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,

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.

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!

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.

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!

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.

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

Certification Cost Share Expansion Coming Soon

Yesterday, USDA announced important changes to the National Organic Cost-Share Certification Program and Agricultural Management Assistance Organic Certification Cost Share Program, that will become effective March 20, 2017.


First, producers and handlers will for the first time be able to apply for cost-share funds for their transitional certification and state organic program fees.  This is great news for those who want to transition to organic – allowing for certification cost-share reimbursement during the three-year transition period, which can be very costly.  It’s also great news for consumers whose demand for organic products continues to grow – as it will remove a barrier to farmers transitioning to meet that demand.


Second, organic producers and handlers will be able to visit over 2,100 USDA Farm Service Agency (FSA) offices around the country to apply for federal cost-share reimbursement to help them with the cost of receiving and maintaining organic or transitional certification.


These cost-share programs offer opportunities for certified producers and handlers to receive reimbursement for up to 75 percent of certification costs each year up to a maximum of $750 per scope – crops, livestock, wild crops, handling, transitional certification, and state organic program fees.

National Organic Program Updates

As 2016 winds down, the USDA National Organic Program (NOP) is not slowing down!

  • On December 6, NOP published draft guidance on “Calculating the Percentage of Organic Ingredients in Multi-Ingredient Products”.  Although the existing USDA organic regulations establish labeling categories for organic products based on the percentage of organic ingredients in the product, certifying agents have interpreted the requirements for calculating the percent of organic ingredients differently.
    The draft guidance clarifies the standards for calculating organic percentages for finished products, including multi-ingredient products that contain ingredients that are actually composed of more than one ingredient.  The draft guidance, which will help farms, businesses, certifiers and other stakeholders implement the USDA organic standards consistently, supersedes “NOP Policy Memo 11-9,” dated October 31, 2011, which is now obsolete.
    The public comment period on this draft guidance will close on February 6, 2017.  Feel free to contact me if you’d like assistance in drafting and submitting comments.
  • The National Agricultural Statistics Service’s (NASS) Agricultural Statistics Board released the results of the 2014 and 2015 Organic Certifier Survey.  NASS collected data on acreage and livestock data for years 2014 and 2015 from USDA-accredited organic certifying agents in the United States.  Published information includes the number of certified organic operations along with the number of acres certified for various crops, and the reported livestock and poultry certified as organic.  The report is available at: 2014 and 2015 Organic Certifier Survey.
  • The USDA Organic Integrity Database has moved to a new server with a new web address, leading to speedier searches and data uploads.  Check out the list of USDA certified organic farms and businesses today and update your bookmark to the new address:
  • The Agricultural Marketing Service (AMS) Dairy Market News recently published the Dairy Organic report.  Published bi-weekly, this report provides organic price information for dairy products and highlights market trends.  The report also includes highlights on organic milk sales for Federal Milk Orders and insights for U.S. and international markets.  For more information on organic dairy product markets, view the Biweekly Dairy Organic Report.
  • The AMS Specialty Crops Market News recently published the National Specialty Crops Organic Summary.  Published daily, this report provides organic price information at terminal markets, shipping points, and retail advertised prices throughout the U.S.  The report highlights prices for 133 organic fruits, vegetables, herbs, and other specialty crops as well as movement data including domestic shipment volumes and import information.  For more information on market trends for organic specialty crops, view the National Specialty Crops Organic Summary.
  • The NOP conducted a review of the California State Organic Program (CA SOP) and approved its continued operation as a State Organic Program.  State Organic Programs provide the opportunity for a state to oversee organic production and handling operations within its state, and California has the only approved State Organic Program.  The CA SOP is authorized under the Organic Foods Production Act of 1990, the USDA organic regulations, and the California Organic Products Act of 2003.  You can access the memorandum authorizing the CA SOP to continue operating as a State Organic Program and read more about the program on the AMS website.

Fall 2016 NOSB Update

Greetings from the Fall 2016 National Organic Standards Board (NOSB) meetings, held in St. Louis, Missouri! As is the case every time it meets, the Board considers a number of standards issues important to the organic sector, and hears public testimony on those issues.

A few highlights from the week:

  • Five Board members will reach the end of their terms at the end of the year, and served their final meeting this week. The organic community owes gratitude to Tracy Favre, Jean Richardson, Zea Sonnebend, Carmela Beck, and Harold Austin – each of whom devoted tireless hours of volunteer service to continued development of strong organic standards.
  • The new NOSB members whose term will begin in January were announced. They are Joelle Mosso (Olam International), Sue Baird (Missouri Organic Association), Asa Bradman (University of California at Berkeley), Steve Ela (Ela Family Farms), and David Mortensen (Pennsylvania State University). We look forward to working with each of them!
  • The Board elected its officers for the next term. Congratulations to Tom Chapman (Chair), Ashley Swaffar (Vice Chair), and Jesse Buie (Secretary).
  • Deputy Administrator of the National Organic Program (NOP) Miles McEvoy gave an update on the work of the NOP and what we can hope to see from the Program in the remaining weeks of the Obama Administration.
    • The rules on Organic Livestock and Poultry Practices and Organic Aquaculture are both in clearance at the Office of Management and Budget (OMB), and are expected to be finalized before the end of the administration.
    • The proposed rules on Organic Apiculture and Organic Pet Food have been written and are in clearance.
    • Other rules in progress include rules on Origin of Livestock, Sodium Nitrate, and Compost.
    • The Program is continuing its work on improving oversight and control of organic trade, import requirements, classification of materials, and calculation of organic materials.
  • The Board heard public comments from approximately 150 stakeholders in person in St. Louis. Most of the comments focused on three main topics – the use of carrageenan in organic products; the use of certain materials in poultry production; and whether hydroponic, aquaponic, or container production can continue to be certified organic.
  • The Missouri Organic Association, in conjunction with the Organic Trade Association, hosted an evening reception with organic snacks and wines. In attendance were representatives from the Missouri Department of Agriculture, U.S. Senator Roy Blunt’s office, and U.S. Senator Claire McCaskill’s office.

The results of the Board’s deliberations on the proposals and petitions before it are as follows:

  • Changes to the National List:
    • Carrageenan and ivermectin were removed from the National List.
    • The remaining substances set to sunset were retained on the National List.
    • No petitions for additions to the National List were successful.
    • Sodium chlorite and tocopherols were referred back to the Handling Subcommittee for further work.
  • Proposals/Reports:
    • The Board adopted the Materials Subcommittee’s proposal on NOSB Research Priorities.
    • The Board adopted the Materials Subcommittee’s proposal on excluded methods, after removing the reference to Dupont seed technology.
    • The Board accepted the Materials Subcommittee’s report to the Secretary of Agriculture on progress to prevent incursion of GMOs into organic.
    • The Board referred the proposal on hydroponics, bioponics and aquaponics back to the Crops Subcommittee for further work. (Work will also continue on the question of standards for container production in organic, which was reviewed as a discussion document, rather than a full proposal to be voted on.)
    • The Board adopted a resolution stating that it intends to continue to consider innovations in agriculture that may or may not be compatible with organic production; and the current Board’s intention would be to prohibit systems that have an entirely water-based substrate.
    • The Board passed the Policy Development Subcommittee’s revisions to the Policy and Procedures Manual and reorganization of sunset review.

We can look forward to a full docket, including continued work on standards for innovative organic agricultural practices, at the April 2017 meeting, which is scheduled to be held April 19-21 in Denver, Colorado.