Regarding your July 31 editorial, "A long overdue step toward Food Confidence":

Yes, our food safety system in broken and in need of repair. Yes, industry and the public have both suffered during the dismantling of the Food and Drug Administration under the Bush administration. However, legislative and other efforts to address the consequences of eight years of neglect must be effective, and must not sacrifice our U.S. agricultural and food system and its diversity.

HR2749 as written will not make our food safer in the long run, and if implemented as written will harm U.S. food and agriculture, undermining our food and national security, and harming our economy in the process.

Your editorial claims that any issues remaining in the bill can be fixed by minor changes to be made by the Senate. You refer to Rep. John Dingell's, D-Mich., "persuasive" lament that "Americans are dying because the (FDA) doesn't have the authority to protect them" is at best partially true.

Authority alone does not protect people, authority with capacity does. Authority can be granted with the stroke of a pen; capacity building costs money and takes time. FDA oversees 80 percent of the U.S. food supply, and the U.S. Department of Agriculture oversees 20 percent. In 2007, food safety expenditures at USDA were $892 million, FDA's were $457 million.

FDA would need to be allocated $3.56 billion, an increase of more than $3.1 billion to provide food safety oversight of its 80 percent of the food system to a level comparable to what USDA achieves in its 20 percent. As a result of the systematic gutting of FDA under George W. Bush, we cannot evaluate how effective current laws and regulations would be if sufficient funding had been provided to FDA.

A common-sense approach would be first to properly fund FDA to implement its existing mandates, and then fine-tune the system based on a stakeholder-engaged approach involving regulators, scientists, and the food and agricultural sector along with consumer groups.

Energy and Commerce and its HR2749 have severely abandoned the U.S. food and agricultural industries, while actually threatening the safety and security of the U.S. food system in the process by choosing a fee-based system. Such a system is wrong. Energy and Commerce and its urban-based Consumer Group allies claim the "high ground" on this issue because they initially planned a fee of $2,000 per "food facility," but reduced it to $500. There is no high ground in a fee-based system. Regardless of how it is implemented, it marginalizes U.S. food and agricultural producers and promotes offshore sourcing.

Your editorial claims that HR2749 extends authority of FDA to cover foreign food sources. How is that going to work? What will be the cost and to whom of building that capacity? Overseas facilities will not be contributing fees, they will be the most expensive to oversee, and we will be facing jurisdictional conflicts whenever we attempt to intervene. HR2749 will penalize U.S. food producers, promote unfair and unregulated foreign competition, and ultimately leave us with a less-safe, less-diverse food system in the process.

The $500-per-facility fee is regressive within our own U.S. food system and will seriously undermine the rapidly growing yet fragile movement of healthy local and regional food production, processing and distribution.

The fastest growing agricultural segment in the U.S. is farms and food processors producing under $25,000 per year of product. A recent Congressional Budget Office estimate states that there are 800,000 entities that would qualify as "food facilities" and be subject to the $500 registration fee proposed under HR2749 that are classified as small, and for these, the $500 fee is a significant burden.

There are thousands of us across the country — farmers, ranchers and food producers of all scales, who have been working to create a safe, secure and diverse global food system, within which a strong and diverse U.S. food system provides leadership, secures fair opportunity for U.S. producers, supports U.S. rural economies, and provides healthy and safe food for all consumers.

Steve Warshawer is the founder of Beneficial Farm, a community-sponsored agriculture program in Glorieta.