Provide options that treat family farms fairly, with due process and without excessive costs. Specifically, FDA must clearly define the “material conditions” that lead to a withdrawal of a farmer’s protected status in scientifically measurable terms. FDA must also outline a clear, fair, process for justifying the withdrawal of a farmer’s protected status and for how a farmer can regain that status.
Thank you for your consideration,
Another comment , from “Amy,” also talks of the over-regulation of the small producer.
I run a small farmers market in South Dakota. It is the only source for local foods year round. The community relies on the market and our small family farms rely on the market to make a living. We have spent years earning the trust, respect, and admiration of the community by providing a safe, clean market with reliable, trustworthy vendors. This rule will unduly harm our market and thousands like us. In fact, I fear it will force us to close leaving a huge gap for healthy local foods for consumers and subtracting a big source of income for small farmers. This country was on track to self-sustaining communities and food systems. That will all be for naught with this rule. Specifically, I am concerned:
They’re too expensive.
The rules could cost farmers over half of their profits and will keep beginners from starting to farm.
They treat farmers unfairly.
FDA is claiming broad authority to revoke small farmers’ protections without any proof of a public health threat.
They will reduce access to fresh, healthy food.
Local food distributors like food hubs could close, and new food businesses will not launch.
They make it harder for farms to diversify.
Grain, dairy, and livestock farmers could be denied access to emerging local food markets.
They will over-regulate local food.
The rules could consider farmers markets, roadside stands, and community-supported agriculture programs “manufacturing facilities” subject to additional regulation.
They treat pickles like a dangerous substance.