TITLE 4.AGRICULTURE

Part 1. TEXAS DEPARTMENT OF AGRICULTURE

Chapter 3. BOLL WEEVIL ERADICATION PROGRAM

Subchapter J. ORGANIC COTTON RULES

4 TAC §§3.600, 3.601, 3.604 - 3.608

The Texas Department of Agriculture (the department) adopts amendments to Chapter 3, Subchapter J, §§3.600, 3.601 and 3.604-3.608, concerning organic cotton production in boll weevil eradication zones, with changes to the proposal published in the March 2, 2001, issue of the Texas Register (26 TexReg 1871). Sections 3.604-3.606 and 3.608 are adopted with changes. Sections 3.600, 3.601 and 3.607 are adopted without changes and will not be republished.

The amendments are adopted to make the sections consistent with state law and with emergency pest or disease treatment program provisions included in the recently adopted National Organic Standards, to make the process for determination of whether an organic field has reached a trap count trigger more efficient, and to provide for compensation, with the approval of the Texas Boll Weevil Eradication Foundation (the foundation), to an organic grower who elects treatment of a field that has triggered under the emergency pest or disease treatment program provision. Further, the amendments are adopted to provide clearer and more efficient procedures regarding the growing of organic cotton in active boll weevil eradication zones, which will facilitate boll weevil eradication in Texas, while providing another mechanism by which organic growers may receive reasonable compensation. The adoption of the emergency pest and disease treatment program provisions of the National Organic Standards will also benefit organic cotton production and marketability because growers who are able to utilize this provision will not lose their organic certification on that operation for years other than the year a direct treatment is made.

Section 3.604 (b) has been changed by the department and also based on a comment received from the Texas Boll Weevil Eradiction Foundation, Inc.(the foundation), and changes this section to substitute the phrase "an individual working for the foundation" with the phrase "an employee or independent contractor of the foundation". This change is made to clarify that the provisions of this subsection apply whether the inadvertent drift is caused by an employee or independent contractor of the foundation. Subsection 3.605(e)(4) is changed to correct a grammatical error. Subsection 3.606(d)(3) has been changed to provide that the foundation's approval or denial of a grower's request for conventional treatment shall be made in writing to both the grower and the department. This requirement is added to ensure that notification of the approval or denial is provided to all of the interested parties and made in a timely manner. Subsection 3.606(d)(3) has also been changed to clarify that if a request for treatment is denied, that either the grower, or if the grower refuses, the department, must destroy the crop. Subsection 3.606(d)(5) is changed also based on a comment received from the foundation suggesting the correction of a grammatical error, and is changed to clarify that once a grower is approved for treatment and his or her crop is treated by the foundation, the grower will be compensated. Subsection 3.608(e)(3)(B) is changed to correct a spelling error. The word "component" has been changed to "competent". Section 3.608 is changed also based on a comment received from the foundation and from an organic grower, and deletes the phrase "upon agreement by both parties" from subsection (h). This change is made because it is confusing and implies that additional agreements may be made in regards to price or treatment. As stated in the rules, the decision of an organic grower to accept treatment also includes the acceptance of the fixed compensation rate of $.39 per pound if treatment is approved by the foundation and the crop is treated.

The amendment to §3.601, concerning the definitions of a "certified organic crop" and "transitional crop", provide that an application under the emergency pest and disease treatment program provisions of Title 4, Chapter 18 will not interfere with the timeline for organic certification. The amendments to §3.604, concerning protection of organic certification, also add a reference to an application made under the emergency pest or disease treatment program provisions of the National Organic Standards as an allowed treatment which will not interfere with the certification status of an organic operation. This section is also amended for purposes of clarification and to make it consistent with the Texas Agriculture Code, §74.125, which allows for the department to provide by rule indemnification for organic cotton growers for reasonable losses resulting from a prohibition of production or for any requirement to destroy organic cotton, but does not allow for indemnification due to drift or inadvertent direct application of a prohibited material by the foundation.

The amendment to §3.605, concerning trigger levels, at paragraph (d)(1), replaces the Texas Agricultural Extension Service (TAEX) representative on the technical review committee that determines if treatment is necessary once a field has triggered with a representative from the department designated by the commissioner. The amendment to paragraph (d)(6) provides for an election by a grower to either destroy or allow the foundation to destroy a crop that has triggered, or allow the crop to be treated by the foundation under the emergency pest or disease treatment program provisions of Chapter 18. The amendment to paragraph (e)(4), regarding who makes a determination as to whether a crop has reached cut-out stage, also replaces the TAEX representative with a department representative designated by the commissioner. The language does not prevent the department's representative from consulting with a TAEX Intergrated Pest Management agent or specialist, as deemed necessary.

