Aquaculture Working Group chair asks for immediate appeals to Under Secretary Gary Ibach
For many years now, an appointed group of aquaculture experts called the Aquaculture Working Group has been advising the United States Department of Agriculture (USDA) on the development of standards for organic aquaculture. Our Aquaculture Working Group was appointed in 2005, and I was appointed to be the chair.
In 2010, after a major collaborative effort with AWG, the National Organic Standards Board recommended standards for organic aquaculture to the USDA National Organic Program for inclusion in the USDA Final Rule for organic food production that was authorized by the Organic Food Production Act of 1990.
Very slow progress and a major setback
The next step was for the USDA to advance the AWG/NOSB recommendations into Final Rulemaking as required under U.S. laws in order for them to become effective. For many reasons within USDA, little happened with the NOSB recommendations for a long time. Finally, in August 2016, with congressional and public urging, the USDA sent their proposed Final Rule to the U.S. Office of Management and Budget to obtain their required consent to publish their proposal for a Final Rule for organic aquaculture for public comment
Usually it takes 90 days for OMB to conclude such reviews. However, in our case approval to publish was not granted until December 2017, 16 months after submission. However, despite approval from OMB, USDA chose to not publish their proposed Final Rule for organic aquaculture before the change in administration on January 20, 2017. This was a major setback.
No progress under the new administration
Since the new administration has been in office our proposed rule has been on the USDA regulatory “inactive” list. It will take action by the Office of the Secretary of Agriculture Sonny Perdue to move the proposed Final Rule for organic aquaculture from the USDA inactive list to their active regulatory agenda. So far, the secretary has not been responsive to AWG requests to move forward and publish
Why is our rule on hold? Within the USDA there is an uninformed belief that there is no need for organic aquaculture products. They believe that nobody wants organic aquaculture products: Not consumers, not producers, not retailers, not restaurant owners. We are told “no one is interested, and no one cares.”
We know differently, however, and we need to communicate the need for organic aquaculture to the secretary and his staff in a major way. The adverse attitude within the USDA can only be changed by public, congressional and interagency communications with Secretary Perdue and his immediate staff.
Of particular importance is the very recent appointment of Greg Ibach as the Under Secretary of Agriculture for Marketing and Regulatory Programs. Although new to federal government service, I am informed that he is open-minded and wants to hear from the public on important matters. Our request of him is simple: Please publish the USDA proposed Final Rule for organic aquaculture for public comment without further delay.
The mailing address for Under Secretary Ibach is:
Hon. Greg Ibach,
Under Secretary of Agriculture for Marketing and Regulatory Programs
U.S. Department of Agriculture
1400 Independence Ave. S.W.
Washington, DC 20250
In your correspondence, I suggest that you include:
- Your position in aquaculture and seafood (consumer, retailer, producer, etc.).
- That you and others in the American public care and want organic aquaculture products.
- A statement on why organic certification for aquaculture is important (see below).
- Any other reasons (see below).
- Your request to “Please publish the USDA proposed Final Rule for organic aquaculture for public comment as soon as possible.”
Organic aquaculture standards needed
Our Aquaculture Working group of 12 professional aquaculture experts has been working with USDA since 2005 for the adoption of good organic aquaculture standards. We accepted this responsibility and have responded in good faith to do a good job. Over many years we have had the support of the aquaculture community: consumers, retailers, restaurant owners, fish farmers, and more. We need our good faith efforts to be honored by USDA.
Organic aquaculture products are the only food group that does not have access to the valuable USDA Organic label. Yet the USDA and our Health and Human Services Administration recommend that Americans eat two portions of seafood per week.
Large amounts of farmed seafood such as salmon, shrimp and mussels are now imported and sold under organic labels of the EU, Canada and foreign private certifiers. American consumers are buying large amounts of organic aquaculture products that are foreign grown by foreign farmers employing foreign agriculture workers.
With the availability of the USDA Organic label for aquaculture, U.S. fish farmers can earn premium prices and be able to successfully compete with foreign producers. New farms to serve new demand would be established, employing American workers. Foreign-grown aquaculture products bearing foreign organic labels would be barred from the U.S. marketplace. The domestic aquaculture industry will grow to fill this large market as well as create new consumption. The present situation is unfair to our domestic farmers and unfair to American consumers who are demanding USDA Organic certification for farmed fish and shellfish.
The USDA completed work on their proposed standards for organic aquaculture over one year ago after many years of delays and slow progress. The new administration is attempting to reduce bad, unnecessary and costly regulations for good reason. However, our proposed organic aquaculture regulation imposes no new costs on anyone and provides for the development of new markets with premium prices for American farmed fish grown by American workers.
Communicate directly with Under Secretary Ibach
In order for this administration to move forward with our rule it is necessary for many people to write Under Secretary Gary Ibach soon. He needs to receive letters requesting immediate publication of the USDA proposed Final Rule for organic aquaculture from consumers and consumer groups, retailers, distributors, chefs and restaurant owners, fish farmers, aquaculture suppliers, various state aquaculture and species associations, members of congress and the staffs of congressional committees.
Mr. Ibach also needs letters and other communication from our Federal Inter-Agency Aquaculture Working Group as a body and from its individual members; the aquaculture staffs and the chain of command in the USDA, the Department of Commerce and the Department of Interior; other departments and federal agencies including Sea Grant and extension agents throughout the country; state aquaculture coordinators; the aquaculture press and others. Aquaculture scientists who are federal and state government employees, and grant beneficiaries of federal aquaculture programs, are urged to write as interested individuals.
Time is of the essence!
A large number of people need to be heard from now with the message that there is a strong need for organic aquaculture standards in the United States. If we cannot dislodge this important rule, more than 13 years of determined efforts by many people will be lost and domestic consumers and farmers will lose this opportunity.
We need your help. Now is the time to act. Please write to Undersecretary Greg Ibach now. Please urge others to write as well.