Current commercial biodegradable mulch films are a key production aid for sustainable organic farming. We understand that this technology has been safely used for many years and has been found to be effective in help managing weeds and conserving water. Additionally, we know that farmers using these types of materials have found the film meets their production requirements and biodegrades in a timely matter.
The rising cost of labor, a shrinking labor force, and limited means of disposing current polyethylene mulch film, will be a decisive factor in an organic farmer’s continued success. We appreciate that biodegradable mulch film was added to the National List in 2014, but regret that subsequent comments in Memo 15-1 have made this tool unavailable for organic farming. We request that the NOSB and the NOP remove the additional requirement which was added to 7 CFR 205.2 by Memo 15-1. This resolution would permit all organic farmers the ability to assess biodegradable mulch film technology to determine whether it is a production aid which meets their specific needs.
March 30, 2017
Ms. Michelle Arsenault
Advisory Committee Specialist
National Organic Standards Board, USDA-AMS-NOP
1400 Independence Ave. SW.
Room 2642-S, Mail Stop 0268
Washington, DC 20250-0268
Dear Ms. Michelle Arsenault:
For the past 3 years, One Straw Farm has provided public comment both written and orally on the value and safe use of biobased biodegradable mulch films that are currently on the market. We fully support the values of organic agriculture. We also believe that it is necessary to find sustainable agricultural tools that help us look at farming holistically, from cradle to cradle
The following petition demonstrates that it is not just One Straw Farms’ position that the current biodegradable mulch films on the market are safe and are a valuable processing tool. The following signatures represent members of the organic industry ranging from farmers, retailers to the consumers.
I look forward to seeing you and the NOSB at the Spring meeting in Denver.
Sincerely,
Drew and Joan Norman