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Summer 2017 Newsletter

Friends and colleagues,

I hope your summer has gotten off to a great start!  Karlin Strategic Consulting LLC has had a busy few months, providing strategic advice and counsel, regulatory and policy advocacy, and wellness and sustainability programming.  Keep in touch with us by subscribing to our newsletterfollowing us on Twitter, and liking us on Facebook!

In particular, the last few months we have advised stakeholders across the supply chain on a variety of issues, from food and agriculture policy to coalition building to strategic business planning.

We have worked with clients to:

How else can we work together to reach our common goals?


  • Can we work together on strategic planning that will allow your business to grow and prosper?  Karlin Strategic Consulting LLC has experience in crafting bylaws and other foundational documents that enable businesses to operate most effectively; as well as Board engagement and management.
  • Can we work together to craft and implement a policy strategy as the new Administration and the 115th Congress continue their work?  We have extensive private and public sector experience in developing and implementing policy strategies in the executive and legislative branches – from drafting legislative or administrative rule language, to identifying champions, to bringing together coalitions, to engaging broad public support.
  • Can we work together to draft responses to the 30 questions USDA published earlier this week regarding GMO labeling?  These questions are a first step in USDA’s response to the Congressional mandate to complete a study on digital or electronic disclosure by July 29, 2017, and implement a labeling standard by Summer 2018.  USDA is expected to publish a proposed rule for public comment later this year, which will provide another great opportunity for input.  Answers to these questions are requested by July 17 – so be in touch today if you’d like our help in drafting your response.
  • Can we work together to consider the impacts of the pending Amazon acquisition of Whole Foods Market, and weigh in with regulators where appropriate?  These impacts could be on your business directly, or more generally on access to organic and other specialty consumers and the continued growth and development of that market, or the impact on the supply chain of further expanding access to organic products – and will be considered by congressional Judiciary Committees as well as the Antitrust Division of the Department of Justice.  Karlin Strategic Consulting LLC has a wealth of experience in both antitrust law and policy, and the organic market, and we are well-positioned to meet your strategic advocacy and planning needs.
  • Can we work together to create and implement an advocacy strategy in advance of the Fall National Organic Standards Board meeting Although discussion documents and proposals for the meeting won’t be posted until late August or early September, the comment docket is officially open, and we expect the Board to consider whether to continue to allow a variety of fertilizers, treatments, products, processing aids, and ingredients in organic production.  We also expect the Board to continue to consider container production in organic; as well as whether hydroponic/aquaponic production may be certified organic.
  • Can we work together to add a food and nutrition component to your corporate wellness or sustainability program?  We have developed food, nutrition, and cooking curricula and training programs for a variety of audiences.  These programs lead to higher business performance; lower expenditures on healthcare; and improved employee morale, engagement, and retention.  Karlin Strategic Consulting LLC can create a food and nutrition program to fit your wellness or sustainability program; and tailored to your specific needs – whether it be a mobile app, a webinar, an in-person training, or some other partnership.

How else can Karlin Strategic Consulting LLC help you achieve your goals?  Let us know!  We look forward to the opportunity to continue to work with you.

All best,
Marni
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Organic’s Growing Size and Market Share Brings Political Clout

Growth in organic, attacked by some in the sector, brings with it political power and should be embraced, said Kathleen Merrigan, former Deputy Secretary of Agriculture who played a major role in writing the Organic Foods Production Act while a Senate aide. “Let’s celebrate that we are Big Food with Values,” she said.

Growing to about 5% of U.S. food sales, and with sector participation from small mom-and-pop farms to billion dollar businesses, there is a tension about being called “Big Food”. But that big-ness may help the sector fight any political challenges in the coming years – and should be celebrated for its role in getting organic a seat at the table.

The size of the sector and its growing popularity will make it more difficult for competitors in conventional agriculture to convince Trump administration officials to lower the government standards that give consumers confidence in the USDA certified organic label or to reduce the research funding that the industry has strived hard to achieve.

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Organic Research Needs Identified; Can Be Met Through Combination of Federal and Industry Funding

The Organic Farming Research Foundation (OFRF) has developed an extensive report on challenges in organic farming, as well as recommendations to address those challenges, to ensure research funding is relevant and responsive to the needs of organic farmers.

The report identifies such challenges as increasing transition to organic and organic acreage in the United States, as well as needs for agronomic research on new practices and tools to address challenges in organic farming systems. In particular, OFRF identified soil health and weed management as top organic research priorities, followed by fertility and nutrient management, nutritional quality of organic food, and insect management. It also noted other concerns, including climate change, food safety, the impacts of GMOs, seed availability, pollinator health, and barriers to market entry. The report also noted regional priorities such as irrigation efficiency and coping with drought in the West.