The amendment to §3.606, concerning crop destruction, extensions and conventional treatment, at subsection (d) provides that a grower may elect for his crop to be treated under the emergency pest or disease treatment program provision in Chapter 18, and if treatment is approved by the foundation and the crop is treated, the grower will receive compensation in the form of an organic premium based on the amount of cotton lint actually harvested from the field. Another amendment provides that a grower must notify the foundation of their election to allow treatment of their certified crop under the emergency pest or disease treatment program provisions at least four calendar days before the destruction deadline. The amendments further provide that if a field is treated under the emergency pest or disease treatment program provisions, such treatment will not affect the certification status of the operation, but the crop cannot be sold, labeled, or represented as "Organically Produced" or "Transitional-Organic Certification Pending".

The amendments to §3.607 clarify that growers may negotiate and enter into voluntary indemnification agreements with the foundation and that such agreements are to be approved by the commissioner. This makes this section consistent with current practice. The amendments more accurately reflect the involvement of growers in the zone in the negotiation process. The proposed language does not prohibit the foundation from seeking input from grower committees, or growers in general, in regards to voluntary agreements, and the foundation may seek such input as it deems appropriate.

The amendments to §3.608(b) add the emergency pest or disease treatment program option to the timeline by which a grower is entitled to compensation. The amendments to subsection (e) clarify when notice of required destruction is deemed received by a grower. New subsection (h) is added to establish the amount of compensation a grower will receive if his crop is approved by the foundation for treatment and treated by conventional means. Under this section, a grower who voluntarily elects and is approved for conventional treatment and whose crop is treated will be able to sell his cotton as conventional, and will receive an organic premium in a fixed amount of $.39 per pound for the actual weight of cotton lint harvested. The amount, on a per pound basis, is the same premium amount established in §3.609 for payment in the case of required destruction. The premium was determined by evaluating the five-year average price of conventional cotton and organic lint and seed. The department believes that allowing for the payment of a premium under this section as well as allowing a grower to benefit from the sale of cotton in the conventional market will provide reasonable compensation to the grower and will also benefit the eradication program. Further, because under the National Organic Standards, and upon adoption of proposed amendments to Texas' state standards, the certification status of an operation is not jeopardized by an application made under the emergency pest or disease treatment program provisions, the marketability of an organic grower's cotton will not be affected for future years.

In addition to the comments previously addressed, the department received comments generally in support of the proposal from the foundation, Plains Cotton Growers, the Permian Basin Grower Steering Committee, the Texas Organic Marketing Cooperative, and individual organic growers. In addition to the receipt of written comments, the department also received oral comments at two public hearings held by the department in Lubbock and Lamesa, Texas on March 14, 2001. Comments are summarized by section as follows. In regard to §3.600, organic growers applauded the adding of language stating as part of the purpose statement for the subchapter, that rules adopted by the department ensure the maintenance of marketability of organic cotton. In regards to §3.604, and amendments made to subsections (b) and (d), organic growers objected to the deletion of language requiring the foundation to indemnify a grower in the event that an organic crop is sprayed or drifted on by the foundation. As noted previously, the amendment to subsection (b) is made to make this section consistent with current law. The Texas Agriculture Code, §74.125 only allows the department to require indemnification for losses due to destruction of a crop or prohibition of growing of organic cotton, and not for incidents involving direct or indirect spraying by the foundation. While indemnification is not required by §3.604, the foundation is charged, where appropriate, with assisting a grower in obtaining just and reasonble compensation, whether a loss is due to an employee of the foundation or an independent contractor of the foundation. Organic growers also expressed concerns that without being held accountable for indemnification for losses due to drift, in particular, the foundation will assume it has a license to spray malathion without regard to who is damaged. As the state agency responsible for oversight of the boll weevil eradication program, the department will continue to work with the foundation to ensure that measures are taken to minimize the incidence of drift or inadvertent direct application on organic crops and will encourage the foundation to work with organic growers to address problem areas regarding drift that have been raised by organic growers. In addition, the department will investigate incidents involving direct spray or drift by a foundation employee or contractor and seek administrative, civil or criminal penalties, as appropriate. In regards to §3.606(d), both conventional and organic growers were generally supportive of the department's amendments to this subsection and the ability of an organic grower to be treated under the emergency treatment program provisions of the National Organic Rules, and the addition of compensation when a grower elects treatment. Organic growers, however, expressed some concern that even if a grower agrees to have his or her organic field treated, that there is no assurance that the grower will be compensated by the foundation. The department believes that the language of subsection (d) as adopted, does clearly provide that once the foundation has approved the growers' request for treatment and treatment occurs, that the grower will be compensated at the fixed premium rate of $.39 per pound. Organic growers were also concerned that the foundation alone determines whether or not a grower's request for treatment should be accepted, a decision, they believe, should be made by the grower. The compensation provision of §3.606 is consistent with the Code, §74.125, which does not allow the department to require the foundation to indemnify growers for losses other than when a crop is destroyed or growing of organic cotton is prohibited. Compensation of growers who are treated does not run afoul of §74.125 because treatment must first be approved by the foundation. Further, it is the department's belief that the decision whether or not to treat and compensate a grower will be made in the best overall interest of the eradication program, and will involve some input from the grower.

