The debate over genetically modified organisms (GMOs), however, may change this paradigm. As more markets reject food that contains GMOs (or includes components produced from GMOs), the momentum builds for "identity preservation" of commodities. For example, Land O’Lakes and Cooperative Business International recently formed a venture, Specialty Grains LLC, that will provide producers "improved access to foreign markets for value-added and identity preserved grains," with an initial focus on identity preserved soybeans and white corn (http://www.farmcredit.com – Reference Library Directory). Moreover, as economist Mike Singer predicts, "next year’s GMO crops likely will need to be segregated, tested, labeled and regulated" (http://www.farmcredit.com – Reference Library Directory). If he is right, ecolabels for corn and soybeans may be a prospect in the near future. Nevertheless, the central question remains: Will consumers be willing to pay a price premium for an ecolabeled good?

In this section, we assume that: 1) farmers’ current practices are designed to maximize yield and quality and minimize production cost; and 2) it would be less efficient to engage in more environmentally friendly farming techniques. In fact, environmental management systems may result in cost-savings that were previously hidden, but we defer consideration of this contention until Subsection C, below. We also assume for the moment that state regulation or subsidies are not part of the equation: the question is thus purely whether consumers are willing to pay more of a premium than they already are for food that has been grown in more environmentally friendly ways. Our analysis of the problem indicates that:

• There may be a latent demand for corn and soy products that are not organic, but also not commodities. There currently seems to be a strong foreign demand for this sort of product, but very little domestic demand.
• Current labeling systems—largely organic—for field corn and soybeans, operate with third (or sometimes second)-party certification. The financial opportunities they offer have been a partially effective method of inducing some farmers to conform to the criteria behind said labels. As with conventionally produced crops, much of this environmentally differentiated corn and soybean is sold in foreign markets. It is possible that the lack of domestic demand is the result of a coordination problem; that is, the domestic market has failed to develop a coherent non-organic, environmental label.
• The main defect of the current regime is that it is too complicated and diffuse, particularly with respect to "life-cycle assessments" (practices not affecting the health characteristics of the final product).
• ISO 14000 would increase rather than reduce complexity and would not generate market power for farmers who undertook the expense of complying.

Since there is already a rapidly growing market for organic crops—which the federal government is poised to standardize, the most promising new opportunity would seem to be in production systems that do not conform to organic standards, but that afford environmental benefits beyond that typical for a given commodity crop (e.g., chemical fertilizers used, but more restricted use of pesticides). The most important questions are therefore: Are there consumers who might be interested in products in such a niche? How much more would these consumers be willing to pay for these products?

We have found no data answering these questions. However, more general facts suggest the potential viability of this niche. First, there are fairly good data indicating that people are beginning to think about the environment when they go shopping, at least up to a point. Although many consumers consider the relative environmental impacts when purchasing products, a smaller but still substantial number will actually pay a premium for such attributes. A data set gathered in 1991, during the first great wave of eco-labeling enthusiasm, was summarized by one observer as follows:

[The] poll found that seventy-five percent of those surveyed considered important the environmental reputation of a product manufacturer, but only fifty-four percent actually selected a more expensive product for environmental reasons. Similarly, fifty-eight percent of adult men in a separate survey said that aerosols should not be used; yet, eighty-seven percent had purchased aerosols in the previous six months. Nevertheless, the number of consumers considering environmental impacts in their purchasing decisions remains substantial. Nearly one in every two consumers has altered his or her purchasing decisions to help protect the environment.

(Church, 1994. pp. 253-54)

The high price of organic produce is another factor that suggests the viability of a non-organic niche for eco-friendly corn and soy products. On the one hand, food costs in the United States are such a small percentage of average personal income that there would seem to be some room to persuade consumers to pay something above the commodity price. This is supported by the 20% annual growth of the organic market during the last five years (Gutman, 1999). On the other hand, organic products cost considerably more than conventional—although the difference is becoming less pronounced. For example, food-grade soybeans sold for approximately $6 a bushel last year. Food-grade beans that were certified as having been grown chemically free (no pesticide or herbicide applied after planting) sold for approximately $7. Organic food-grade beans sold for $19 to $22 a bushel. (Interview with Pearcy Grain Services, a small family-owned processor of soybeans in Illinois). While the chemically free food-grade soybean market has traditionally been served by small, family-owned processors, the large agribusiness companies have recently made a strong push in the direction of all niche markets (Pearcy, 2000).

We are primarily concerned here with that segment of the corn and soy crop that is destined for human consumption in the form of oils, syrups, tofu, corn, etc., as opposed to animal feed and industrial uses. The human food uses are a small part of the corn crop. Of the portion sold domestically, less than 17% of the United States corn crop is for human consumption. Much of that is in the form of high fructose corn syrup sold to food processors to incorporate into their proprietary beverages, breakfast cereals, etc. About 75% of the crop is dent corn used as feed for livestock. Much of the remainder is used to make ethanol (National Corn Growers’ Association, 2000). Most soy, however, is ultimately fed to humans in the form of oil and foods such as tofu (American Soybeans Association, 2000).

It is unclear whether consumers will show the same level of concern as more transforming processes intervene between the crop and the consumer. On the other hand, the link between health issues and environmental issues is unusually strong with agricultural products. This factor may serve to heighten consumer interest to a higher level than has been observed with other products (e.g., paper products).

A final distinction may be relevant in assessing consumer demand for more eco-friendly corn and soybean products. This is the difference between practices that actually affect the qualities of the crop at the time it reaches the consumer (e.g., less pesticide residue), versus farming practices that include environmental PPMs, (e.g., lower water usage, less cultivation of riparian areas), but do not change the end-product. The industry sources we spoke to were quite adamant that the latter sort of improvements, known in the literature as improvements flowing from "life-cycle assessments," would not command a premium with consumers (Interview with Keith, 2000). However, "life-cycle" attacks have been successful on a few occasions, at least where the bad practice was visibly part of the product, as in the campaign to get McDonald’s to abandon polystyrene hamburger containers.

Some of these distinctions are borne out in the niche markets for more eco-friendly corn and soy products that already exist. These markets are discussed in the next subsection. Overall, we should stress that we have been unable to find any evidence confirming or denying the existence of still-unsatisfied demand for a more moderately priced, non-organic, eco-friendly corn and soybean crop. It is clear that there is cautious interest in this area among processors and retailers. The interest is even greater among growers—the sector least able to drive the market—as they are seeking opportunities to increase income and decrease reliance on undifferentiated commodities.

