Late June

Riverbend Farm Newsletter                                                 June 28, 2014

It has been a busy couple of weeks.

You probably have seen that the Crow has been flooding.  There is a lot of water out there. Last Friday Gina from Three Crows sent out a note that the crest was forecast to be 21 feet and they needed help to keep the river out. The city had mostly given up on protecting them.  The cafe is on the wrong side of the dike…

On Friday Brad and I draped a sheet of plastic around the back of the building to try to slow down the water coming into the building.  A crew of local characters was busy moving everything out of the back of the shop to keep it from being ruined by the water. As we were finishing up the water was lapping over the edge of the sidewalk.  A truck load of  refrigerators and perishable items went to Brad and Gina’s garage. Mary and I got home about 11 pm.

On Saturday we sandbagged between the existing flood wall and the building to keep the river from running in the back door. We also sandbagged the patio to slow the water running into the basement and along the side of the building to keep the water out of the main room.

The fundamental problem is that the whole river bank is made up of chunks of granite from the Granite Works. There is about 3’ of soil on top of the fill, but the fill is very porous. When the river gets high it finds the gaps in the fill and works its way toward the street.

Saturday night Brad kept an eye on the pumps as the water came up to  18.5 feet. On Sunday the water came up about another foot. The river was up to the bridge deck. One of the pumps crapped out and Brad and Gina’s daughter Liza went and got a couple more.  At the peak we had seven pumps running. The sand bag dikes started leaking and they needed to be higher and wider to keep out the projected crest of 21 feet.

Sunday night we took shifts running pumps and keeping an eye on the sandbags.  The water was high, it was starting to flow around the east end of the bridge and up along the south side of the building. When we shut down a pump to refuel the water would come up 2-3 inches. We were holding our own, but just barely.

Monday the water kept coming up. In the afternoon Brad and Gina decided that they could not fight it any longer. The high water was forecast to last  until Thursday and they were afraid that the water eddying next to the building would wash out the foundation or the big trees on the bank. Either would be catastrophe. If the foundation failed,  the back part of the building would fall into the river. If the trees went, they would take the sandbags and the patio with them. It was too much risk to ask their friends to take.

With the clay dike in front of the building all we could do was set stuff up on blocks and hope for the best.  We started shutting down pumps and pulling them out of the way. At 3pm the river flowed into the cafe, closing that chapter of Three Crows.

Gina is planning to reopen. See the Three Crows website: .


Around here things are shifting from planting to harvest, such as it is. We had been getting out butts kicked all spring with the stormy, cool wet weather.  This week I disked under five plantings of arugula, radishes, and other greens  that were never going to amount to much, to make room for fall brassicas and the last round of zukes and cukes.  Weed control continues.

Here is a little photo tour of the farm (you will notice that it is raining…)

This is the seed bed where I am selecting seeds from F2  and F3 generations of some good hybrid eggplant, peppers, and tomatoes to make stable open pollinated varieties.

A killdeer nest next to an F2 eggplant. It is amazing that any of them ever survive.

Sorghum sudan grass cover crop.

This should look like the previous image, but it has been too wet to get in and plant. It is not a complete disaster. The plants with the yellow flowers are sweet blossom clover. The purple ones are hairy vetch. Both are good soil building plants.

Winter squash that is planted in part of teh field that should be sorghum sudan grass. It looks good.

The next arugula and radishes.

Crop mob was here and installed a couple thousand tomato stakes before it started to rain. Thanks everyone.

Nice looking cabbages and kale. The broccoli looks good, but the crummy weather has made it all decide to bolt to seed rather than produce a large head.

A spot that is simply too wet.

A zucchini that was produced from seed that was hand pollinated. Cocozelle is supposed to have the light stripes.

The onions are doing well this year. The tops are a little beat up from the wind.

Arugula seed (on the right) and french breakfast radish seed.

Cippolini onions going to seed. We stored the onions in the basement over the winter and planted them first thing this spring.