Comments were received on several sections or subparts of sections on which no amendments were proposed or on issues which were not addressed in the proposal. Several comments were received on §3.605 both in regards to the use and setting of trigger levels and on 3.605(e) and the definition of "cut-out", and whether that should be used as a threshold for not being able to treat an organic field. Comments by organic growers on the setting of trigger levels requested that that trigger levels not be the sole determining factor of whether destruction is required by the foundation. The department believes that §3.605 already provides that other factors besides trap count will be considered in making a decision as to destruction and that the foundation will work with organic growers to come to agreement as to alternative approaches to destruction, with destruction of a crop being the last resort. Comments from the Foundation's counsel suggested changing the definition of "cut-out stage" to 50% of cracked bolls to ensure greater uniformity in fixing a stage when organic cotton will not require treatement or destruction. Comments from the Foundation's Technical Advisory Committee stated that the preference was to allow the Foundation to treat or destroy any acreage at any time that there is a threat of boll weevil reproduction. Comments from the Plains Cotton Growers recommended the use of a scale based on progress of the program and also stated that reaching cut-out stage does not signify that a field no longer poses a threat of reproduction. The department did not propose any changes to the definition of cut-out because no need to change the definition has been demonstrated. Other comments were received on §3.608, concerning calculation of indemnity, in general, and specifically on §3.608(e)(1), relating to formulas for indemnification when a grower is indemnified due to crop destruction. Again, the department did not propose any changes to the indemnification formula because no need to change the formula has been demonstrated. The department will reconsider these issues after the 2001 growing season and make changes as it deems appropriate. Other general comments received recommended the setting of a maximum amount of organic acreage which can be destroyed in any crop year in order to ensure the protection of organic markets. Again, the concern of organic growers is that under the rules, the foundation may choose to destroy or treat all organic cotton crops, when treatment or destruction should only be required as a last resort. The department believes that the process established in §3.605, which sets out how it is determined whether or not destruction or treatment will be required, provides protection to organic growers to the extent that the determination is not made by the foundation, but by a technical review committee considering several factors besides the trap count, and must be approved by the commissioner before any action may be taken. As noted in the statement of purpose of this subchapter, the commissioner will consider not only the ultimate success of the eradication program, but also the affect on the certification and marketability of Texas organic cotton.

The amendments are adopted under the Texas Agriculture Code (the Code), §74.125, which provides the department with the authority to develop rules and procedures to protect the eligibility of organic cotton growers to be certified by the commissioner of agriculture, ensure that certification by the commissioner meets national certification standards and in all events maintain the effectiveness of the boll weevil or pink bollworm eradication program administered under the Code, Chapter 74, Subchapter D, including rules that provide indemnification for organic cotton growers for reasonable losses that result from prohibition or production of organic cotton or from any requirement of destruction of cotton; and, the Code, §74.120, which provides the department with the authority to adopt reasonable rules to carry out the purposes of the Code, Chapter 74, Subchapter D.

§3.604.Protection of Organic Certification.

(a)

The foundation will take steps reasonably necessary to protect the certification of organic crops during the course of its normal eradication activities.

(b)

In the event the foundation or an employee or independent contractor of the foundation inadvertently treats a certified organic or transitional field or portion of a crop, either directly or through drift, with prohibited materials, other than an application allowed under emergency pest or disease treatment program provisions of Chapter 18 of this title (relating to Organic Standards and Certification), the foundation will, to the extent appropriate, assist the grower in obtaining just and reasonable compensation.