Since consumer demand is the only driver being considered at this point in the analysis, it is logical to ask whether the market is already exploiting this demand effectively on its own. Three phenomena are relevant here: niche markets for eco-crops, identity preservation systems, and monitoring by third parties. Overall, the evidence suggests that markets are partially capable of matching the demand for moderately eco-friendly products with crops that meet that demand. However, this finding is limited to situations involving tangibly superior end products (e.g., fewer pesticides on the final product at the loading dock). Market mechanisms may be less capable of valuing "life-cycle" improvements that do not affect measurable qualities in the end product. However, as we noted in the previous sections, it is not clear that consumers are interested in products that have been grown in a more environmentally friendly fashion, and yet are not tangibly or even symbolically better in terms of health characteristics.

There are already small niche markets for post-harvest, chemical free corn – corn that contains little or no pesticide residues when it is delivered from the farm – as well as certain types of soy products. These products are sold primarily for export to Europe and Japan. They are extremely small fractions of the total crop purchased by the major food processing companies. Our main sources of information here have been Cargill and Pearcy Grain Services (a small family-owned processor of soybeans in Illinois). We note that an ADM grain merchandising specialist also confirmed that ADM passes on to farmers requests from food processors for crops with certain environmental characteristics (Interview with Batchelder of ADM, 2000).

At Cargill, a food manufacturer or exporter may request certain environmental or other criteria, usually concerning pesticide residue (or use) or genetic modification. Cargill then passes on the criteria to farmers. Cargill also agrees to segregate the products, so they are not mixed with conventional products. In return for their added trouble, Cargill gets a premium, part of which is share with the farmer. In addition to the identity preservation system, Cargill operates a verification system to ensure that the farmer has complied with the demands of the Cargill customer. Cargill performs tests to detect pesticides and GMOs. One interesting aspect is that Cargill believes this process adds enough value that it has branded it-"Century Corn." This product has been available for approximately two years (Interview with Pocock, Cargill, 2000.)

Pearcy Grain Services, of Clare, Illinois, has shipped pesticide-free, food grade soybeans to Japan since at least 1995. Mr. Pearcy ships a sample of the soybeans to labs in New Orleans and Missouri where they test for 500 of the more common pesticides. "Chemically free" tags are affixed to the bags of raw soybeans when they are shipped to Japan, along with paperwork from the lab. Mr. Pearcy said that the tag served a function more symbolic than actual, since crops that have been grown in a conventional manner typically do not show post-harvest any residue of the many pesticides and herbicides that have been used on them (Interview with Pearcy, 2000). For evidence of more small operators exploiting the ecological niche for food-grade soybeans sold to Japan, see the listing at: www.ag.uiuc.edu/~stratsoy/ expert/niche95.html. [University of Illinois Extension, "Niche Market Soybeans - Opportunity for Some Soybean Growers in Illinois] Judging by this listing, there seems to be no interest in life-cycle improvements to the farming process that do not result, symbolically or actually, in improvements in soybeans’ chemical features when they are measured at the loading dock.

It appears that the market is less than adept at giving consumers information about PPMs or life-cycle information, i.e., information about the environmental impacts of agricultural practices that do not affect the quality of the end product. Some of the larger verification laboratories have indicated a willingness to undertake life-cycle assessments, but so far, these assessments have proved to be more controversial than the verification business. One of the testing groups is a privately held firm, Scientific Certification Systems (SCS). Its testing procedures are laid out at www.scs1.com/nutrihome. Like its non-profit competitor, Green Seal, SCS performs life-cycle assessments of the entire operation that produces a particular product.

Despite its availability, life-cycle testing appears not to have caught on – though the reasons for this failure do not indicate that more private sector coordination is the solution. Green Seal’s program appears so far to have limited its life-cycle assessment analyses to manufactured products (paper towels, automobiles). It is not clear whether SCS's life-cycle audits are limited in the same way. Moreover, the life-cycle assessments undertaken by these groups have been criticized for involving far more subjective policy assessments than either group lets on. Critics believe that such judgments are better left to democratically accountable public agencies such as the EPA. Is it better to use genetically modified crops that require fewer pesticides and fertilizers? What is an acceptable level of water usage? Of riparian land use? These trade-offs between cost and environment and between different environmental impacts have not been worked out by experts, let alone by the public. Until they are, it would be difficult to create an easy-to-read, uniform life-cycle standard to which farmers could adhere (Staffin, 1996). In this area, there is a clear market failure, though it is by no means easy to see how cooperation by non-governmental actors could remedy the failure.

There are two views on whether the current, completely private eco-labeling regime is doing a good job. One view is that the replacement of the current panoply of private standards with a more unitary regime would actually result in less information being given to consumers and in less choice in the market (Church, 1994; Gutman, 1999). The other view is that some kind of government standard-setting is needed because consumers are overwhelmed with misleading information and producers cannot find a single target to concentrate on hitting (Wynne, 1994). The latter view seems to be the majority view among scholars who have approached this subject (Gutman, 1999).

This view – that greater simplicity is desired – appeals to us as well, at least in this context. Once health issues related to the product itself are out of the way, on-farm pollution is not, as yet, a high priority with American consumers in the same way that, say, saving dolphins was in the tuna fish label campaign. Given the current low emotional investment by consumers in the on-farm pollution problem and given further, the highly processed character of most corn and soy crops (discussed above), it is reasonable to surmise that consumers will factor environmental issues into their corn and soybean product purchases only if these issues are crisply presented.

The key question is whether ISO 14000 would help overcome information deficits in the existing private market that may be hampering the development of domestic ecological niches for corn and soybeans. But in terms of labeling, ISO 14000 adds very little. It allows for certified farmers to develop their own labels, if they wish, and requires that claims on the label be proved either beforehand by auditors, or afterward by interested consumer groups (Stauffer, 1997; Lathrop & Centner, 1998). However, ISO does not provide any mechanism for farmers to develop a uniform label; that is, to supply the key information deficit in the marketplace. If anything, the ISO process encourages farmers to make environmental improvements that are specially tailored to each particular farm, or at best to a group of farms. It is true that under ISO, individual farmers might achieve substantive, self-defined goals that would otherwise have eluded them. However, it would be extremely difficult to convey this achievement to consumers, since each farmer would have different goals.