The OFRF report calls for federal research funding at least proportionate to the organic sector’s market share, which is about 5-6% of U.S. food sales. However, faced with a Trump budget proposal that would cut USDA’s budget by 21%, it is pragmatic to consider other methods for meeting these needs.

Another mechanism for addressing the organic sector’s research needs is an organic research and promotion order, or checkoff. A checkoff program would allow the sector to pool its resources to address research, promotion, and technical assistance needs of the sector as a whole. Moreover, some federal research funds are only available if the sector puts forward matching funds – which would be possible with a checkoff. The organic checkoff proposal is in the comment process as we speak, with USDA accepting comments until April 19. Click here to submit your comment, or here to reach out to Karlin Consulting for assistance in crafting a comment.

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USDA Publishes National Organic Standards Board Proposals in Advance of April Meeting

In advance of the National Organic Standards Board (NOSB) meeting scheduled for April 19-21 in Denver, Colorado, USDA last week published a revised agenda and meeting materials.  The meeting will include the first discussion of substances that are scheduled to sunset from the National List in 2019, as well as a proposal on organic seed guidance, and a discussion document on aeroponics, hydroponics, and aquaponics.

Written comments are due to USDA by March 30, and the public is invited to register to provide oral comment either in-person or during a webinar on April 13.  Visit the Spring 2017 NOSB website to register to provide comments, or contact us if you’d like help!

Karlin Strategic Consulting will be at the Denver meeting – looking forward to advocating for the continued strength of the organic regulations; and to connecting with certified organic operations!

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House and Senate Kick Off Agriculture Work with Hearings on 2018 Farm Bill and Appropriations

In recent weeks, the debate around the next Farm Bill – which will be up for reauthorization next year – has begun on Capitol Hill and in the field. The Senate Agriculture Committee held a Farm Bill hearing in Kansas (home to Chairman Pat Roberts), and the House Agriculture Committee has held subcommittee hearings on the next Farm Bill on conservation, international markets, rural development and energy, and specialty crops. Farm Bill hearings are noticed in the House Agriculture Committee for next week on agricultural research and forestry.

Also, the Agriculture Appropriations Subcommittee of the House Appropriations Committee held its first hearing to take a closer look at farm credit and lending programs.

Senate Ag Committee Hearing in the Heartland

Last month, the Senate Agriculture Committee traveled to Manhattan, Kansas, to kick off its 2018 Farm Bill hearings.  The hearing focused on general perspectives on the Farm Bill from Kansas.  The Committee will no doubt hold additional hearings on various titles of the Farm Bill in D.C. as the year continues.

In Kansas, the Committee heard from three panels of witnesses. The Welcome Panel consisted of General Richard Myers, President of Kansas State University; Congressman Roger Marshall; and Jackie McClaskey, Secretary of the Kansas State Department of Agriculture. Panel I included Kansas family farmers David Clawson, Lynda Foster, Amy France, Lucas Heinen, Tom Lahey, Kent Moore, Cameron Peirce, Michael Springer, Kenneth Wood, and Kent Winter.  Panel II included Shan Hanes, representing First National Bank of Elkhart; Catherine Moyer, of Pioneer Communications; Kathleen O’Brien, of Nemaha-Marshall Electric Cooperative; Gena Ott, representing Frontier Farm Credit; Derek Peine, of Renew Kansas; Greg Ruehle, representing Servi-Tech; Clay Scott, of Kansas Water Congress; and Cherise Tieben, City Manager of Dodge City, Kansas.

House Ag Committee Hearing on Conservation

At the House Subcommittee’s conservation hearing, Subcommittee Chairman Frank Lucas (R-OK) noted that USDA conservation programs are critical. “I’m proud of the work of the farmers, ranchers and forest owners who implement these important conservation practices,” Lucas said. “I think the results speak for themselves—voluntary conservation works.” Conservation Subcommittee Ranking Member Marcia Fudge (D-OH) noted that the 2014 Farm Bill cut conservation program spending by $6 billion; and further cuts in the upcoming reauthorization would hamstring conservation efforts.

The Subcommittee heard from five witnesses: Chuck Coffey, a rancher from Oklahoma, representing the National Cattlemen’s Beef Association; Timothy Gertson, a rice farmer from Texas, representing the USA Rice Federation; Jeremy Peters, the CEO of the National Association of Conservation Districts; Dave Nomsen, Vice President of Government Affairs for Pheasants Forever; and John Piotti, President of American Farmland Trust.