Kale seed that is almost ripe. These plants were stored n the root cellar before planting them out this spring.


Mid June Newsletter

Riverbend Farm mid June Newsletter                                            June 12, 2014

We have been planting non stop for the past two weeks or more.  At the end of May we set out thousands of lettuce and kale plants. The Birchwood Crop Mob stopped by on the last Saturday of May and kicked off the tomato planting. We got rained out a little early. It seems like the first crop mob always brings rain. It was great to see some old friends and meet some new ones.

Our crew has been planting everything that will fit. We finished up the tomatoes and moved on to the eggplant and peppers. Right after that we started on winter squash and pumpkins. The pumpkins continue today. The last round of lettuce is also set to go in this week.

I have been staying a little ahead of them, working up ground and marking out rows. The weather has not been terribly cooperative with getting things done.  The problem continues to be periodic, very heavy rain.  At the end of April we had a month’s worth of rain (5.5+ inches) in a week.  May 31st and June 1st brought  4+ inches. We have been getting an inch or so every week, which is about perfect, but the big storms saturate the ground and there is no place for the regular rain to go.

The southern quarter of this year’s vegetable field has been too wet to drive on, much less work.  The road over to the land I have rented from our neighbor Cathy has been under water for about six weeks. At this point it is above water, but about half of it is washed out.  The ground over there is heavier and it dries out slower than our land.  It might be possible to plant late cabbages over there, but at this point I am not counting on it.

All this has put us in a bind for tillable acres. I figure that we are short about 1/3 of the land I was planning on planting. The only ground that is accessible is part of the field that was in oats and peas last year. It was supposed to get a second soil building crop of sorghum sudan grass this year, but I have decided to plow some of it and start planting there. It feels a little like eating our seed corn,  but there are not any other good options, especially if we get 2-3 inches of rain in the next week.

With spending all of our time on planting we had gotten behind on weeding. A crew of about 20 people from Common Roots came by on Tuesday and helped us get caught up on cultivation.  They hoed all the onions, most of the peas, and about half of the potatoes.  It was great. And we got a break from planting.

Monday June 16

We picked up another 2½ inches of rain over the weekend. We did not need that much, but it seems to have come down slow enough or with enough breaks that we did not get any severe erosion. Once it dries up a little I’ll be able to see if the soil got packed from the heavy rain.

We did get all the pumpkins, zucchini, and cucumbers planted. Noelle was excited to see that the little fruit behind the female flowers on the green and yellow zucchini that she had hand pollinated last year were indeed green and yellow. In theory, we (she) can grow seed for all the vine crops.  Cucumbers are next.

Dave Rieder stopped over Friday afternoon to fix a broken shingle on the barn and helped Andrew, Noelle, and Zach set out all the tomatoes, peppers, and eggplant that we will be selecting  seed from this fall.

Our CSA will start up this week. We will be dropping off the first CSA shares on Wednesday. I have sent out a separate mailing to our members to verify their choice of pick up location. If you are one of them and have not seen that message, please let me know.

A Wet Week update

We have had ( as of 6 am) 4.2″ of rain since Saturday night and a little over 5″ in the past week. It is wet. We did get about 900 kale and cabbage plants set out while the weather was nice last week. I seeded a few rows or radishes and arugula too.

Seeds are still showing up
This is $276 worth of squash, broccoli, and cabbage seed.  There are a total of 4000 seeds in those packets.

Knowing that the rain was coming I tried to get the oat and pea green manure crop seeded on Friday and Saturday. Disking and most of the planting of the oats went well, but
progress came to a rather sudden halt when I drove through a dead furrow while turning around and snapped the the spindle off on the right front wheel.
Here is another view where you can see the dead furrow and the grain drill behind the tractor.
I had broken the spindle on the other side about 15 years ago trying to pull out a dead apple tree. At that time our neighbor Marty welded it up and I put it back on.  After that I had bought a spare spindle just in case the weld didn’t hold. The welded spindle is fine to this day.
The spare does not look a well made as the original, but the tractor was fixed and moving again in about an hour. I did not get the peas finished, but did get them planted in what would be the wettest part of the field. Now if it dries up even a little I can plant the rest of the peas and not get stuck or make a mess. Hopefully the weather will dry out at the end of the week and we get back to planting.