Nor can an identity preservation system solve this problem. Even where an identity preservation system is used for a niche crop, within that niche the processor will need to mix one farmer’s crops with the crops of many other farmers. All the farmers must come up to the standards of the niche if the standard is to have any meaning to the consumer. This would be impossible under the ISO 14000 regime, which operates on a pluralistic model antithetical to any ready summarization for casual consumers. Moreover, ISO 14000 has lots of (costly) requirements that would produce no tangible differences in the end product.

What about life-cycle assessments, that is, information about farming practices that do not affect the end product’s health characteristics? The market failure here is serious, but again ISO’s pluralistic model offers no real solution. Of course, ISO’s focus on record-keeping and improving the whole organization is a distinct advantage in implementing a life-cycle auditing regime. Indeed, ISO requires a life-cycle assessment, an area where the private sector appears to have fallen down. But what is not clear is that consumers value improvements in this area enough to be willing to pay for it in the supermarket. Additionally, it is uncertain that, even if consumers were willing to pay, that ISO is the appropriate vehicle to "sell" products that are the same as any others in their health and pesticide characteristics (but have been grown in an environmentally friendly fashion.) Again, the flexibility of ISO is the problem; consumers don’t know what they are getting for the money, and we believe they will want a simple label to tell them. The information complexity of a life-cycle assessment will require a lot of tricky judgments and simplifications, and ISO provides no consensus mechanism to accomplish this on a mass scale. Moreover, ISO specifically prohibits using labels advertising ISO certification itself (Interview with Castelnuovo, National Farm*A*Syst, Madison, Wisconsin, 2000).

Thus, we are pessimistic about the possible success of ISO 14000’s in the absence of some kind of government intervention, whether in the form of additional regulation or a subsidy. One study of ISO 14001 registration in the business and institutional furniture industry concluded: "ISO 14001 registration is seen as a non-value-added process with uncertain benefits" (Ruddell & Stevens, 1998). It is hard to see why this conclusion would be different in the food business, where the purchasing decisions by end-users are much more casual and price-driven. While the domestic corn and soybean market may have failed to identify and market an eco-friendly product for which there is latent consumer demand, and while a low-cost, simple, and substantive EMS may cure this failure, it is fairly clear to us that ISO 14000 is not such an EMS. The market failure with respect to "life-cycle assessments" is much more obvious, yet here the complexity of the issue, and the amount of consumer education that will need to occur, are such that private coordination efforts are not likely to succeed.

In general, the ISO system is predicated in part on the notion that businesses can run more efficiently if they can gather information and process it more scientifically. ISO 14000 is perhaps something of an exception to the general ISO rule, since some improvements in environmental efficiencies do not necessarily result in cost reductions for the private businesses that have undertaken the improvements. Yet there are some areas where cost reductions are in fact likely to flow from better environmental performance. In this section, we attempt to identify those areas.

Although environmental standards are generally perceived as additional economic burdens on farmers, many elements of EMSs, particularly those that aim at improving the efficiency of operations, present opportunities for cost savings. Conservation tillage, soil nutrient testing, and integrated pest management are examples of environmentally superior practices that may save farmers money (Runge, 1997). The former two practices reduce the need for fertilizer applications, while the latter practice reduces the need for pesticides. In addition, farmers who reduce their energy and water usage will save on utility bills. However, government subsidies counteract this incentive for water conservation.

Many small farmers do not have the resources to analyze and optimize their operations. With proper assistance, farmers who implement EMSs, are likely to identify wasteful practices. By reducing or eliminating these inefficiencies, farmers will realize cost-savings. "It is clear that ‘good management practices’ improve the economic results of the farmer through better utilization of resources like nutrients, chemicals, medicine, energy, water, etc." (Bergstrom et. al., 2000, p. 11).

If environmental management can translate into larger profits, why do Midwest farmers so rarely implement environmental management systems? First, it should be emphasized that not all elements of EMSs realize net cost savings. To the contrary, elements such as riparian buffer zones may significantly reduce production—in this case, by decreasing the acreage available for production. It is possible that more Midwest farmers would implement EMSs if the elements were restricted to those that generate cost-savings. However, the tradeoff would be a lower level of environmental protection for society, as certain, perhaps larger, environmental impacts are overlooked. The second barrier to EMSs is the large up-front cost of implementation. Our Cargill interviewee referred to an internal study indicating that it would cost a farmer $25,000 to win ISO certification – an amount approximately equal to many farmers’ annual net incomes (Pocock interview, 2000). While collaboration among farmers may spread out the record-keeping and auditing costs of certification, and while some costs may be offset by long-term payoffs, the costs are still high enough to discourage experimentation. Initially, farmers must be convinced that it is worth exploring the potential benefits of EMSs. Then, they (and where, applicable, their consultants) will need training in environmentally superior farming practices. These barriers could be surmounted through a coordinating body (government, NGO, or trade organization) that provides loans or assistance with start-up costs, disseminates information, and offers training workshops.

Another potential economic incentive for environmental stewardship surfaces through agreements with loan and insurance agencies. These agencies may be willing to offer discounted insurance and/or loan rates to farmers who adopt EMSs or other environmental PPMs, if it can be shown that these practices increase profits or reduce risks. An environmental audit, for example, may address safety risks associated with the handling of hazardous materials (e.g., pesticide storage), while groundwater stewardship and water conservation may reduce liabilities associated with groundwater contamination, runoff, and flooding. These programs are "at the forefront of preventive insurance." This is the conclusion that the North Pointe Insurance Company reached after investigating Farm*A*Syst (FAS) and the Michigan Groundwater Stewardship Program (e-mail from Ruth Kline Robach, via Castelnuovo). In fact, they agreed to offer lower insurance premiums to farmers who completed FAS assessments. Three progressive stages of environmental management entitled farmers to 5%, 5%, and 10% premium reductions, respectively. Although North Point Insurance no longer participates in the program (they ceased their farm insurance programs altogether), another insurance company, Auto Owners, now offers the same discounts over an eight-state region. Moreover, the Antrim Conservation District of Michigan has received an EPA grant to expand this program. The District hopes to sign on the Farm Bureau, for nationwide coverage, and would like to see the program applied beyond liability insurance to include all pollution prevention programs. However, the District notes that they currently have limited resources to run this program and that more publicity and more farmers are needed to ensure its success (personal correspondence with Janet Person, Antrim Conservation District).

Benefits of the Farm*A*Syst program have also been recognized by AgriBank, a regional funding bank for Farm Credit Services. [an 80-year-old, a $60-billion, nationwide network of lending institutions—the largest single provider of credit to American agriculture.] They have included FAS as part of their due diligence process and, in some cases, are offering lower interest rates to farmers who employ "Best Management Practices" (personal correspondence with Castelnuovo, Farm*A*Syst).

