Dear Ms. Stommes:

I am writing you on behalf of the National Organic Standards Board to request that the time period during which people may comment on the proposed National Organic Program be extended beyond 90 days.

Several reasons lead us to request this extension. First, the proposed rule is lengthy and complex. Dozens of appeals to the public for detailed information are included in the proposal and many individuals and organizations will require additional time to develop comprehensive answers to the critical questions that the Secretary has raised.

Second, the proposed rule was published in the midst of the December holiday season, meaning that many people were on family vacations and unable to obtain the rule until the new year, a potential loss of 20 days.

Finally, as anticipated, there is an unprecedented interest in this proposal. Throughout the NOSB deliberations we strived to provide a forum for public debate and our recommendations to the Secretary were strengthened by the public comment we received. We believe that the NOSB will continue to do its best work if it can make informed recommendations having had the benefit of the public input from the February USDA Listening Sessions and with the opportunity to review the greatest number of comments on the proposed rule. To that end, we are requesting that we convene the NOSB meeting, in California, with a public input session beginning on March 16, 1998. This meeting would immediately follow the Natural Products Expo in Anaheim. A majority of the board will already be there and this appears to be the only week between now and then that we can convene a full board.

The National Organic Standards Board appreciates your serious consideration of our requests.

Sincerely,

Robert B. Anderson
Chairperson, NOSB

1/12/98