GMO bill hearing

GMO Labeling Law Hearing

There is a hearing tomorrow morning in the House Commerce and Consumer Protection Committee on House File 3140, the GMO labeling law. It is an informational hearing that sets the stage for trying to pass the bill next year.

Please contact the committee and thank them for holding this hearing. If one of your representatives is on the committee, all the better.  It won’t hurt to add a brief statement why you think Genetically Modified ‘food’ should be labeled.  Be polite and to the point, we want them to help us.

I was surprised by the warm reception I got from our Republican state Senator when I talked to him about the bill when it was being introduced.  Accurate labels are important if we are going make good decisions about what we are eating. A link to the Commerce Committee is below.

Since this is an informational hearing, it is not critical that you contact them today, but sooner is better than never…




GMO Labeling rant

Labeling GMOs Rant

GMOs are wrong on so many levels it is hard to know where to start.  Not labeling GMOs in our food has got to be the dumbest thing that humans have ever done.

Hey, I have a great idea. Lets introduce a novel protein in our food, something that no food has ever had. Now, lets feed that ‘food’ to everyone and see what happens.  Genius. What could go wrong ?

If you are over 50, you probably remember pizza mix in a box. Do you remember anyone who was allergic to milk, soy, wheat, etc. when you were a kid ? My brother had hay fever (asthma) and maybe one kid in grade school couldn’t eat shellfish, but me being a clueless kid, he might have been Jewish.

Food allergies in children have increased 50% since 1997.  GMO crops were introduced in 1996.  England kept GMOs out until 1999.  Food allergies increased by 50% in one year after their introduction. It’s not like there was a breakthrough in detection methods that year.  What changed in their diet ?

But the big chemical companies that control our food supply say that GMO crops are safe.  And profitable.  I don’t understand why I have never seen one long term study that investigated the result of feeding GMOs and said they were safe to eat.  If they exist, wouldn’t they be plastered all over the internet ? Lets not review the  Monsanto people nor the revolving door process that lead to the approval of GMO crops. You know, it is looks like corn or soybeans, it is perfectly safe to eat.  Michael Taylor says it is so.

It is more than interesting that every bag of GMO seed has a contract on it that says you can not use this seed for any research without permission. Clearly no permission has been granted since no food safety research has been done with these seeds.  Why is that ? Is there something they don’t want us to know ?

Those sneaky Europeans have repeated Monsanto’s GMO feeding study (no doubt without permission) with the same number and type of rats. Except that the European study ran for two years instead of just 90 days  The rats developed all manner of horrible tumors and basically died like flies.  For some pretty flimsy reasons, the journal that published the paper retracted it after publication. They didn’t say  the results were incorrect or the method was bad. I’m sure the board member from Monsanto had nothing to do with it.  Just a  coincidence to be sure.

GMO crops don’t come with little rain jackets to protect them from RoundUp, they absorb it just like the weeds. Once they take it in, they  metabolize some of it into aminomethylphosphonic acid (AMTA), but they really can’t do anything with glyphosate or AMTA. At harvest the plants contain both RoundUp / glyphosate and AMTA. Both are toxic.

Remember the story in the news for a day last week about Argentina where cancers in  agricultural workers increased by 90% and their children are 4 times more likely to be born with birth defects in the last 15 years since industrial agriculture and GMO crops have moved into the area ? Or was it about the chronic kidney disease that is killing droves of farm workers in El Salvador, Sri Lanka, India, all places with widespread glyphosate (RoundUp) and 2,4-d use ? Toxic.

The chemical companies say that these chemicals are absolutely profitable safe.  And who would doubt that the have our best interests at heart ?