Midwest farmers should work cooperatively, through a coordinating body and with the Antrim Conservation District, to locate insurance companies and banks that may be willing to offer insurance and loan discounts to farmers who implement EMSs.

Particularly at the implementation stage, EMSs are costly and ISO 14000 is very costly. Yet once farmers are over the implementation hump, thorough accounting and record-keeping of environmental practices may lead to some cost-savings, in the form of lower insurance costs, and more efficient and sparing use of soil, pesticide, and water resources. However, the critical question is about the size of these cost-savings and whether they outweigh the implementation costs and the cost of additional record keeping, year-to-year. The case studies (considered in section IV) are our best source of information on this question. They indicate that the financial benefits to the farmer do not greatly outweigh the bureaucratic costs – and thus, there is little incentive to go forward.

Since consumer-driven environmental stewardship for agricultural commodities is problematic (at least for now), this section focuses on interventions by government and NGOs. Specifically, it explores the potential to create a market for environmental stewardship via taxes, subsidies, and/or tradeable pollution permits. Each of these mechanisms presents the opportunity to assign prices to environmental harms and internalize their associated costs.

EMSs are essentially a form of self-regulation, in which the farmer identifies his own environmental problems. This approach to fixing environmental problems has the advantage of early detection. For example, it is much cheaper to prevent a hazardous waste spill than it is to clean it up and pay for the damages it incurs. The proper handling of hazardous materials and reduced runoff and flooding has great potential to realize cost savings for society (or government) as a whole. Stated more generally, pollution prevention is cheaper than downstream (end-of-pipe) remediation (Runge, 1997). However, this is only true from the perspective of society as a whole. From the farmers’ perspective, the costs of pollution prevention are very real, while the cost-savings are virtually imperceptible (since they are shared with all of society). Pollution prevention and EMSs place a disproportionate burden on farmers without corresponding benefits. For farmers to justify economically their implementation of EMSs, the benefits (cost-savings) to society must be returned to the farmer in some form of economic incentives.

A pollution tax assesses a fee for environmental damages. For agriculture, this fee may take a number of forms. It may, for example, be a charge per acre of fertilized (or pesticide-sprayed) soil, or it may be a tax on the fertilizers (or pesticides) themselves. Either way, if the tax is set appropriately, it will drive at least some farmers to reduce their use of fertilizers (or pesticides). It will also create a revenue stream, which the government may in turn reinvest in environmental incentive programs, for example, in subsidies for superior environmental management.

While agricultural pollution taxes may succeed by economic standards, they are likely to fail in the political arena. Historically, in United States agro-environmental policy, penalties have been rare (Runge, 1997). The federal government has far more frequently offered cost-sharing programs or subsidies to reward progressive environmental management, land conservation, or investments in environmental technology. A subsidy could take the form of a price paid to farmers per acre of land farmed under an environmental management system, or per acre of land that is not farmed. In this way, the subsidy compensates the farmer for any losses in crop yield associated with environmental management or land conservation. The federal government’s existing Conservation Reserve Program (CRP), "provides incentives and assistance to farmers and ranchers for establishing valuable conservation practices that have beneficial impacts on resources both on and off the farm. It encourages farmers to voluntarily plant permanent covers of grass and trees on land that is subject to erosion, where vegetation can improve water quality or provide food and habitat for wildlife" (http://www.fsa.usda.gov/dafp/ cepd/12crplogo/page3.htm). This program presents an opportunity for Midwest corn and soybean growers. However, note that "only the most environmentally-sensitive land, yielding the greatest environmental benefits", will be accepted into the program

Of course, the CRP aside, most federal subsidies have the effect of encouraging the over-utilization of resources, and thereby harming the environment. For example, by offering water to farmers at prices below market, government subsidies encourage over-irrigation and discourage water conservation.

The difficulty with administering taxes or subsidies lies in setting the right prices to bring about the desired outcome or environmental target. This difficulty disappears when pollution rights are tradeable. In a tradeable permit system, a governing entity decides upon an aggregate level of pollution and then distributes "rights" to that pollution either freely or through an auction. This system creates a market for pollution (and abatement). The market, in turn, sets a price for the "right" to pollute. One could imagine such a system applied to agriculture. For example, farmers could be given permits for nutrient or fertilizer use. Farmers who reduce their usage below permitted levels could sell their excess rights to other farmers and, thus, increase their profits (Runge, 1997).

Although taxes, subsidies, and pollution rights are most commonly thought to come from government, it is possible for a private party to set up a similar system of incentives (and disincentives). A trade organization or NGO, for example, could offer its members cost-sharing or assistance for implementing environmental management systems. This alternative third party would need to generate revenue for such programs. They may seek funds from government or from outside investors, or they may set up a self-governing system. The latter option could be akin to the various Business Improvement Districts (BIDs) that have arisen in cities across the United States. These quasi-government groups consist of private property owners in a specified geographic area. The group’s members agree to impose a tax upon themselves and to use their tax-generated revenues for improvements to the neighborhood, including, for example, maintenance and lighting. It is reasonable to believe that a similar group and system could work for Midwest commodity farmers. A self-imposed tax could be collected and used to assist farmers with implementing EMSs or used to hire environmental consultants for group members. Although it is hard to imagine that farmers would choose to be taxed for the purposes of environment protection, it is possible that they would agree to such an arrangement if it were tied to other benefits. A BID-like organization may provide a forum for increased access to markets, information sharing, and other forms of assistance, tailored to sector and regional conditions.

Often, industries are motivated to implement EMSs for fear of additional regulation. By pursuing improved environmental performance, businesses hope to avoid regulations and maintain a greater degree of control over their operations. Alternatively, we can think in terms of "getting ahead" of regulations. If a farm or factory starts taking appropriate steps on a voluntary basis, then when the regulations are promulgated, they may already be in compliance or close to it. The fear of regulation is strong and gaining momentum in the farm community as well. As we mentioned earlier, genetically modified organisms (GMOs) are one area where regulation seems to be on the horizon. There has also been discussion of "an EPA proposal to strictly regulate timber harvesting and other segments of agriculture as point sources of pollution using its ‘total maximum daily load’ plan" (http://www.farmcredit.com – Reference Library Directory). In sum, there is some basis to believe agricultural products and processes will be regulated more in the future than they are now, perhaps enough someday to induce farmers to participate in EMSs as a way to avoid government interventions. EMSs can also be used as a means to ease transition to a new regulatory regime. In fact, it is possible that EMSs may become part of the regulatory framework.

