Ensuring “access to pasture” for organic cows
October 28, 2005
Secretary Mike Johanns
United States Department of Agriculture
Whitten Building – Suite 200A
1400 Independence Ave SW
Washington, DC 20250
Dear Secretary Johanns,
For over five years, thousands of farmers and consumers, through public testimony, formal written comments, letters, emails, and petitions, have communicated with the National Organic Standards Board (NOSB) and the National Organic Program (NOP), articulating grave concern over the growing trend of organic milk production from massive factory farms (3000-5000 milk cows plus young stock).
At issue are a handful of large farms in the arid West that are producing milk on Concentrated Animal Feeding Operations (CAFOs), allowing their animals only token access to pasture.
Even though the organic regulations (§ 205.239) require producers to “maintain livestock living conditions which accommodate the health and natural behavior of animals, including…access to pasture for ruminants” these corporate farm operators are gaming the system and putting family-scale farmers at a serious competitive disadvantage.
NOP staff have come under criticism for rejecting a draft rule change that was promulgated by the NOSB and unanimously adopted by that expert body. Crafted only after careful consideration and significant public input, the rule change would have tightened regulatory language requiring cows to actually “graze”-rather than strictly just have access to pasture-and to very specifically require lactating cows to be pastured, not just young stock and dry cows, as has been the alleged practice on some industrial-scale farms.
Instead of collaborating with NOSB members to promulgate language that would allay the staff’s concerns, while continuing to respect the spirit of the original language, the NOP has scheduled one more in a series of public comment sessions to garner additional input. After five years of earnest participation in the rule making process, organic dairy producers and consumers are unwilling to go to the expense of making one more trek to Washington. All stakeholders have had ample opportunity to participate to date.
If additional public comments focusing on specific staff questions are justified, the Department could certainly accept written input prior to the meeting and still allow for the NOSB to act at their forthcoming meeting. Chairman Jim Riddle has publicly stated, “If scheduled, we will be prepared to take final action on the rule change.”
We appeal to you, Mr. Secretary, to personally intervene and assure that pasture is back on the November NOSB meeting agenda so that final regulatory language can be adopted. We need you to partner with the organic community to protect the integrity of organic farming and food.
Respectfully yours,
(groups listed below)
PS: The organic community is about to lose five of the most knowledgeable and well-spoken leaders on the NOSB who have been addressing this and other critical issues. In the past, the organic community worked in concert with the USDA in order to recruit and retain the highest possible caliber members for NOSB-this is a nonpartisan body of exemplary quality. The Department previously released the names of candidates for the NOSB. This resulted in highly qualified candidates being appointed.
Engaged members of the organic community want to be involved and want to help you, Mr. Secretary, make the best possible choices. I respectfully ask that you please intervene and have the names of all current candidates released publicly so that organic farmers, processors, marketers, and consumers can participate in the appointment process.
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Organizations/Businesses Agricultural Missions, Inc. Animal Welfare Institute Bronx Greens – NY Carolina Farm Stewardship Association Cayuga Pure Organics Center for Rural Affairs Church Women United Concerned Citizens of Central Ohio Cooperative Development Services The Cornucopia Institute Court St Joseph #139, Catholic Daughters of the Americas – BY D’BugLady Pest Management Co. Demeter USA Diocese of Jefferson City DownRiver Alliance Ecological Farming Association – CA Eden Foods Endangered Habitats League Food Animal Concerns Trust (FACT) Farm Sanctuary Friends Fields, Inc. Georgia Chapter of Sierra Club Greenstar Cooperative Market – NY Heavenly Organics, LLC Highlands Bar & Grill – AL Hmong American Comm. Horseheads Grange #1118 – NY The Humane Society of the United States Iowa Citizens for Community Improvement Iowa Farmers Union La Crosse Coalition for Peace and Justice Ladies of Charity – NY Lake Erie West Foodshed Network – OH Michigan Farmers Union Milk Outrage Organization (MOO) National Cooperative Grocers Association Nebraska Wildlife Federation New England Small Farm Institute New Entry Sustainable Farming Project Ohio Family Farm Coalition Organic Consumers Assocation Organic Food Network Public Citizen Northeast Organic Farming Association of Connecticut Northern Plains Sustainable Agriculture Society Politics of Food Rachel’s Network Revitalization Institute River Alliance – Wisconsin The Sierra Club National Agriculture Committee Sierra Club Atlantic Chapter Small Farm Today Sisters of St. Francis of Tiffin – OH Slow Food Pittsburgh Small Planet Institute South Tex Organics, LLC The Southern Cheesemakers’ Guild Southern Sustainable Agriculture Working Group Stellar Certification Services Traders Point Creamery Twin Pines Cooperative Foundation Union of Concerned Scientists UWL Progressives Valley Stewardship Network Virginia Association for Biological Farming Weston A. Price Foundation Weston A Price Foundation, Toledo Chapter Wisconsin Farmers Union Wisconsin Resources Protection Council Cooperative Grocers |
Cooperative Grocers (continued) Harvest Co-op Market – MA Honest Weight Food Co-op – NY La Montanita Coop – NM Lexington Co-op – NY Linden Hills Co-op – MN Marquette Food Co-op – MI Mississippi Market – MN MOMS Food Co-op – MN North Coast Bakery – CA Ocean Beach People’s Organic Food Co-op – CA Open Harvest Cooperative – NE Oryana Natural Foods Market Cooperative – MI Outpost Natural Foods – WI PCC Natural Markets – WA Peoples Food Co-op of Ann Arbor – MI People’s Food Co-op – OR People’s Food Co-op of Kalamazoo – MI Rainbow Natural Grocery – MS Rising Tide Natural Foods Cooperative – ME River Valley Market – MA Selene Whole Foods co-op – PA Sevananda Natural Foods Market – GA Seward Cooperative Grocery and Deli – MN Sacramento Natural Foods Cooperative – CA Stueve Certified Organic – CA Takoma Park Co-op – MD The Food Co-op – WA Weaver Street Market Wedge Co-op – MN Individual Signers — mostly organic farmers |