On another level, GMO crops are such an abject failure that the chemical companies are having to reconfigure their genetically engineered crops to be resistant to even more toxic chemicals. Weeds have become resistant to RoundUp (glyphostae)  and  those oh so clean soybean fields were the reason that farmers adopted GMO crops so quickly.  The neighbors will talk if you have weeds in your beans.

Being the brilliant, far sighted thinkers that they are, folks at the big chemical corporations that control our food supply didn’t realize that weeds would become resistant to years of repeated application of the same herbicide.  Weeds have been developing resistance to chemicals since the introduction of herbicides.  The claim that GMO crops would reduce the use of chemicals has been proven to be so much corporate BS.  But hey, they say it is safe.

Now they want to add 2,4-d and Dicamba  resistance to GMO crops to deal with the weeds that are resistant to RoundUp.  Another master stroke. THAT will solve the problem once and for all. Except maybe for the weeds that are already resistant to 2,4-d and Dicamba.  And since the crops will look just like corn and soybeans, the FDA and USDA will decide that they are perfectly safe to eat and will not require any long term safety studies.  This is profitable safe too.

Remember the little rain coats that the plants don’t get to protect them from RoundUp  and how they absorb the chemicals ? 2,4-d and Dicamba are much more toxic than glyphosate.  We will be eating those too.

I get invited to talk about organic farming fairly often. With college level classes I like to ask a few questions to see what the audience is interested in and kind of where we are at.  At some point, my questions for the audience go like this:

“Who eats a mostly organic diet ?” Usually one girl raises her hand.

“Who eats Genetically Modified foods ?” Only the same girl ever raises her hand.

Looking around the room I have to ask “What do the rest of you eat ?”

That is usually met with blank looks. I explain that 80+% of all the ‘conventional’  corn and soybeans in the American diet are the product of genetic engineering.  This appears to be new information for these people.

We are unwittingly taking part in an uncontrolled pesticide feeding experiment. There are no controls. And when something goes horribly wrong, there is no accountability.  There is no option to opt out, people don’t even know they are participating.

You should know what endocrine disrupters are. If you don’t, fire up the google and search for ‘warren porter endocrine disrupter’. Should pregnant women be eating foods containing endocrine disrupters, i.e glyphosate ?  Who doesn’t want some bizarre chemical affecting hormone levels for a developing baby ?  What could go wrong ?

Why not let people know what they are eating and let the marketplace decide if these are good things ? Isn’t that the way the free market works ? The answer is, obviously, that corporate profits would suffer. Corporations are people now and money is not property, it is speech, So big chemical companies have a much louder voice than the 90% of flesh and blood Americans who think that GMOs should be labeled.

Don’t worry about the farmers, They will happily buy cheaper seeds and grow what ever the market demands. GMO crops feed the world’s cattle. The world’s poor feed themselves. Really.

Ask to see the data when confronted with what sounds like corporate BS.  It usually is. Remember, ‘Figures don’t lie, but liars can figure’.

I have enough risky things to deal with. Eating novel proteins along with endocrine disrupting and toxic chemicals is one risk that I and everyone else would surely choose to avoid if they knew about it. If GMOs were as wonderful as the chemical companies make them sound, cereal packages would have “NOW WITH MORE GMOs” plastered all over the front, but they don’t.

We have a Right to Know what we are eating. Just Label It.

Greg Reynolds

Riverbend Farm

Delano, MN

Certified Organic since 1994


Spring update

The snow has mostly melted and the chickens are outside again.

Seed potatoes have arrived and are in the root cellar.

Newly fabricated parts are being installed on the combine to replace

frame parts that were bent when the bean lifters dug in last fall.

The greenhouse is filling up.

The fields are not turning green yet.

Biennial brassicas are reviving after a long cold winter in the root cellar. These will be set out and allowed to produce seed. There are 2 kinds of radish, 2 turnips, 3 cabbage varieties, 4 kale, and several types of onions (that are not in the picture).