Our assessment of the domestic situation is largely corroborated by a review of EMSs that have been implemented on a micro-scale in the United States, and on a larger scale in certain foreign states. These programs have often succeeded, but not without carrot-and-stick interventions by government and NGOs.

We have examined a number of international and domestic case studies addressing environmental issues and management in agriculture, in an effort to learn more about the various voluntary activities underway. The use of voluntary environmental management systems seems to be growing and catching on abroad quickly, often to avoid future regulation, but also in response to rising community concerns and demand for sustainable agricultural practices. Despite the heavy workload and sometimes exorbitant costs required to implement these environmental management systems, there are a number of very real benefits and rewards that may be reaped. Among the benefits are improved environmental conditions on farms, the power of self-regulation, demonstration of responsiveness and confidence to consumers, promotion of market access, competitive advantage, brand image, recognition, and community responsibility.

To date, many on-farm strategies have evolved to minimize environmental impacts and maximize environmental performance in the agricultural sector. In an effort to learn from past and current lessons, methodologies and approaches to several environmental management plans were reviewed. The following case studies reveal the various approaches to design, planning, implementation, and review of environmental performance in agriculture. Common elements that emerge from these case studies are lower levels of bureaucratic formality and lower costs, compared to the ISO 14000 protocol. As one scientist with the Australian project on sustainable grain production said, "For most broadacre farms, hitting them with ISO 14000 first off is like asking them to do a uni[versity] degree when they have not finished secondary school" (Personal communication with Ridley, 2000).

The following subsections are divided in two: each describes a prominent agricultural EMS that has been implemented somewhere in the world and then summarizes the key issues that are relevant to domestic corn and soybean farms.

The Ontario Environmental Farm Plan (EFP), a project of Canada, was developed in response to community environmental concerns. In an effort to forge ahead, local farmers, tired of continually falling short of governmental regulations, decided to mobilize themselves and set the agenda on environmental management issues on farms (Carruthers & Tinning, 1999). Farm leaders created the Ontario Farm Environmental Coalition (OFEC) and worked together with regulatory agencies and researchers in an effort to design a self-audit process for environmental management on farms. This process based on a whole-farm management approach is known as the Environmental Farm Plan, or EFP. EFP is a self-evaluation/best management practice approach whereby farmers complete a series of workshops on 23 modules related to environmental management. An action plan is then drafted, peer reviewed, and submitted for approval (Carruthers & Tinning, 1999).

OFEC requested and secured assistance from the government to provide technical assistance from field staff and development of printed information in the "Best Management Practices" series of publications. Federal funds were allocated for management of the plan, development of BMP publications, and financial aid to implement the plan in the form of an incentive payment to farmers. An incentive payment in the amount of $1500 per farm is distributed to those farmers who complete, implement, and secure approval of their participation in the EFP. To date, 15,000 out of 35,000 farmers have participated (Ridley et al., 1999a).

Interestingly enough, EFP has been directly compared to the ISO 14000 standard because of their similar elements and has been said to be quite compatible. The way it stands now, there are only a few changes that would be necessary in order to achieve ISO 14000 status, as the Ontario EFP is already very close to meeting the requirements. These additions would include the creation of an environmental policy, provisions for third party on-site auditing, and a continuous improvement commitment (Wall, 1998). Currently, Ontario is conducting a number of pilot projects with local farms to learn more about what is involved in actually certifying to ISO 14000 standards.

The Ontario Environmental Farm Plan is a particularly interesting EMS, since it was initiated by the farmers themselves in an effort to streamline and rationalize compliance with existing (and potential future) regulations. The program’s success is likely attributable to three forms of government intervention: tough environmental regulations, technical assistance (with BMP publications), and financial assistance. The third intervention provides for management of the program, as well as $1500 incentive payments to farmers who adopt EFP. The structure and content of EFP, including self-evaluations, workshops (farmer training), and action plans could serve as a model for environmental management of Midwest agriculture. However, the motivations in the United States would vary from those in Ontario. Since Unites States farmers are subject to relatively little environmental regulation, government would need to compensate for this lack with greater technical and financial assistance. It is likely that the incentive payment to United States farmers would need to be greater than the $1,500 offered to Ontario farmers.

New South Wales (NSW) Agriculture in coordination with the Grains Research and Development Corporation of Australia has been facilitating a three-year research project with five farmer groups to determine the likelihood of the adoption of an EMS by the grain industry (Green Marketing Prospect, 2000). By trying out a flexible approach to a voluntary EMS, it is hoped that farmers will recognize the benefits in taking responsibility for long-term sustainability of their farms and in the area in which they live. Among the benefits are the possibility of improved grain marketability and increased access into expanding international markets (Ridley et al., 1999a).

The program is designed to take place in three stages. The first stage involves a review of the current legislation, regulation, and environmental planning issues. Stage two is the facilitation of workshops to develop EMS guidelines for grain production management. This is followed by a third stage where farmers first review generic EMSs and then become involved in customizing and streamlining them for their own use through farm operation plans, monitoring programs, and corrective actions (Green Marketing Prospect, 2000).

By implementing such a program, grain growers may rest assured knowing that they are supporting sustainable farming practices by responding to community concerns of responsible stewardship and consumer expectations for clean and safe products. In addition, the adoption of these ideas may help to lower costs associated with environmental remediation resulting from poor resource management as well as provide the grains industry and growers with an effective and international standard for environmental issues.

A similar endeavor is underway by the Department of Natural Resources and Environment of Agriculture, Victoria, and the Institute for Integrated Agricultural Development of Agriculture, Victoria, to work with two groups of local farmers to develop a voluntary "on farm" environmental management scheme. The project hopes to determine whether a voluntary farm assessment scheme coupled with "best practice" methodology and group learning is an appropriate tool to deliver an effective environmental management system for grain production. Through the use of "best practice," the intent is that management practices will undergo a change from those in which yield of grain crops are maximized to those in which yields are optimized with regard for both profit and the environmental implications of grain production. The "best practice" approach may be thought of as a "bottom-up" self learning and empowerment approach rather than a traditional, more formal "top-down" approach which might stem from increased regulatory pressure (Ridley, 1999).

These projects serve as pilot investigations, which will continue for the next couple of years. The approaches are intended to evaluate the likelihood of the success of such voluntary environmental management schemes on a larger scale. This research is, in effect, the first step towards identifying the ability of farmers to implement "best practice" on farm and understanding their motivation to address environmental issues associated with grain production.