(c)

For purposes of this section, a determination of whether or not a direct treatment or drift occurred will be made by the department in accordance with established procedures.

(d)

In the event of a confirmed case of direct treatment or drift of chemical applied for or by the foundation, and where appropriate, the department will investigate and seek such penalties as warranted under the Texas Agriculture Code, Chapter 76, and Chapter 7 of this title (relating to Pesticides).

§3.605.Trigger Levels.

(a)

During the first season of treatment in an active boll weevil eradication zone, the "diapause" phase of the program, all organic producers may plant certified organic or transitional cotton consistent with §3.602 of this title (relating to Planting of Certified Organic or Transitional Cotton in Active Eradication Zones), without regard to boll weevil trap captures. Producers will be required to communicate with the foundation as prescribed in §3.603 of this title (relating to Communication with Organic Producers; Notification of Organic Production).

(b)

Certified organic or transitional cotton fields in active boll weevil eradication zones will adhere to the same trap count trigger levels that are set by the foundation and pursuant to subsection (c) for conventional cotton fields in that zone beginning in the first season-long phase of the program and continuing each season thereafter.

(c)

Trap count triggers will be set under the following conditions.

(1)

The foundation will inform organic growers of the trigger levels at the beginning of each season.

(2)

The trap count trigger level may change during the season, and when these changes are made, the foundation will inform organic growers at least 48 hours prior to implementing a new trap count trigger level.

(3)

Traps around organic cotton fields will be checked at the same interval as traps around conventional fields in the same zone.

(4)

The establishment of the trap count trigger level and placing of traps will be based on sound scientific and entomological considerations and shall be implemented in a fair and equitable manner.

(d)

If an organic or transitional field surpasses the set trap count trigger level, a technical review committee will determine if destruction of that field or other alternative action should be required using the following procedures.

(1)

This committee will consist of the foundation program director or his designee, a member of the foundation's technical advisory committee appointed by the commissioner, and a department representative designated by the Commissioner.

(2)

No less than two committee members will meet at the field in question within 48 hours after the field surpasses the trap count trigger level.

(3)

The committee will consider factors established by the foundation's technical advisory committee and approved by the foundation's board and the commissioner including, but not limited to, crop damage, trap captures in nearby traps, and cost to the eradication program.

(4)

The technical review committee shall make a written recommendation to the commissioner on the organic cotton field in question specifying the recommended actions and justification for those actions. This recommendation shall be made within 48 hours after the field surpasses the trap count trigger level.

(5)

The commissioner shall review the technical review committee's recommendation and make a final determination on the action required within one business day of receiving the committee's recommendation.

(6)

Should the commissioner determine that some type of eradication activity should occur, the grower may elect to either destroy the crop as prescribed in §3.606 of this title (relating to Crop Destruction), or may elect to allow the crop to be treated under the emergency pest or disease treatment program provisions of Chapter 18 of this title (relating to Organic Standards and Certification).

(e)

Destruction of an organic cotton crop under this section will not be required, regardless of trap captures, once the crop in that field has reached cut-out stage for that season. This stage will be determined through the following process.

(1)

For purposes of this section, "cut-out stage" is defined as at least 50% of cotton plants in a field having four or fewer nodes above white flower.

(2)

The grower will contact the foundation when they believe their crop has reached cut-out stage.

(3)

A foundation representative will inspect the field within 48 hours after being contacted by the grower to confirm that it has reached cut-out stage.

(4)

If there is a dispute relating to the stage of the crop, a department representative designated by the commissioner will inspect the crop and determine if cut-out stage has been reached.

(5)

The foundation will notify the department when it is determined that a field has reached cut-out stage.

§3.606.Crop Destruction; Extensions: Choice of Conventional Treatment.

(a)

Crop destruction. A grower who has been notified that destruction of their organic cotton crop is necessary will have no more than seven calendar days from the date of receipt of notification to destroy that crop by plow-up.

(b)

Extension requests. A request for a deadline extension will be handled as follows.

(1)

The department may, on written request by a grower, grant an extension of the destruction deadline. Request for extensions may be granted for the following reasons:

(A)

weather factors;

(B)

illness;

(C)

mechanical failure; or

(D)

other good cause, as determined by the department.

(2)

A written request for an extension of the destruction deadline must be submitted on a form prescribed by the department.

(3)

Request forms may be obtained from either the department or the foundation.

(4)

Failure to complete the form in its entirety may result in denial of the request.