It’s spring. The snow is melting even if it is not exactly warm outside. The fields where we will be working are largely clear. A flock of 30 or so robins stops by in the evening and searches for bugs in the flower gardens. The puddles are draining so I think the frost is starting to go out.

I was planning to change the greenhouse heater last Saturday. The forecast was for it to be above freezing overnight so it there was a hold up, it would not be a disaster. Saturday morning the old heater was kaput. Gas valves don’t seem to like the heat and humidity in the greenhouse. The hardest part was moving the old heater. It was full of antifreeze and had been kind of built into the corner behind the germ chamber. Once it was out of the way I used air pressure and a hose to transfer the antifreeze to the new heater. By Saturday night it was up and running. It is nice to have a working pilot light system again and a burner that puts out the rated amount of heat.

It has been a little cool in the greenhouse with the fading heater so the early tomatoes, peppers, and eggplant (for plant sales) are a little slow, but the cool season crops have been loving it.




Late Winter Newsletter

March 10, 2014

Riverbend Farm Late Winter Newsletter


It has been a real winter. It feels like I spent most of January plowing snow. We could get another foot of snow this month, but it feels like it is over. The sun is coming back north. The birds are singing. A wasp thawed out and was staggering around on the window sill this morning. I have moved enough snow that I can get into the greenhouse again. It didn’t help that the doors were iced shut, but with the warm weather the past few days it is all good. Today I’ll start heating up the floor to get ready for starting onions and herbs. I’m also going to test the germination of the seeds that we saved from last year.

Meeting season is over and it is time to wake up the next farming season.

At the Northern Plains Sustainable Ag Society meeting I came up with a vague idea of a farm breeding club to produce locally adapted vegetable seed. We would select varieties to do well in our region and produce the seeds. At first it will probably just be a club  or coop where we share the seeds between the farms that are growing them. In the future I see it being a local seed company, a place with a catalog of seeds for local growers and home scale vegetable gardeners.

If you have a vegetable garden and are interested in participating in a beta test I have some vegetable seeds that were in 2012 and grown out in 2013. I know that these produce good fruit. I also have some seeds that were saved from 2013 that have not been grown out. I’m very confident that they will also be productive since I’m planning to use a lot of them this year. Send me a note and I’ll send you my seed list. Packets will $3 each plus $1 for envelopes and postage.

Most of the varieties are straight ahead Open Pollinated varieties, but some are seeds saved from hybrids.  F2 seeds are saved from hybrids so they produce a lot of variation. All of the F2s that we grew out last year produced useable veggies, but the size, shape, and color were all over the place. Some of those variations will become new varieties. F3s are the result of selecting the plants and fruit with the best characteristics of the F2s from last year. They will be less wild, but will  still have a fair amount of variation.

I will have organic vegetable transplants available for sale this spring. There will be all manner of tomatoes ranging from big reds to cherries to heirlooms and paste (roma type). In addition to bell peppers there will be red and yellow sweet peppers, and many hot peppers. Eggplants, onions, herbs, and a few flowers will round out the mix. The plants will be available at the Birchwood around Mother’s Day, at the Saturday Delano Farmers Market, and here at the farm.

Our Sustainable Farming Chapter has been pushing around the idea of doing something with locally produced food, beyond fresh produce. Catsup, pickles, and who knows what else ( pop and potato chips would be popular, but were ruled out early on). Last fall Carl over at Three Crows tried making a test batch of kimchi using all local ingredients (except for salt) to see what the process would be like. He used cabbage, onions, the real deal Korean kimchi peppers, daikon, and smoked hot peppers (in place of fish sauce) all from our farm. It is spicy, but not too hot. Now I have jars of local kimchi available for sale.  Pints are $9, Quarts are $16 and Half Gallons are $30.  If you are interested, let me know. Mary is addicted to it.

