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One Day Left to Save Family Dairy Farmers & Organic Dairy!

by: Jill Richardson

Mon Dec 22, 2008 at 16:54:30 PM PST


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A few months ago (when nobody cared about anything except for the election), the USDA put out some proposed rules for organics. The rules mostly pertained to dairy but there were a few other provisions thrown in that have nothing to do with dairy at all. I would like to believe these rules reflect good intentions by the USDA. I would like to believe that they show the USDA wants to prohibit factory farms from calling themselves "organic" and that is why they proposed the rules.

Unfortunately, if these rules go through unchanged, about half of legitimate organic dairy farmers will no longer qualify as organic. And the comment period ends tomorrow.

Comment here - talking points are below.

Jill Richardson :: One Day Left to Save Family Dairy Farmers & Organic Dairy!
Unfortunately, this proposed rule and its flaws are not easily explained to non-farmers. And I group myself into that category. I've read through the rules and through a critique of the rules, and it went RIGHT over my head. Fortunately, I know a dairy farmer or two from my three years in Wisconsin :) So, I'm putting some talking points below and I hope you will take the 2 minutes to contact the USDA about this.

The long story short of it is this... cows that graze on pasture require less oil than cows that eat grain. For one thing, grass is a perennial so once it's planted, it grows. Also, the cows harvest it themselves, whereas grain must be harvested and then transported to feed the cows. So organic consumers who wish to benefit the environment with their purchase get more for their money when they buy milk from pasture-raised cows.

Also, cows that eat grass actually have an extra cancer-fighting nutrient in their milk called CLA compared to cows that eat grain. Therefore, part of the price you pay for organic milk is because you are getting extra nutrition. In theory at least...

Currently, a few organic dairies are essentially factory farms. The cows don't graze on pasture at all. Therefore, any consumers buying their milk are getting ripped off because they are paying high organic prices for an inferior product. (The brands to avoid are Horizon and Aurora. Aurora is sold as store brand at Wal-Mart, Costco, Target, and Safeway.)

The rules aim to disqualify these factory farms from calling themselves organic. And that is GREAT. I hope that aspect of the rules actually go into effect. But the way the rules are written they will currently disqualify half of legitimate organic dairy farmers as well, and that's no good. Here are the suggested comments to make so that we can kick out the bad guys while keeping the good guys as organic:

Richard H. Mathews
USDA-AMS-TMP-NOP
1400 Independence Ave., SW
Room 4008-So., Ag Stop 0268
Washington, DC 20250

Dear Mr. Mathews-

I am formally commenting on the National Organic Program draft rule [Docket No. AMS-TM-06-0198; TM-05-14].  

I ask that you craft the final rule in such a way as to eliminate abuses on giant factory farms, milking thousands of cows, representing their milk as "organic."

Unfortunately, the current draft rule would not only constrain the industrial-scale dairies but would likely injure or force out of business a high percentage of our nation's ethical organic farmers without some changes.  I ask that you take the following into consideration while making needed changes and revisions:

1. No matter how long it takes to enact this new rulemaking it is clear that the current regulations are perfectly enforceable based on past violations found by the USDA and your statements in the Federal Register October, 24 2008.  I request that the NOP immediately take actions to bring large livestock operations into compliance and continue this diligence until a new rule is enacted.

2. I support the requirement for ruminants to be on pasture for the entire grazing season (but not less than 120 days) and to consume a minimum of 30% of their dry feed from pasture.  Organic livestock should have daily outdoor access whenever conditions permit.

3. I support the alternative rule proposal forwarded by groups representing organic producers including the FOOD Farmers and The Cornucopia Institute with the following alterations.

a. When agricultural products are used for bedding they should be certified organic, based on commercial availability.  Non-organic hay, or other feed likely to be consumed in more than a negligible quantity, should never be allowed.  Do not create a loophole.

b. The continuous transition of conventional animals onto organic dairies should be prohibited.  We encourage the adoption of the NOSB recommendation requiring all cattle brought onto organic farms to be managed organically from the last third of gestation.  

c. Due to the diversity in views, within the organic farming community, the proposal to completely eliminate confining beef cattle for final finishing on grain should be removed from the proposed rule.  Instead, the status quo for limited confinement (the NOSB recommendation: either incorporated into this rule or as guidance)
should be maintained and strictly enforced.  Widespread abuses are now taking place and separate, future rulemaking in this area, involving all organic stakeholders, should be actively pursued.

And finally, please extend the comment period by another 30 days, allowing for a public comment period of 90 days (and ending on January 23, 2009) rather than the 60 day comment period as noticed in the Federal Register announcement of the rule proposal.  As a ((farmer, consumer, retailer - circle one )) I believe a longer public comment period is necessary for these reasons:

1. The USDA's proposed rule is an extensive rewrite of numerous portions of the federal organic livestock regulations.  It requires careful reading to understand and digest its full impact.

2. The proposed pasture rule includes numerous changes to the federal organic regulations that extend beyond the pasture provision as it pertains to dairy, a rule proposal that many in the organic community have been waiting years for.  These new additions must be carefully assessed.

3. The timing of this rule's release, encompassing the harvest season for many farmers, the recent high-profile election and covering much of our nation's holiday season, is difficult for reviewers and slows mail delivery.  An extension of the comment period to January 23, 2009 will greatly help consumers and members of the farm community provide better review and comments.

Thank you for the consideration of my comments and those of many other concerned members of the organic community.

Sincerely,
<you>

For more details than you probably want: Uber-detailed word by word scrutiny of the USDA's rules by a consortium of public interest groups representing organic farmers and consumers (including The Cornucopia Institute and FOOD Farmers).

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Organic pasture rule (4.00 / 2)
Having been a dairy farmer most of my life,and an organic dairy farmer for about half of it, the new rule looks like USDA said,"so you don't like the originals rule, well we'll show you a  rule".

You have hit most of the main points, but in their effort to require more pasture for dairy cattle USDA is now saying cattle must be managed on pasture for 365 days a year.

Yesterday our high temp was 4, and we have about 26 inches of snow. Believe me, there is no pasture out there, the ground is frozen and covered with snow, cows do not want to go outside with a 35 wind chill. We had a calf born a couple of days ago, it would have died outside. So what I am saying is USDA will, by their new rule, get rid of most small organic dairy farmers in the upper Midwest and northeast.

We turn our cows out for exercise in the winter in a concrete yard behind the barn, but under the new rule that will be illegal, pasture only. There are supposedly exceptions for weather that may be "life threatening" (according to whom?), why not just require cows to be on pasture for the grazing season, stored feed and exercise for the rest/that will apply to all regions of the US.

The other big thing is the dairy replacement issue. It is a complicated wordy issue, but my take on it is, once a herd is certified organic, all animals must be managed as as organic all their lives. A certified dairy should not be allowed to buy non-organic animals and "transition" them in.  

My hunch is that the new rule will get so much protest that they will chuck it and stick with the old rule that lets the big dairies keep their cattle in feedlots and away from pasture. But then I'm a cynic.


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