Project proponents realize that economic and social factors play a role in the success of such programs. As a result, further research is needed to highlight problems surrounding the lack of incentive payments, tax breaks, or subsidies to assist farmers with the costs of carrying out voluntary environmental management schemes in Australia. There is an example of partial tax rebates in one area. However, these may only be claimed after a farmer puts up the full sum of money first—an unrealistic expectation for many Australian farmers. Punitive measures have also been mentioned to help encourage EMS adoption. These include the restriction of farmer access to vital elements involved in running a farm such as water or chemicals. (e-mail, Carruthers, 2000).

The Australian cotton industry is believed to be the most progressive and advanced sector in developing environmental management systems for agriculture. The Best Management Practices (BMP) program, as it is known, was developed, initially, to address the negative environmental image of cotton farming. It has been designed to meet community demands for environmental management by assisting industry with self-regulation through proactive implementation of a regulatory framework rather than reliance on conventional, and thus slower, reaction to increased legislation (Ridley et al., 1999b). A number of groups are responsible for the development and implementation of this program, including the Australian Cotton Cooperative Research Centre (CCRC), Cotton Australia, and the Australian Cotton Industry Council (Cotton Australia, 2000). In addition, cotton growers themselves significantly contribute to the program through compulsory and voluntary research levies on the order of $1.75/bale (matched by the federal government), which funds CCRC and $2/bale for Cotton Australia (e-mail, Williams, 2000).

Through the use of self-assessment worksheets, the BMP program aims to empower farmers to develop an EMS that meets the ISO 14001 standard by the year 2001. However, one observer noted that "ISO 14000 may be too big a jump at this stage." Currently, on farm action plans address high risk areas and strive for minimal environmental impact by focusing on people, soil, water, air, and waste. An audit process, consisting of three levels ranging from a self-audit to a third-party audit, evaluates the plan's effectiveness. The BMP committee hopes to develop credibility with outside industries and the general public through the use of the audit and a BMP Manual. The Manual consists of four modules: farm design and management, pesticide application, integrated pest management, and pesticide storage and handling. In an effort to seek continual improvement and encompass a more holistic approach, a few other modules (occupational health and safety, water management, and dryland cotton production) are under development (Carruthers, 1999b).

A pilot program with 34 growers is underway in an effort to evaluate this BMP approach. To date, at least one cotton farm in Australia, Southernstar Cotton, has secured ISO 14001 certification. The Australian Cotton Industry Council will officially launch this program later this year. They hope to achieve a 60% BMP audit rate of Australian cotton farms within 3 years and eventually, total participation by the remaining farms.

Australia’s BMP program encourages growers to take individual responsibility for environmental protection through continuous improvement. The implementation of BMPs may be thought of as a model for the commodity sector, for it combines sound science and practical farm management to help facilitate the adoption of environmentally responsible sustainable farming systems. While the self-regulation element of Australia’s BMP may be appealing to Midwest farmers, the lack of incentive payments and, especially, the farmer contributions to research are unrealistic. It is questionable whether the program will continue beyond the pilot stage in Australia. It is even more doubtful that such a program, without economic incentives, could succeed in the United States. However, feasibility studies are underway to investigate appropriate incentives and drivers in introducing ISO 14000 broadly across the cotton industry in Australia. A range of incentives is expected to be proposed, particularly related to technology access (email, Williams, 2000).

In 1995, the European Union adopted the Eco-Management and Audit Scheme (EMAS) to facilitate environmental policies with considerations for sustainable development of industry and free trade. EMAS has most often been applied to heavy industries in the EU. However, anticipated provisions will transition this plan to the agricultural sector. EMAS focuses on the improvement of environmental performance with a site-based approach, unlike ISO 14000, which is a system-improvement approach. EMAS includes measures toward environmentally sound management, including development and implementation of a formal environmental management system (EMS), auditing and verification of system and environmental performance, documentation and publication of a "Register of Environmental Impacts," and an annual environmental performance evaluation (Carruthers & Tinning, 1999). Additionally, it specifies the use of economically viable application of best available technology (EVABAT) which calls for technological solutions to problems even if they do not prove to be the best option for the situation (Bell, 1995).

The EMAS is in fact more prescriptive than ISO 14000 and commands more extensive levels of public disclosure on environmental performance. This is the result of pressure from government and non-governmental organizations to adopt EMS. Through a series of eight major steps, EMAS hopes to achieve continuous improvement in environmental performance by establishing policies, programs, and management systems (Carruthers, 1999b).

The EU government initiated EMAS in order to fuel competition and recognition in the EU market, facilitate industry’s participation in government procurement plans, and capitalize on benefits from deregulation. The adoption of EMAS by United States farmers would potentially increase their penetration in the EU market. However, the value of EMAS for domestic sales alone would not justify its implementation. By contrast to conditions in the EU, United States consumers are not willing to pay significant price premiums for sustainably grown agriculture, and the United States government has not made EMS a prerequisite for its procurement plans. This latter distinction highlights an opportunity for the United States government to encourage EMS. Perhaps in the future, agricultural procurement plans will specify the need for an EMS similar to the EU’s EMAS. Ideally, the United States program will replace the technology-based standards of EMAS with performance-based standards.

The Linking Environment and Farming Program (LEAF), begun in 1991, is a project of the United Kingdom and part of the European Initiative for Integrated Farming, an alliance of international NGOs and stakeholders focusing on integrated crop management activities. However, in response to public pressure placed on the environmental performance of agriculture, LEAF has since been expanded beyond Integrated Crop Management (ICM) to cover all aspects of farming, including organization and planning on-farm as well as livestock and biodiversity management (Carruthers, 1999b). LEAF is built upon a self-audit process designed to manage environmental issues on-farm. This voluntary whole-farm approach to environmental management affords farmers the freedom to choose the level of participation that is most appropriate for them as well as the security in knowing that the information they provide to LEAF is kept confidential (Ridley et al., 1999b).

The LEAF program aims to develop and promote a few keys areas: integrated crop management (ICM), demonstration farms used for community’s educational purposes, tools/guidelines for farmers, and training and technical information. However, the main component of the program is an audit developed to assist farmers with assessing their environmental performance. The audit includes a self-assessment questionnaire based on seven major areas: organization and planning, soil, crop protection, pollution control and waste management, energy, landscape and wildlife, as well as animal husbandry. Recommendations for areas of improvement and action plans are generated based on the results of the audit. The farmers then use this information to compare environmental performance on farm from year to year in addition to assessing and optimizing inputs in an effort to achieve maximum profits (Ridley et al., 1999b).