A couple things coming right up on GMOs. The USDA is getting ready to approve a new generation of RoundUp ready seeds that will be resistant to Dicamba and 2,4-D.  The first generation of GMO crops was a failure due to the creation of RoundUp Ready resistant weeds. So now they want to add much more toxic and likely to drift chemicals to the mix to fix that problem. It didn’t work the first time, so why not do it again ?! Seems crazy to me.

One of the big problems with Dicamba and 2,4-D is that they drift a lot more than RoundUp and they can drift for miles days after they have been applied. The drift will affect everyone not growing GMO corn or soybeans.  The other problem is that they are much more toxic chemicals.

Today is the day to act. The USDA comment period closes tomorrow. Search for ‘USDA Subject: Docket No. APHIS-2013-0042 ‘ and make a comment opposing the approval for these crops.

Closer to home Right to Know Minnesota is having a lobby day at the Capitol in St. Paul to push for the labeling of GMOs in our food. Unless you are eating an all organic diet you are taking part in a mass feeding study to see if novel proteins in our food have undesired health effects.  If you would like a chance to opt out of this poorly designed  experiment, labeling GMOs in food is a good first step.

Big Ag and Big Food are spending 10s of millions of dollars to keep food from being labeled when close to 90% of Americans think it is a good idea. It seems important to them to keep us from knowing what we are eating. I get the idea that these corporations are all excited about the free market doing its work, not to mention I don’t trust them to do what is the best for me.

The event at the Capitol  will be Thursday, but they are asking that you sign up in advance so they have time to set up meetings with your legislators.  See their website at




Saved Seed List

2013 Saved Seed (112 Varieties)


Greens (1)

Arugula (Fedco) 10#

Kale (3)

Red Russian Kale

Rainbow Lacinato


Other Brassica (2)

Brussel Sprouts

Columbia Cabbage

Roots (3)

Chiogga Beets

Purple Top Turnips

Misato Rose

Zucchini (3)

Dark Star

Golden Arrow


Winter Squash (3)

Sunshine F2

Waltham Butternut (2012 Denny Compton)

Delicata (2012 Denny Compton)

Lettuce (3)

Rouge d’ Hiver

Grandpa Admire’s


Peanuts (1)

Tennessee Red Valencia

Misc. Nightshades (3)

True Potato Seed

Aunt Molly

Purple Tomatillo

Peppers (22)

Korean Kim Chi

Sauhuro F2

Aji Dulce

King of the North



Hungarian Hot Wax


Olympus F2

Highlander F2

Trinidad Spice

Alma Paprika



Early Sweet Hungarian

Vietnamese Hot

Revolution F2

Serrano OOHH

Sweet Sunrise F2

Flavorburst F2

Serrano Tampico


Eggplant (12)

Beatrice F3 Oval

Beatrice F3 Round


Clara F2

Classic F2

Nadia F2

Nubia d’ Gandia

White Lightning F2

Orient Express F2

Orient Charm F2

Dairyu F2

Galine F2

Tomato (32)

Granadero F3 1st

Early Girl F3 1st

Early Girl F3 Potato Leaf 1st


Early Cascade F3

Uncle Everett


Martian Giant

Orange You Glad


Paul Robeson



Peron Sprayless

LeRoy’s Orange Banana

Granadero F3 2nd

Cherokee Purple

LeRoy’s Sausage

PROS Brandywine

Amish Paste

Dakota Sport



Early Girl F3 2nd

Early Girl F3 P.L. 2nd

Purden’s Purple


Chianti Rose

Blush F2


San Marzano

FFSC Brandywine


Caro Rich

Pole Beans (11)

Mette’s Gotland Cranberry

Kentucky Wonder (Siskiyou Seeds)

Kentucky Wonder (SSE)

Hidatsa Red

Hidatsa Shield

Scarlet Runner

Trebano Romano

Kelly Farm White

Blue Lake

Golden Nectar

Parshall Snap


Bush Beans (9)

Dragon Tongue

Black Turtle


Royal Burgundy


Gold Rush


Easy Pick

Herbs (1)


Grain (3)


White Sorghum

Wachichu Flint


Field Peas



Comments on the FSMA

Re:      Food and Drug Administration Produce Standards Rule: FDA-2011-N-0921  RIN 0910-AG36

Nov. 12, 2013

We own and operate Riverbend Farm, in  Delano, Minnesota, a small scale diversified, certified organic, vegetable farm. We produce more than 20 types of vegetable crops for sale to our CSA members, local restaurants, grocery stores, and schools.