(5)

All requests for extensions shall be postmarked on or prior to the destruction deadline

(c)

Penalties for not destroying a crop by the deadline.

(1)

If the crop is not destroyed within seven calendar days of the date of notification or expiration of an approved extension, the compensation the grower is entitled to under §3.608 of this title (relating to Calculation of Indemnity), for that acreage will be decreased by 50%.

(2)

If the crop is not destroyed within 14 calendar days of the date of notification or expiration of an approved extension, the grower will no longer be entitled to compensation under §3.608 of this title, for that acreage.

(3)

The department may assess an administrative penalty of not more than $5,000 per day if the crop is not destroyed within 15 calendar days after the date of notification or expiration of an approved extension.

(4)

If the crop is not destroyed by the 15th day after the date of notification or expiration of an approved extension, the department or its designee may destroy the crop.

(d)

Choosing conventional treatment.

(1)

In lieu of crop destruction, a grower who qualifies under the emergency pest and disease treatment program provisions of Chapter 18 of this title may notify the foundation and the department in writing that he or she desires conventional treatment within three days of receiving notice that the field must be treated or destroyed. Under Chapter 18 of this title, any harvested crop or plant part to be harvested that has been treated cannot be sold, labeled, or represented as Organically Produced or Transitional-Organic Certification Pending; this treatment will not affect the certification status of the operation or future crops.

(2)

Such notification must be provided in writing to both the foundation and the department and must be postmarked, if sent by mail, or faxed at least four days before the destruction deadline.

(3)

Once notified, the foundation shall approve or deny in writing, to the grower and the department, the request for conventional treatment within 48 hours. If the request is approved, the foundation may treat the crop with conventional methods. Should the request be denied, the grower, or if the grower refuses, the department or its designee, must destroy the crop as outlined in subsections (a) and (c) of this section.

(4)

Once the foundation has approved the grower's request for conventional treatment, the Foundation will treat the field in the same manner as all conventional cotton fields in the same zone.

(5)

A grower whose cotton is approved for treatment by the foundation and is treated under Chapter 18 of this title, will be entitled to compensation under §3.608, subsection (h), of this title (relating to Calculation of Indemnity or Compensation), for that acreage.

§3.608.Calculation of Indemnity or Compensation.

(a)

To be eligible for indemnification if a crop must be destroyed under §3.606 of this title (relating to Crop Destruction; Extensions; Choice of Conventional Treatment), a grower must report the Farm Service Agency farm numbers, physical locations, and row acreage on each farm that the grower will use as the base acreage calculated in §3.607 of this title (relating to Eligibility for Indemnification or Compensation), to the foundation before planting each year on a form provided by the foundation.

(b)

If certified organic or transitional cotton on the grower's base acreage is destroyed through the requirements of this subchapter, or if the acreage is treated by the foundation under emergency pest or disease treatment program provisions as provided under Chapter 18 of this title (relating to Organic Standards and Certification), any indemnification or compensation will be made by October 31 of that year.

(c)

If the commissioner determines that the foundation is delinquent in a payment owed to a grower, the foundation will be responsible for an additional payment to the grower of 1.5% of the amount owed per month of delinquency.

(d)

The following factors will be considered when calculating indemnity payments for organic cotton growers whose cotton is required to be destroyed in accordance with §3.605 of this title (relating to Trigger Levels) and §3.606 of this title (relating to Crop Destruction; Extensions; Choice of Conventional Treatment):

(1)

eligible acreage - the base acreage, in row acres planted to certified organic or transitional cotton, determined as provided in §3.607 of this title (relating to Eligibility for Indemnification), and identified for that field as described in this section. Organic or transitional cotton must be planted on this acreage by the final planting date set by the Risk Management Agency of the United States Department of Agriculture in the county in which the crop is planted.

(2)

yield - the yield per acre will be determined by using the Actual Production History per row acre planted to cotton for that farm, as determined by the Risk Management Agency of the United States Department of Agriculture; and

(3)

conventional cotton price - the conventional cotton price will be determined by the upland cotton price election for an APH policy in the county in which the organic or transitional cotton in question lies for the current crop year. This price for the coming crop year is published by the Risk Management Agency of the United States Department of Agriculture before December 31 of each year.