Both Coffey and Gertson spent much of their time talking about the importance of working lands conservation programs, including the Conservation Stewardship Program (CSP) and Environmental Quality Incentives Program (EQIP).

House Ag Committee Hearing on International Markets

Last month, the House Agriculture Subcommittee on Livestock and Foreign Agriculture held a hearing on international markets. At that hearing, the Subcommittee heard from six witnesses: Gary Williams, professor of Agricultural Economics at Texas A&M University; Joseph Steinkamp, on behalf of the Coalition to Promote U.S. Agriculture Exports and the Agribusiness Coalition for Foreign Market Development; Tim Hamilton, of Food Export Midwest and Food Export Northeast; Philip Seng, of the U.S. Meat Export Federation; Dean Alanko, on behalf of the Hardwood Federation; and Paul Wenger, almond grower and President, California Farm Bureau.

The hearing was designed to give organizations who receive funding from trade promotion and market development programs a platform to discuss the continued need for the programs and the innovative ways in which they use them to establish and enhance markets for U.S. agricultural products overseas.

House Ag Committee Hearing on Rural Development and Energy Programs

At the House Subcommittee’s hearing on rural development and energy programs, Subcommittee Chairman Austin Scott spoke about the rural development and energy programs that “support infrastructure construction, encourage capital formation, and help to promote economic development across rural America.” He noted that so much of what rural America will be able to accomplish will be tied to how well these programs work. He spoke about reversing the cycle of young people in rural America leaving their communities for what they perceive to be greater opportunities elsewhere.

The Subcommittee heard from Bob Fox, on behalf of National Association of Counties; Dennis Chastain, on behalf of National Rurual Electric Cooperative Association; Steve Fletcher, on behalf of National Rural Water Association; Craig Cook, on behalf of The Rural Broadband Association; John Duff, representing National Sorghum Producers; and Jim Greenwood, representing Biotechnology Innovation Organization.

House Ag Committee Hearing on Specialty Crops

Last week, the House Agriculture Subcommittee on Biotechnology, Horticulture and Research held a hearing on specialty crops issues in the Farm Bill.  The lineup of witnesses included five farmers or packers of fruits and vegetables (including two organic representatives). They spoke of issues including the need for a legal agriculture guest worker program (immigration reform), funding for specialty crop research and marketing (including research on citrus greening), food safety, organic research, and organic certification cost share.

One witness, Sean Gilbert of Gilbert Orchards and Sundquist Fruit, asked the Subcommittee to work with stakeholders that “currently operate in, or have an interest in, the organic marketplace, to modernize the makeup of the National Organic Standards Board (NOSB) to better represent the current state of the organic industry.” This is something we will keep an eye on, as it is imperative that any efforts to reform the NOSB be driven by certified organic operations, rather than any other interests who may the organic sector’s best interests at heart.

Appropriations Hearing on Farm Credit

The House Agriculture Appropriations Subcommittee  held a hearing to examine the Farm Credit Administration (FCA), which oversees a national network of regional Farm Credit institutions that provide roughly 41 percent of our nation’s agricultural credit. The Subcommittee heard from Dallas Tonsanger, Chairman and CEO of the FCA, and Jeffery Hall, an FCA board member. Much of the conversation centered on the current economic downturn and the growing need for credit from farmers across the country. In this context, the Subcommittee also addressed rural development, consolidation within the farm credit system, and FCA budget caps.

Hearing Season to Continue

Both the Agriculture Committees and the Agriculture Appropriations Subcommittees in the House and Senate will be holding numerous hearings through the spring as the 2018 Farm Bill debate and 2018 appropriations debate heat up. Stay tuned for more coverage in the coming weeks.

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USDA Extends Comment Period for Organic Checkoff Proposal

Late last week, the Department of Agriculture extended the comment period on the proposed organic research and promotion order – the deadline is now April 19.  If you’re an organic stakeholder who’s interested in making your opinions heard at USDA, please consider submitting a comment.  Contact us to help you craft your comment!

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AMS Delays Final Rule on Organic Livestock and Poultry Practices

The U.S. Department of Agriculture’s (USDA) Agricultural Marketing Service (AMS) is delaying the effective date of the Organic Livestock and Poultry Practices final rule by 60 days to May 19, 2017.   This action is being taken in accordance with guidance issued January 20, 2017, to ensure the new policy team at the Department has an opportunity to review the rules before implementation.