Food Safety is important to every small farm. If we have a contamination problem and someone gets sick from eating our food, we are out of business.  I take food safety very seriously.

The definition of a facility will make it very difficult for anyone ramping up production on a small farm. Many times a beginning farmer will not have a wide enough product offering or quantity to attract the attention of potential buyers. If they can piggy back their offerings on a more established farm they will have an opportunity to enter the marketplace.  For example: A neighboring farm grows great onions, but is just starting out. No one is going to buy just onions when they also need cabbages, winter squash, potatoes, and turnips.  They meet their produce needs with a farm that offers all of these items.  If the onions can be delivered by a farm that has most of the above items, both farms can benefit. A low limit (5 items) on the number of items delivered from other farms would solve this.

The proposed rules for applying composted manure are in conflict with the NOP standards for composted manure.  There is no documented case of anyone getting sick from produce that was fertilized with compost in accordance with the NOP standards. And the NOP standards are over the top for anything but sewage sludge. Align the proposed rule with the NOP standards. The FDA may also want to consider including best practices for handling raw manure in the new rules, i.e. incorporate the raw manure within 24 hours to minimize nutrient loss and the potential for water ( surface or irrigation ) contamination.

The proposed rules should include language to encourage the use of conservation practices that enhance beneficial insect habitat, provide windbreaks for soil erosion control and limit pesticide drift.

In many instances it is completely impractical to exclude wild animals from farm fields.  Training on how to identify scat and droppings would go a long way towards eliminating that as a possible source of contamination. A list of ‘animals of concern’ may be interesting, but not useful in many instances.  For example, what happens if our neighbors on three sides have habitat for listed animals ? 

Under the Produce rules for the ‘qualified exempt’ farms the income limit should not apply to commodity crops unless all commodity crop farms are subject to the proposed rules.  Since commodities are not regulated under the Produce Rule the value of them should not be considered as income for a produce operation.

It is not clear what would cause a qualified exemption to be withdrawn. I can’t tell from reading the proposed rule what would trigger that withdrawal nor what actions would prevent it.  It is also not clear how a farm would earn back the qualified exemption.  As a small farm we do not have staff to do extra paperwork and documentation. Losing the qualified exemption status ( for unknown reasons) would probably put us out of business.  This could be improved by stating what kind of problem would lead to withdrawal of qualified exempt status, what would be acceptable documentation to prevent withdrawal, and including a process to regain qualified exempt status.

The estimated cost to comply with the regulations would seem to favor large scale operations, perhaps another facet of an unstated, but misguided  ‘Get Big or Get Out’  policy.  Current trends show that the number of small farms are  increasing to meet the demand for local food.  Preventing these farms from operating is not going to help satisfy that demand and will not appreciably affect food safety. The vast majority of people who suffer a food borne illness are eating products from large scale operations. To put a undue portion of the cost of insuring a safe food supply on small farms makes no sense.

An integrated approach to producing safe food makes the most sense. We grow  more than 20 different kinds of produce,  several types of cover crop seeds, and large areas of green manures.  To treat each crop separately would be a  logistical nightmare. The details may differ if a crop  is lettuce or tomatoes, but avoiding contamination in the field,  during harvest, cleaning, packing, and storage are common to every crop we produce.

Thank you for your consideration of this.

Greg Reynolds

Riverbend Farm

5405 Calder Ave SE

Delano, MN 55328