The UK agricultural sector views this EMS approach as a useful tool to prepare growers for future environmental responsibility and has responded favorably to it. Some UK food companies are even going so far as to require the completion of a LEAF audit and compliance with integrated crop management in order to enter many fresh produce products into processor or supermarket sales. In fact, companies such as Birdseye, Sainsbury’s, Tesco, and Safeway stores in the UK have released policies which "strongly suggest" completion of audits and protocols in order to gain market entry (Carruthers & Tinning, 1999). As a result, the LEAF brand has been registered and labeling is slated for the future. As of September 1999, the LEAF audit has assessed 10% of the agricultural land in the UK (Ridley et al., 1999a).

The success of this program has been attributed to the farmer-to-farmer support as well as the integrated management approach achieved through the inclusion of all sectors. LEAF suggests the viability of a policy that is cheaper and less formal than ISO 14000. It is a system initiated by NGOs and driven by consumer demand, as evidenced in the requests by food processors and grocery stores. United States agriculture can learn from the farmer-to-farmer support and cost-effectiveness of LEAF, as well as the role of NGOs in its implementation. However, implementation of a LEAF-like program is less likely in the United States (than in the UK) to be consumer driven. Our research, including conversations with United States food processors, indicates that it is unlikely for EMS demand to come from higher levels of the supply chain. Presumably, the processors are unwilling or unmotivated to require EMS, since they are not hearing this demand from their customers (the consumers).

In 1996, the North Ontago Sustainable Land Management Group (NOSLaM) from New Zealand developed "ENVIRO-AG" through a grant from the Ministry for the Environment. ENVIRO-AG is an environmental management scheme based on ISO 14001. It consists of a process for assessment and monitoring of farm activities relating to environmental, animal welfare, and product safety issues. Each farmer develops an "Environmental Farm Plan" based on continual improvement according to his or her individual farm needs. Farmers then audit themselves once a year to ensure compliance with the objectives they have previously outlined. In addition, farmers are also subject to audits by NOSLaM every three years and random audits by a third party called SGS New Zealand Ltd. ENVIRO-AG, supported by research funding from AGMARDT and the Ontago Community Trust, is not an accreditation scheme in itself, but it satisfies the requirements of ISO 14000 accreditation (Overview of NOSLaM, 2000). This has been proven to be cost-effective since system requirements for ISO 14000 are dealt with at a group level (Ridley et al., 1999b). Over 80 properties in New Zealand are now using ENVIRO-AG plans, with a few of the first farms having already advanced beyond the audit to become officially ISO 14000 certified. To date, six farms have achieved ISO status with many more applications pending. Talk of developing labels that state, "This product comes from an environmentally friendly farm" is also spreading (Overview of NOSLaM, 2000).

The NOSLaM program is farmer driven and goal-oriented. Its success may be attributed to strong partnerships between the farmer and community as well as the processors, producer boards, and other industry groups. Perhaps the key to NOSLaM’s success is the government grant and NGO assistance that got the program up and running. NOSLaM has also found the group accreditation scheme to be particularly effective based on the cost-effective nature of group coordination for certification of both ENVIRO-AG and ISO 14000 (Overview of NOSLaM, 2000). The lessons of NOSLaM are especially valuable for application to the United States agricultural sector. We believe that government and NGO assistance with start-up costs, as well as cost-savings from group coordination, are key to the success of EMS in Midwest agriculture.

The U.S. Farm*A*Syst (FAS) Program, begun in 1987 and operating in 46 American states today, is a partnership among government, universities, private businesses, and farmers (Ridley et al, 1999a). This program, developed in response to consumer and community concerns related to pesticide and groundwater contamination, helps farmers determine their risk. This program has since been expanded to whole farm management and provides guidance to farmers in an effort to achieve greater environmental performance and improvement without the fear of punishment from regulatory agencies. By providing direction without specific goals, U.S. Farm *A* Syst remains flexible and can be adapted in different forms by individual states.

This program’s platform, designed around a series of legislated performance standards and best management approaches, was used as the basis for the Ontario EFP and resembles LEAF (Carruthers, 1999a). It consists of fact sheets, questionnaires, worksheets, and action plans. Based on the responses, confidential scores are calculated and recommendations for improvement are formed. To date, 8500 farmers have participated, which is less than 1% of the farmers in America. However, 70% of the 8500 have changed their management practices and 80% have recommended the Farm *A* Syst program to others (Ridley et al., 1999a).

The U.S. Farm*A*Syst program is informal and low cost, centered primarily on the dissemination of information. The major benefits of FAS include improved management skills, reduced risk of regulation, health protection, better credit ratings with lenders, elevated public confidence, and expanded access to financial assistance. FAS is a sign of hope for environmental management of Midwest agriculture. It implies that there is United States demand for environmental management (PPMs), apart from end-product standards. However, the low rate implementation of Farm*A*Syst hints at the small size of this demand. Without consumer demand or subsidies, the incentives for FAS boil down to reduced liabilities and, potentially, insurance and loan discounts. Although these motivations are not currently enough for widespread implementation of Farm*A*Syst, we believe that the program is a scalable model that can be expanded into other regions with the addition of subsidies, expansion of insurance and loan discounts, and greater publicity.

Gårdcertifieringä is a voluntary program that integrates quality assurance and environmental management, allowing farmers to gain simultaneously ISO 9002 and ISO 14001 certification. Elements of the program include a mapping of the farmer’s regulatory and contractual requirements, an understanding of the farm’s environmental impacts, guidelines for future actions, internal quality and environmental audits, and a commitment to continual improvement.

The underlying principle is management by objectives, which means that the manager himself defines the goals he wants to achieve. There is no prescribed level of compliance defined by the system itself, but existing laws and regulations are of course necessary to follow in order to be certified.