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USDA Conducting Organic Production Survey

The U.S. Department of Agriculture’s (USDA) National Agricultural Statistics Service (NASS) is conducting the 2016 Certified Organic Production Survey to gather new data on certified organic crops and livestock production in the United States. This effort is critical to help determine the economic impact of certified organic agriculture in the United States.

NASS is mailing the survey to all known certified organic farms and ranches within the country. The form asks producers to provide information on acreage, production, and sales, as well as production and marketing practices. The agency asks all participants to respond by February 19.

Agriculture statistics are frequently used by business and policy decision makers. Farmers and ranchers themselves stand to reap benefits. The 2016 Certified Organic Production Survey will provide data for USDA’s Risk Management Agency to evaluate crop insurance coverage to help provide adequate pricing for organic producers. The report, to be released September 2017, will also assist producers, suppliers and others in the private sector in planning the production and marketing of new products to help sustain industry growth.

As is the case with all NASS surveys, information provided is confidential by law. NASS publishes all data in aggregate, ensuring that no individual operation or producer can be identified, as required by federal law. For more information about the 2016 Certified Organic Survey, visit www.nass.usda.gov/organics.

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USDA Announces Transitional Certification

USDA announced a new certification designed to make the transition from conventional to organic production easier for farmers. This National Certified Transitional Program will further enable U.S. farmers to meet the growing demand for organic products.

USDA will oversee accredited organic certifying agents, who will be authorized to offer transitional certification to producers. This is expected to help those transitioning to organic, lead to expanded certified organic acreage in the United States, and create consistency in documentation of operations’ adherence to organic regulations on land in transition to organic. It will ultimately support the continued growth of organic agriculture in the United States.

As it stands, farmers must undergo a rigorous transition period of three years before they can become certified organic and market their products as such. The new program will harmonize existing transitional certification programs currently operated by accredited certifying agents, and provide a mechanism for additional certifiers to offer this service. This can help farmers overcome barriers such as decreased yields during transition, as well as qualify them for federal grants previously out of reach.

Farmers will need to prove their land has been free of prohibited substances for at least a year, and must follow all other organic production standards, in order to achieve transitional certification. These standards include crop rotation, fostering and conserving biodiversity, and avoiding the use of genetic engineering. Once land is eligible for organic certification, it can only enter the transitional program once more – ensuring that transitional certification acts as an on-ramp to organic production, rather than a mechanism to create an “organic-light” label.

The new program does not include certification of products labeled as transitional – and is limited only to producers working toward organic certification. This dovetails with USDA’s announcement that it would expand the reach of the National Organic Certification Cost Share Program to include transitional certification fees.

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Final Rule on Organic Livestock and Poultry Practices (Animal Welfare) Published

USDA’s Agricultural Marketing Service published its animal welfare standards for organic products in the final days of the Obama Administration, but Senate Agriculture Chairman Pat Roberts (R-Kan), ranking member Debbie Stabenow (D-Mich), and House Agriculture Committee Chairman Mike Conaway (R-Tex) have all stated they have concerns, and intend to seek changes in the coming months.

The organic sector generally supports these rules, which represent over a decade of work, input from thousands of stakeholders, and recommendations from the National Organic Standards Board. The rules provide consumers and producers with clarity on what it means to buy organic meat, dairy, poultry, and eggs. But opponents worry that the cost of complying with requirements for more space and outdoor access could put some organic producers out of business; and that expanded outdoor access could lead to another avian flu outbreak.

The rules cover many aspects of animal welfare for organic livestock and poultry, but the biggest impact is likely to be felt in the organic egg industry. The regulation requires that producers provide outdoor access for organic poultry, and codifies biosecurity practices that guard against disease spread by wild birds. Organic egg producers were always required to let their hens go outside, but the new rule defines exactly what that means. The new rules will require farmers to provide at least one square foot of outdoor space for each 2.25 pounds of poultry in their flock, or about two square feet per egg-laying hen, or about an acre for a flock of 20,000.

The rule includes a five-year transition period for current organic egg production that doesn’t meet the new standard. After that five-year period, if egg producers do not comply with the rule, they will not be able to be certify their production as organic.

The regulations also ensure that organic livestock and poultry have sufficient space; require living conditions to meet certain ventilation and light requirements; and prohibit beak removal and cattle docking.

The rules are designed to help organic producers meet consumer expectations and ensure the integrity of the USDA organic seal. They are intended to strengthen consumer confidence in the USDA organic seal, and ensure that organic agriculture continues to provide economic opportunities for farmers, ranchers, and businesses across the country.