator (January 13, 2017)

We, the undersigned environmental, health, labor, faith, community, business, and advocacy organizations, and elected officials, write to urge your strong, unqualified, and robust opposition to Oklahoma Attorney General Scott Pruitt’s appointment to head the Environmental Protection Agency (EPA). Pruitt has a record of advocating against any and all protections for our water, air and climate. Allowing him to lead the EPA would not only be a disaster for the environment, but for every person in the United States who drinks water or breathes air.

Read the full letter here

Letter to Governor Cuomo (November 15, 2016)

NOFA-NY supports American Farmland Trust in the creation of a "Farmland for a New Generation" program.
"Agriculture in New York, like the nation, is undergoing a major transition as a new generation of farmers seek to enter farming. The Beginning Farmer Workgroup that you established in 2014, as well as reports by American Farmland Trust, American Farm Bureau Federation, GrowNYC, National Young Farmers Coalition, United States Department of Agriculture and others have identified that securing access to farmland is one of the greatest barriers facing new and next generation farmers in New York, and across America."
Read the full letter here
Read about the "Farmland for a New Generation" program here

Letter sent to National Organic Standards Board (October 26,2016)

NOFA-NY is a member of the National Organic Coalition (NOC) - a national alliance of organizations working to provide a "Washington voice" for farmers, ranchers, environmentalists, consumers and industry members involved in organic agriculture. The coalition works to assure that policies are fair, equitable, and encourage diversity of participation and access. In order to achieve this goal, NOC submits letters to the National Organic Standards Board (NOSB), which is the federal advisory board that considers and makes recommendations on a wide range of issues involving the production, handling, and processing of organic products. Please see our Fall 2016 letter to the NOSB.

Read the full letter here.

Letter sent in support of the Standing Rock Sioux Tribe's water protection efforts to halt the Dakota Access Pipeline (September 29, 2016).

NOFA-NY declares our solidarity with the Standing Rock Sioux Tribe’s opposition to the Dakota Access Pipeline. We affirm the treaty rights, tribal sovereignty, and protection of their lands, waters, cultural and sacred sites of the Standing Rock Sioux Tribe. We are grateful to the Native Peoples who are acting as protectors of our waters and lands and we pledge to stand with them for the sake of the healthy soils and clean waters necessary for healthy food production from our farms and gardens, and for life itself.

Read the letter here

Letter sent to the Cornell University College of Agriculture and Life Sciences regarding GE Diamondback Moth Trials (September 13, 2016)

Since spring 2015, NOFA-NY and our colleagues from Consumers Union, Food & Water Watch, Center for Food Safety, Friends Of the Earth, and Genewatch UK have been attempting to get answers to various questions regarding the permitting process – federal, state, and University – as well as impacts on health and environment regarding the proposed open air trials of the Genetically Engineered Diamondback moth (GDM) at the New York State Agriculture Experiment Station (NYSAES).  We have had good conversations with various people, but have not specifically received answers to questions we have continued to ask. 

Read the letter here

Letter regarding Okanagan Specialty Fruit GE non-browning “Arctic” Fuji apple (September 12, 2016)

One of the latest applications for GE foods comes Okanagan Specialty Fruit for their non-browning “Arctic” Fuji apple. NOFA-NY certifies 78 organic apple producers and four handler/processors who use organic apples in their products and we work to enhance the organic apple production, while fighting the invasion of GMO foods in our farm system. We requested that the USDA deny the application for these GE apples, based on the following rationale:

  • The Nature of Apples: It is the nature of apples to brown, indicating any damage it has incurred; thus, warning consumers of a potential problem.
  • Food Safety:  The intended market is pre-sliced, ready to eat apples, which is a frequently recalled food product, since the whole fruit is at risk of pathogens. No independent testing has been done on the safety or unintended consequences of silencing the genes that make apples turn brown when exposed to oxygen. Babies are the intended test market for these easy to use, pre-sliced apples.
  • Pollen and Gene Flow: The pollen gene flow from apple orchards is significant and accomplished by insects, including bees, which can become contaminated with GE pollen, and, thus jeopardize entire organic honey productions. In addition, it is unclear how pollen gene flow may contaminate organic apples, resulting in a loss of future markets, or even suspension of organic certification.
  • Consumer Preference: Avoidance of genetically engineered food is one of the explicit reasons that consumers purchase organic products. There is increased potential for GE apples to be purposely or inadvertently used in organic products, such as organic apple juice or apple sauce. 