(Bergström et al., 2000, p. 3)

Through Swedish Farm Assured (SFA), a program started in 1997, 39 Swedish farms implemented farm certification. These farms included milk, hog, and vegetable production, and ranged in size from zero to more than five external employees. Farmers who participated in this project received financial support, which covered the costs of certification procedures. Several interesting findings arose from a case study of these farmers, as described in "Farm Certification: Implementing and using quality and environmental management systems in Swedish agriculture" (Bergström et. al., 2000). The most interesting observations for the purposes of this paper involve the motives of farmers. The smaller farmers, those with 5 or fewer external employees, "perceived the financial support as a prerequisite for them to work toward a certification at all…To many farmers two months labour [equivalent to the estimated cost of certification] is much more valuable than a farm certificate. Especially when the market signals still are weak" (Bergström et al., 2000, pp.4, 7). By contrast, the larger farmers perceived certification as a valuable tool to improve their management practices. Other motives for certification included product differentiation, price premiums, and expected future consumer demand. Some stakeholders, for instance local authorities, banks, and insurance companies, have responded positively to farms being certified (Bergström et al., 2000, pp.5).

Farm certification in Swedish agriculture is relatively complex and expensive compared to the EMS programs discussed above. For the purposes of their study, Swedish Farm Assured fully compensated farmers for implementation costs. Subsequent surveys of the farmers indicate that this compensation is essential to the program’s propagation. Most importantly, this case study demonstrates that most small farmers will not adopt an EMS as burdensome as ISO 14000 requires, without significant financial support.

If the analysis of current conditions in domestic agriculture provides grounds for pessimism, then the case studies provide some basis for optimism, which is perhaps the best way to conclude our report.

The preceding case studies make it clear that there are different styles and unlimited options for developing and implementing voluntary environmental management systems. It is also evident that an environmental management system need not be burdensome, time-consuming, expensive, and painful. Nonetheless, the case studies confirm our assessment of the domestic agricultural market – namely, that EMSs are expensive enough that some kind of carrot/stick intervention by government or NGOs is required, in the form of subsidies or cost internalizations such as regulation or taxes. Such inducements may be less necessary when and if consumer demand in the United States becomes strong enough to sustain more completely private forms of coordination. Moreover, such demand could allow EMSs to be gradually ratcheted up as consumer awareness grows. The value of an incremental approach is seen most clearly by Ontario Agriculture’s experience in moving towards ISO 14000.

• Subsidies or other forms of financial assistance to farmers who implement EMSs
• Tough environmental regulations/cost internalization of environmental impacts
• Substantial consumer demand for sustainably grown food products (crops grown under environmental Production Processes and Methods).

In most of the case studies, we observed a combination of the above system conditions. In the case of the Ontario Environmental Farm Plan, farmers are motivated both by tough regulations and an incentive payment. In the LEAF program, there is a stronger consumer demand component. Some caution should be exercised when applying these models to Midwest agriculture, since conditions in the United States vary from conditions abroad. Specifically, the United States is notable 1), for having fewer environmental regulations, and an overall lower threat of future regulation and 2), for there being less consumer demand for food that has been grown in an environmentally friendly fashion. While these drivers appear likely to grow over time, current conditions call for intervention by the government or some other third party that can provide financial assistance for EMS implementation.

In most cases, successful EMSs have been highly flexible and have allowed the farmers to determine, or at least participate in, the promulgation of standards. This latter feature, if expanded to allow farmers free rein in developing the EMSs that they will follow, is one way to circumvent the systems conditions. Presumably, the farmers will choose to implement only those environmental management practices that realize net cost savings. Thus, some level of environmental protection may be achieved without intervention; however, other environmental practices that reduce yields (including some that produce large environmental gains) must be compensated.

One overarching lesson from the case studies is that all of these attempts at implementing EMSs follow an iterative and evolving process. The demonstrated successes of these studies have been the result of an ongoing learning process. None of them has achieved success overnight and all of them show an understanding of the complexity involved in reaching a generic EMS or more importantly, one with ISO 14000 stature. As the Farm certification for Swedish agriculture demonstrates, ISO 14000 is too complex and expensive, at least as a first step for environmental stewardship.

• The potential economic incentives for implementing an EMS include price premiums, increased access to foreign markets, and cost savings. The latter two incentives are highly likely; while the former is less certain.
• Without intervention, the market will probably not bring about the desired level of environmental management. Financial assistance, for example, in the form of subsidies to farmers, is necessary to overcome the lower level of regulatory pressure in the United States. However, a domestic market for eco-friendly crops could materialize ex post, diminishing the importance of subsidies going forward.
• There is particularly important lesson to learn from the NOSLaM experience. Specifically, it is possible for environmental management systems to be cost-effective for small farmers with appropriate assistance and coordination. EMS is a realistic target for Midwest corn and soybean growers provided that they work cooperatively through a coordinating body.

The last point above alludes to the role that IATP or another NGO or trade organization may play in bringing EMSs to Midwest agriculture. Each of these organizations may serve as a coordinating body and a hub for information sharing, training workshops on environmentally superior farming techniques, cost-sharing and economies of scale (shared consultants, etc.), cooperative lobbying for government (financial) assistance, and cooperative negotiations for discounts from banks and insurance agencies.

The agriculture sector can forge ahead of government regulation to meet consumer and community environmental and sustainability expectations. Voluntary environmental management systems for agriculture have proven to be worthwhile in several places around the world. Similar programs are both realistic and worthwhile for Midwest corn and soybean growers, especially in light of predicted United States trends: increases in regulatory pressure and market demand for environmental management. Proactive, voluntary environmental stewardship may even ensure that small farmers are not squeezed out of the market when EMSs become mandatory.

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The guidelines received extensive use as an objective tool to document IPM compliance in the Partners with Nature program, which certified over 600 crops on over 100 farms. A discussion of the PWN program is available at: http://www.umass.edu/umext/programs/agro/ipm/educert/pwn.htm

Another application of the Massachusetts IPM guidelines was the assessment of adoption of IPM by sweet corn growers in six northeastern states. The report for this study can be viewed at: http://www.umass.edu/umext/programs/agro/ipm/Reports/craig.html

Massachusetts IPM Guidelines: Crop Specific Definitions, UMass Extension publication IP-IPMA (66 pp.) can be ordered for $6.00 through the UMass Extension Bookstore, Draper Hall, UMass, Amherst MA 01003 and can be also be viewed at the UMass Extension website at: http://www.umass.edu/umext/programs/agro/ipm/ipm_guidelines/

The authors especially thank Vicki Van Zee for her important work during the early phases of this project.
Development of the Massachusetts IPM Guidelines was funded by University of Massachusetts Extension, Massachusetts Department of Food and Agriculture and USDA Extension Service under special project number 94-EPMP-1-0049.

Contact:
Craig Hollingsworth, Ph.D
Extension Educator
Department of Entomology
University of Massachusetts
Amherst MA 01003
Tel: 413-545-1055
Fax: 413-545-5858
chollingsworth@umext.umass.edu