(e)

When a grower is entitled to indemnification as a result of crop destruction, the foundation will indemnify the grower in accordance with the following formulas:

(1)

If the notice is received by the grower less than thirty days after the final planting date in that county that destruction of a crop is required, the indemnity will be: eligible acreage x yield x (conventional cotton price + $0.39) X 50%, with no mitigation required; or

(2)

If the notice is received by the grower thirty days or more after the final planting date in that county that destruction of a crop is required, the indemnity will be: eligible acreage x yield x (conventional cotton price + $0.39) X 65%, with no mitigation required.

(3)

For purposes of this subsection, notice is deemed received by the grower:

(A)

upon hand-delivery of the notice to the grower or an authorized representative by a department employee;

(B)

if mailed by certified mail, return receipt requested, upon the date of delivery as shown on the green card receipt, if no delivery date is shown, three days after the date the department deposits the notice in the mail as shown by department records or other competent evidence; or

(C)

if mailed by regular mail, and upon showing of proof by the department that the notice was deposited in the U.S. mail and sent to grower's last known mailing address, after 3 days from date of mailing.

(f)

After a zone has been declared eradicated by the commissioner:

(1)

any grower who plants certified organic or transitional cotton will be eligible for indemnification on an acre per acre basis only, if all or part of a crop is required to be destroyed;

(2)

indemnification will only be available for certified organic and/or transitional cotton acreage that is required to be destroyed; and

(3)

indemnification will be acreage x yield x (conventional cotton price + $0.39) X 75%, with no mitigation required.

(g)

The commissioner will resolve any dispute between the grower and the foundation regarding the amount of indemnification.

(h)

If a field is treated under §3.606(d) of this title (relating to Crop Destruction; Extensions; Choice of Conventional Treatment) by conventional means the foundation will compensate the grower at a rate of $0.39 per pound of lint harvested from that field that crop year.

This agency hereby certifies that the adoption has been reviewed by legal counsel and found to be a valid exercise of the agency's legal authority.

Filed with the Office of the Secretary of State on April 11, 2001.

TRD-200102099

Dolores Alvarado Hibbs

Deputy General Counsel

Texas Department of Agriculture

Effective date: May 1, 2001

Proposal publication date: March 2, 2001

For further information, please call: (512) 463-4075


Chapter 18. ORGANIC STANDARDS AND CERTIFICATION

4 TAC §18.10, §18.11

The Texas Department of Agriculture (the department) adopts amendments to §§18.10 and 18.11, concerning certification of organic food and fiber, without changes to the proposal published in the March 2, 2001 issue of the Texas Register (26 TexReg 1817). The amendment to §18.10 is adopted to make the section consistent with the newly adopted National Organic Standards in regards to emergency pest or disease treatment programs. The amendment to §18.11 is adopted to provide a more efficient and reasonable procedure for establishing a residue tolerance level for a crop or product that is not intended for consumption for which an Environmental Protection Agency (EPA) tolerance level or Food and Drug Administration (FDA) action level has not been established. The amendment will also result in greater availability of Texas organic cotton for sale in state, national and international markets. The amendment will change the method for establishing the tolerance level for non- consumable crops or products. Under the amendment, when crops or products are not intended for consumption and there is no EPA tolerance or FDA action level for a particular substance that is present, the crop or product may not be represented or sold as organic or transitional if the substance is detected in excess of 5% of the highest EPA tolerance or the FDA action level for that substance for all products or crops.

Oral comments were received concerning the amendment at two public hearings conducted by the department on March 14, 2001, in Lamesa and Lubbock, Texas. Comments from Plains Cotton Growers, the Texas Cooperative Marketing Association, and individual organic cotton growers were general comments in favor of the amendments. Organic growers, in particular, commented that the amendments are reasonable and provide a practical solution for organic growers. One remaining concern for organic growers is that while the amendments will help organic cotton growers and others producing crops not intended for consumption, it will not solve the problem for organic growers producing crops for human or animal consumption. The department is aware of and looking into this issue, and intends to continue to explore the possibility of taking a similar action for consumable crops.

The amendments are adopted under the Texas Agriculture Code (the Code), §18.002, which provides the department with the authority to adopt rules necessary for the enforcement and administration of Chapter 18, Subchapter A., concerning Organic Standards and Certification.

This agency hereby certifies that the adoption has been reviewed by legal counsel and found to be a valid exercise of the agency's legal authority.

Filed with the Office of the Secretary of State on April 11, 2001.

TRD-200102100

Dolores Alvarado Hibbs

Deputy General Counsel

Texas Department of Agriculture

Effective date: May 1, 2001

Proposal publication date: March 2, 2001

For further information, please call: (512) 463-4075