Read the full letter here.

Sign the petition telling the USDA to say NO to the new GMO apple here

Letter to Commissioner Richard Ball regarding Farmland Protection (August 15, 2016)

We are writing to share our appreciation of Commissioner Ball’s leadership and to express our sincere thanks for the support given to protect farmland in New York.  The purchase of conservation easements on working farms has helped hundreds of farm families meet their goals and reinvest in the viability of their operations, while growing the state’s farm economy and bolstering local food production. This is an important year as 2016 is the 20th anniversary of the State of New York investing in protecting working farmland. We greatly appreciate the state’s allocation of $140 million to conserve approximately 60,000 acres of farmland on over 230 farms in 29 counties through the Farmland Protection Implementation Grant program (FPIG). This 20th anniversary was recently celebrated with a joint New York State Legislative Resolution commemorating the past two decades of state funding for protecting farmland. 

The process of completing these permanent farmland protection projects, which frequently involve multiple generations of farm families, local governments and private land trusts, can be intricate and time consuming.  The work that Governor Cuomo and the Department of Agriculture have invested in ensuring state-funded farmland conservation projects are completed at a quicker pace has been meaningful to farmers and to the conservation groups and local governments with whom they collaborate.  We urge the Department of Agriculture and Markets to make state funding for protecting farmland available on an annual basis to maintain the high level of interest among farmers as well as ensure a regular schedule of farmer PDR trainings as well as pre-application procedures and other activities conducted at the local level.  Ultimately, this regular annual application process will ensure the state receives high-quality projects that are poised to be completed quickly.

Read the full letter here   


National Organic Program Organic Livestock and Poultry Practices Proposed Rule (July 12, 2016)

It is a basic tenet of organic production for animals to be treated humanely, and consumers  believe that animals bearing the organic label have had significant access to the outdoors The final rule implementing Organic Foods Production Act, (OFPA) notes that animals should have living conditions “which accommodate the health and natural behavior of the livestock.” [regulation].  This is clearly stated in the law, the Regulations, as well as congressional intent language.

Indeed, the concept of accommodating health and natural behavior of animals is already a certifiable standard, and NOFA believes that additions to the regulations should enforce that principle as well as make it more consistently implemented, without losing each farm’s unique manner of complying with these standards. Successful organic systems rely on practices that attempt to approach natural systems, and therefore can be significantly different in terms of practices, feed, as well as genetics for livestock and poultry.  As organic evolves its standards to reflect these differences, we expect to see a decreasing reliance on conventional systems that are used with organic input substitutions, and an increase in wholly more organic, welfare-based sustainable systems.

Read the full letter here

New York State Minimum Wage Statement (July 2016)

Raising the minimum wage in New York State is a complex issue involving many interrelated parts that must be considered together. NOFA-NY does not provide blanket support of an increase in the minimum wage to $15 in NYS. It should not happen without due consideration of these interrelated parts. 

NOFA-NY advocates first for farmers to retain a larger share of the food dollar. Organic family farmers contribute much to their communities in the form of healthy food, carbon restored to the soil, cleaner environmental conditions, and healthy local economies. Yet these farmers are often compelled to augment their farm income by obtaining additional employment off the farm. It is only when they can earn a living wage from farming that they can securely and consistently provide higher wages to farm workers.

NOFA-NY is not just an organization of farmers and consumers, but also of farm workers. Many of our members who would identify themselves as farmers when given our usual breakdown of options—farmer, gardener, consumer—actually turn out to be interns, apprentices, farm workers, assistant managers, and farm managers. While their interests are not always identical with farm owners’, in this case NOFA-NY speaks for them all when we point out that the minimum wage has not kept pace with inflation.  Farm employees find it difficult to make financial ends meet and need to be compensated at a higher wage for the hard work they do. We believe these two issues are linked. 

NOFA-NY understands these are complex issues and is dedicated to working towards equitable solutions for the good of the local, organic, food system.