Re:  Request for Comments on Negotiating Objectives Regarding the Modernization of the North American Free Trade Agreement with Canada and Mexico (83 FR 23699)

Betsy Garrold, at-large executive board member, will speak on behalf of the National Family Farm Coalition and the Rural Coalition/Coalición Rural to the U.S. International Trade Commission.

June 27, 2017

Thank you for the opportunity to present our comments today.

The National Family Farm Coalition represents 25 family farm and rural groups in 40 states whose members face ongoing economic recession in rural communities. The Rural Coalition is an alliance of some 50 farmers, farmworkers, indigenous and migrant organizations working together toward a new society valuing unity, hope, people and land.

U.S. trade policy has long promoted the interests of agribusinesses and other multinational corporations over the economic and social stability of U.S. family farmers, rural small businesses and rural communities. Overproducing U.S. agricultural products for trade has resulted in a pattern of low farmgate prices and ignored the very real problems of farmers’ ability to stay on the land, as well as the environmental unsustainability of and competition from U.S. agribusiness.

Additionally, imports of lower priced agricultural products, including many fruits and vegetables, has hurt the livelihoods of thousands of U.S. farmers. Ben Burkett, NFFC’s board president and Mississippi farmer, stated that his family had grown cucumbers and chili peppers since the 1940s, which they sold under contract. “This all changed in 1995 when NAFTA was signed. We lost the contract – the contractor started sourcing from Mexico.”  Of the 800 farmers who had benefited from this contract, only 200 were left in 2015.

Meanwhile, the U.S. has dumped grain, meat and dairy products in trading partner nations, devastating farmers who cannot compete with these items sold at prices below their cost of production. When these farmers lost their farms they took essentially all they had left – their agricultural skills – and migrated to the U.S. for farm work. Any new trade agreement must establish binding accords to address immigration and to protect farmworkers’ labor and other human rights, including transnational collective bargaining efforts.

The current export-oriented model of production enshrined in NAFTA and other trade agreements needs to be reversed, not intensified. This point is more integral given the recently proposed reorganization of the U.S. Department of Agriculture, which adds an Undersecretary for Trade. With the additional deep cuts proposed in U.S. rural development and nutrition programs and the Farm Bill debate ahead, trade agreements must promote policies that ensure farmers and ranchers receive prices meeting their costs of production to restore agriculture as the economic base of the rural sector.

We propose that the U.S. request Canada and Mexico to withdraw their Country of Origin Labeling, or COOL, complaint under the World Trade Organization and agree to withdraw any action to implement the WTO award.  COOL enables consumers to know the origins of their food and producers to receive a fair price.

We would also ask the U.S. reject any proposals from the Trans Pacific Partnership that expedite rules for approving agricultural biotechnology products in ways that bypass national efforts to assess their safety, effectiveness and impacts on workers, rural communities and ecosystems. A renegotiated NAFTA simply must not allow trade in untested and potentially dangerous food and agricultural products derived from novel, unregulated technologies.

We support Canada’s dairy supply management program, which helps to maintain dairy prices at a level high enough to cover their cost of milk production and keep Canadian family dairy farmers in business. Undermining this program will NOT bring a large increase in U.S. dairy exports; in fact, the U.S. should emulate this dairy supply management to regulate milk production and consequently the milk price for dairy farmers. In addition, the U.S. should export high quality dairy products instead of low quality products enhanced with imported milk protein concentrate. 

Lastly, under a new tri-national trade agreement, each country, state and local government should retain their sovereignty to enact and implement policies that are designed to reach their commitments under the Paris Climate Agreement. NAFTA should be replaced with an agreement that encourages and ensures environmental sustainability, economic viability and longevity for the people growing and harvesting our food, as well as their communities, in all three NAFTA countries.