301 5th Ave Southeast, Medina, NorthDakota 58467 USA Ph: (701) 486-3578 Fax: (701) 486-3580
E-mail: info@ics-intl.com Website:
19 July, 2006
To Whom It May Concern,
International CertificationServices, Inc. certifies Gardens of Eagan as an organic producer under the USDANational Organic Program as well as under its internationally accredited IFOAM(International Federation of Organic Agriculture Movements) program. It hascome to our attention that the ecological integrity of this exemplary organicfarming operation is currently being threatened by the potential installationof an oil pipeline through the farm premises. We wish to share our perspectiveabout the negative impacts Ð both for this farm itself and for organic farmingoperations in general Ð that such a pipeline or similar actions would cause.
Gardens of Eagan has provided uswith copies of the documents submitted by them and their counsel in response tothe proposed pipeline installation. We wholly agree with the content of thosesubmissions, and as such shall not strive to recreate them here. Nonetheless,our experience working with organic farming operations worldwide affords uscertain knowledge that we wish to emphasize to authorities as they consider thefate of Gardens of Eagan and other organic farms in light of such proposed landuse and development.
The use of the organic land inquestion by the pipeline company will, in our estimation, inevitably andwithout a doubt cause long-term harm to the soil and immediate surroundingecology, perhaps irremediably so for all practical purposes. We can categorizethe damages as follows:
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In organic systems the soil canbe thought of as a living organism itself. Each farming operation is specificto the soil it stewards. Activities such as tillage, planting, and amendmentare done with consideration to foster the greatest degree of soil life, a combinationof minerals, water, air, organic matter, and living organisms (bacteria, fungi,insects, others Ð the list of species far too long to fully know andunderstand) in a dynamic physical structure and cycle of life that constantlytransforms and feeds itself. All parts of the system must be functional toconstitute a living organic soil and thus a successful farming operation.
Compaction of the soil bymachinery, pipelines, and related infrastructural equipment will undoubtedlyruin soil structure, killing countless life forms currently existent,suppressing life and productivity of the soil. Lifeless soil easily erodes andthen is lost. Building good soil is a years-long process. Destruction canoccur in a quick event such as installation of this pipeline. Rebuilding ofthe damaged soil is again a years-long process.
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Biodiversity is directly impactedby the installation of the pipeline, as virtually any species in the way of theinstallation will be killed, chased out, or deterred from passing through thesite. Nature does not have borders as humans might. Travel lanes for bothsmall and large species are disrupted by the advent of the pipeline. Thesespecies play an important role in maintaining the ecological balance not onlyof the farm but of the ecology of the region in general. They complete thefood chain and help maintain balance of species. This brings equilibrium topotential agronomic disease and pest problems. Systems without sufficientdiversity usually suffer in one way or another and must be restored todiversity to flourish again. Organic production systems rely on such holisticbalance, as opposed to conventional systems which use chemicals as curativemeasures. Where it is laid, the pipeline will effect a permanent disruption ofat least some speciesÕ existence and life cycle and effectively create abarrier to others. While some species may ultimately return, others might not,depending on the degree of negative impact of the pipeline installation. Thelong-term negative effects of the installation and pipeline on the organicfarming operations could thus be persistent.
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The above two points areaggravated by the fact that the soil where the pipeline is laid and the spacearound it will be contaminated Ð by theequipment used to effect the installation, structural components of thepipeline and its support infrastructure, and/or leaks in the pipeline. Historyclearly shows (with the company in question here as well as with other similarcompanies) that oil leaks do occur. The reality of using heavy equipment isthat this machinery operates with materials that are toxic to life and explicitlyprohibited by organic production standards, and are counter to the holisticmanagement essential to successful organic farming. Incidental leaks fromequipment, use of heavy metals in the form of solder, and chemically-treatedfence posts are just a few examples of such types of contamination, not tomention the devastating impact of an actual leak in the line. Organic farmersare required to maintain equipment in their operations in good order and onlyuse materials on organic land if they comply with specific lists of allowedmaterials. Exposure of the land to non-compliant materials can render the landineligible for organic certification for at 3 years, regardless of whether theexposure was unintentional.
In summary, the unavoidablecontamination as described above, in combination with the deleterious effectsof the construction on soil structure and biology of the ecosystem will be adamaging blow to the land in question, removing affected areas from organiccertification for at least three years, not to mention the unknown additionalyears needed for the land to recover from the abuse sustained by theinstallation and produce again in a manner that is economically viable for thefarm. Furthermore, organic standards require that buffer zones be maintainedon organic lands to protect them from potential or actual contamination threatsfrom surrounding areas. The land around the pipeline will likely need to bebuffered in such a manner, the exact delineation of which depends on theparticulars of the construction. This means additional loss of certifiableland from the organic farm holding.
The loss of farmland should neverbe taken lightly, and the loss of organic farmland far less lightly still. Most farmers struggle to remain economically viable even under generallyfavorable circumstances.
1. Pipelines shouldavoid organic farms if there are feasible alternatives.
2. If there are no feasiblealternatives, specific precautions should be used in pipeline construction andmaintenance on or near organic farms to protect soils from contamination anderosion and to rebuild and restore any organic soil or biodiversity which isdisturbed. This would include the training and supervision of operators on thesite to conduct activities in a manner that takes substantive precautions toavoid contamination and undue negative environmental impact otherwise,including documentation of all such training and activities.
We stay available to assist inthis discussion further. Any questions or comments are welcome. We hope for adecision favorable to the fate of Gardens of Eagan and other organic producersnow and in the future.
Sincerely,
International CertificationServices, Inc.